United States Office of Water (4203) EPA-xxx-x-xx-xxxx

Environmental Protection Washington, DC 20460 March 2001

Agency

Development, Selection, and Pilot Demonstration

of Preliminary Environmental Indicators for the

Clean Water State Revolving Loan Program 

Volume I : Task Force Report
EPA/xxx-x-xx-xxx

March 2001

Development, Selection, and Pilot

Demonstration of Preliminary Environmental

Indicators for the

Clean Water State Revolving Loan Program

Volume I: Task Force Report

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue

Washington, DC 20460

March 2001
Environmental Indicator Task Force Membership

November 2, 1999

CWSRF:

Rich Deringer 

Kong Chiu

EPA Headquarters:

Needs Survey:

Lisa Christ

Office of Planning, Analysis, and Accountability:

Anita Street

Arden Calvert (alternate)

Index of Watershed Indicators:

Karen Klima

Susan Holdsworth (alternate)

Margarete Heber (alternate) 

Office of Wetlands, Oceans, and Watersheds:

Chuck Spooner

Otto Gutenson

AA/Water, Policy and Resource Management

Office

Anne Treash 

Office of Science and Technology

Mahesh Podar

Office of Sustainable Ecosystems, Policy

Coordination Division

Michael Mason

Office of Wastewater Management, Permits

Division

Kelley Volak

EPA Region VIII:

Brian Friel

EPA Region IX:

Juanita Licata

EPA Region V:

Lula Spruill

EPA Region IV:

Betty Barton

States:

Ohio:

Greg Smith

Bob Monsarrat

Theresa Gordon

California:

Bryan Brock

Texas:

Mark Hall

George Green

Clyde Bohmfalk

New Jersey:

Theresa Fenton

Karen Schaffer

Scott Shymon

Michigan:

Chip Heckathorn

Utah:

Walter Baker

Bryan Atwood
Table of Contents

Volume I

Executive Summary ........................................................ i

Chapter 1. Introduction ................................................... 1-1

Background .............................................................. 1-1

The Clean Water State Revolving Loan Fund (CWSRF) Program ..................... 1-2

Funding Summary ......................................................... 1-2

CWSRF Indicator Development and Implementation ............................... 1-6

Chapter 2. Identification of Environmental Indicators for Pilot Testing ............ 2-1

Chapter 3. State Pilot Projects to Test the CWSRF Environmental Indicators ..... 3-1

Selection of States ......................................................... 3-1

Analysis Type ............................................................ 3-1

State Pilot Project Summaries ................................................ 3-2

Other States ............................................................. 3-5

Chapter 4. Evolution of Environmental Indicators ............................. 4-1

Chapter 5. Observations and Recommendations ............................. 4-1

Observations Related to Data ................................................ 4-1

Observations Related to Programmatic Issues .................................... 4-2

Recommendations Related to Data ............................................ 4-3

Recommendations Related to Programmatic Issues ................................ 4-4
List of Tables

Table 2-1. Evolution of CWSRF Indicators from Draft 1998 Report to Pilot Testing ..... 2-1

Table 3-1. Partial Summary of State Pilot Projects ................................ 3-1

Table 3-2. Partial Summary of California Analysis ................................. 3-2

Table 3-3. Partial Summary of Ohio Analysis .................................... 3-3

Table 3-4. Partial Summary of Texas Analysis ................................... 3-3

Table 3-5. Partial Summary of New Jersey Analysis ............................... 3-4

Table 3-6. Partial Summary of Utah Analysis .................................... 3-5

Table 3-7. Partial Summary of Maryland Analysis ................................ 3-6

Table 4-1. Evolution of CWSRF Indicators from Draft 1998 Report Through Pilot Testing 

Process and Final Proposed Indicators ................................. 4-1

List of Figures

Figure 1. Percent of $26.1 Billion Total CWSRF Assistance (1988-1999) by Category. .... 1-4

Figure 2. Percent of Yearly Total CWSRF Funding for Eight Categories of Wastewater

Treatment. ....................................................... 1-5

Figure 3. Percent of Yearly Total CWSRF Assistance Funding for Collection and Treatment 

Projects ......................................................... 1-5

Volume II

Introduction

Appendix A. Force Membership

Appendix B. Generic Scope of Work for Pilot Project

Appendix C. Pilot Project Data Entry Questionnaire

Appendix D. Pilot Project Data Summary

Appendix E. State Reports on Pilot Project Experience 

Appendix F. Ohio Pilot Project Specific Examples

Appendix G. Ohio EPA Biological Indicators

Appendix H. Ohio EPA Sampling Fact Sheet 

Executive Summary
March 2001 i

Environmental indicators have been under development at the U.S. Environmental Protection

Agency (EPA) for more than a decade. Government-wide programs such as the Government

Performance Review Act and National Environmental Performance Partnerships, as well as the

environmental goals and milestones of EPA’s Strategic Plan, establish the need for outcome-based

measures like environmental indicators. EPA conducted a feasibility analysis, developed a

methodology, and identified available resources for developing environmental indicators and

applying them to the Clean Water State Revolving Fund (CWSRF) program in 1998. EPA’s

Office of Wastewater Management established a federal-state Task Force to propose and oversee

the pilot feasibility testing of a series of environmental indicators specific to the CWSRF program. 

Participating states cooperated in testing a range of environmental indicators to determine the

feasibility of the indicators and their applicability to their respective state CWSRF programs.

This report presents the findings of the Task Force, which evaluated a preliminary set of

environmental indicators developed for the CWSRF. Pilot testing was used as an approach to

evaluate whether data exist to support the selected indicators, and how easy or difficult it is to

apply the data to the environmental indicators. Based on the findings of this pilot testing,

recommendations are presented on how to proceed with the development and application of

environmental indicators to the CWSRF (i.e., to continue with or eliminate one or more of the

pilot indicators). California, Ohio, and Texas were selected to conduct environmental indicator

pilot projects. Michigan, New Jersey, and Utah also agreed to participate as pilot states. Each

state reviewed a subset of its projects funded through the use of the CWSRF and applied

environmental indicators to ascertain whether it could measure or otherwise reflect environmental

improvement as a result of the implementation of the projects.

Following initial conference calls, the Task Force members revised, developed, and discussed six

indicators. The states then conducted pilot projects to test as many of the proposed indicators as

they could apply to CWSRF projects in each of their respective states. Next, states modified the

indicators resulting in the following suite of final indicators: 

(1) Actions funded by CWSRF programs. The Task Force recommends using this indicator as an

indirect measure of the contribution state CWSRF programs make to achieving Clean Water Act

objectives because this indicator would be useful in situations where there is an absence of any

other information regarding CWSRF-financed projects; 

(2) Number of pounds of pollutants removed from the environment through CWSRF-funded

projects (Point source oriented). This indicator is suitable for projects with influent and effluent

data available. The indicator may also be used where pollutant loading levels in the receiving

stream are quantified and are expected to decrease as a result of the CWSRF-funded project. It

has remained consistent in focus throughout the indicator development stages; 

(3) Number of pounds of pollutants prevented from entering the environment through CWSRFfunded projects. This indicator is proposed as a prevention measure. It is suitable for projects

that aim to reduce loading “to” or within a treatment facility, expand plants to handle increased

population, and address nonpoint sources of pollution;

(4) Physical changes to the terrestrial, riparian, or aquatic habitat and hydrology as a result of
ii March 2001

CWSRF-funded projects. This indicator is proposed for the category of CWSRF-funded projects

that cannot be measured by load reduction or projected load prevention. Habitat destruction and

hydromodification are major causes of aquatic life impairment, surpassing organic enrichment and

dissolved oxygen impacts in some states. This indicator measures changes in land use (such as a

change in agricultural tillage practices or restoration of a riparian stream corridor) and other

attributes of the physical environment that could affect the aquatic community; 

(5) Waterbodies, expressed as river and riparian miles, lake acres, estuary square miles, and

wetland acres, previously impaired, now improved or meeting designated uses, as a result of

CWSRF-funded projects. This indicator proposes to measure water quality conditions in terms of

designated uses for a distinct subset of waterbodies, impairment is quantified and reported as not

meeting water quality standards and designated uses. 

(6) Waterbodies, expressed as river and riparian miles, lake acres, estuary square miles, and

wetland acres, protected as a result of CWSRF-funded projects. This indicator has a clear focus

on protection of unimpaired resources; and 

(7) Reduced health risks and/or increased recreational use attributable to CWSRF-funded

projects. The indicator is important because it monitors a Clean Water Act objective. The data

used for this indicator should be collected by a regulatory agency or collected in a manner that is

subject to quality assurance and quality control procedures to ensure their accuracy. Problems in

using this indicator occur when sampling is lacking or inadequate to draw conclusions. Ideally,

bacteriological samples should be taken during low seasonal flows and at strategic locations, and

the sampling should be done before and after project completion.

The Task Force report covers both data and programmatic observations and recommendations. It

was observed that some states have suffered budget cutbacks in the area of environmental

monitoring, including ambient monitoring. A lack of environmental baseline data undermines a

state’s ability to directly measure environmental improvements that could be evident as a result of

implementing environmental programs and improvements such as the CWSRF. Without ambient

monitoring data, states that conduct only limited water quality monitoring would be hardpressed

to demonstrate actual environmental improvements as a result of environmental infrastructure

improvements through CWSRF funding. In order to document environmental improvement, the

Task Force believes that more data are needed to support environmental indicators for nonpoint

source (NPS) projects. A broader scope of data types beyond traditional 

water quality parameters would be appropriate to better demonstrate environmental improvement

from CWSRF-funded projects.

Under programmatic issues it was observed that environmental data at the project level are not

reported or tracked by most states, and none of the information is reported to EPA. States do not

have procedures in place to collect information on environmental outcomes related to CWSRF

projects, or on whether they were the result of the combined efforts of many programs. There are

a wide variety of approaches at the state level that could be used to report on environmental

improvements associated with CWSRF-funded projects.

The environmental indicators identified in this report represent the start of an evolutionary

process. As the states gain experience in trying to measure environmental progress by using those
March 2001 iii

indicators, additional or revised indicators are likely to surface, and use of geographic information

systems to detect progress is expected to be expanded. Additionally, determination of total

maximum daily loads and other monitoring efforts are likely to increase the amount of information

that is available. Because of the diversity among the states, the environmental indicators are

presented as a “suite” of indicators to be used at each state’s discretion according to its individual

needs.
Chapter 1. Introduction
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

March 2001 1-1

Chapter 1. Introduction

Background

Environmental indicators have been under development at the U.S. Environmental Protection

Agency (EPA) for more than a decade. Environmental indicators have been defined in many

ways: as biological, chemical, or toxicological constituents of the environment that define risk

levels; as trend measurements that describe improving or degrading conditions; and as

mechanisms to demonstrate the effectiveness of environmental projects and programs. Initially,

EPA environmental indicators were an outgrowth of the need for comprehensive and up-to-date

environmental assessment information used for internal planning and budgeting. More recently,

indicators have been recognized as an important tool for measuring and communicating

environmental progress and for demonstrating progress and accountability. Government-wide

programs such as the Government Performance Review Act and National Environmental

Performance Partnerships, as well as the environmental goals and milestones of EPA’s Strategic

Plan, establish the need for outcome-based measures like environmental indicators.

In 1998 EPA conducted a feasibility analysis, developed a methodology, and identified available

resources for developing environmental indicators and applying them to the State Revolving Fund

(CWSRF) program. This resulted in publication of a draft report, Environmental Indicators for

the Clean Water State Revolving Fund (EPA 832-D-98-002). One of the recommendations of

the report was that EPA should establish a workgroup with significant state and regional

participation to continue the development and implementation of indicators. Another

recommendation was to adopt a process to shape the development of indicators in a stepwise

manner that would clearly articulate EPA’s desire for states to shift CWSRF funding toward NPS,

estuary, and wetland projects. The report also made the observation that traditional CWSRF

projects may employ a set of environmental indicators different from those that pertain to NPS

and wetland projects.

In response to these recommendations, EPA’s Office of Wastewater Management established a

federal-state Task Force to propose and oversee the pilot feasibility testing of a series of

environmental indicators specific to the CWSRF program. The Task Force, which consists of

representatives from six CWSRF programs, four EPA regions, and eight EPA water program

offices, has participated in monthly conference calls since January 1999. In addition to

participating in conference calls, participating states cooperated in testing a range of

environmental indicators to determine the feasibility of the indicators and their applicability to

their respective state CWSRF programs. 

The purpose of this report is to present the findings of the Task Force, which evaluated a

preliminary set of environmental indicators it developed for the CWSRF. Pilot testing is being

used as an approach to evaluate whether data exist to support the selected indicators, and how

easy or difficult it is to apply the data to the environmental indicators. Based on the findings of

this pilot testing, recommendations are presented on how to proceed with the development and

application of environmental indicators to the CWSRF (i.e., to continue with or eliminate one or

more of the pilot indicators).
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

1-2 March 2001

This chapter provides background information on the CWSRF pilot indicator project, discusses

the CWSRF program, and summarizes funding. CWSRF indicator development, Task Force

membership, and steps for applying the pilot environmental indicators to the projects also are

outlined in the chapter. Chapter 2 explains the proposed pilot environmental indicators. Chapter

3 discusses how states were selected to conduct pilot projects and summarizes state approaches. 

Also included in Chapter 3 are segments written by individual states, detailing their experience

and their successes and failures while conducting pilot indicator projects. Finally, Chapter 4

presents succinct findings and recommendations from the states as a result of their work on the

CWSRF pilot environmental indicators.

The State Revolving Loan Fund (CWSRF) Program

The Nation has invested billions of dollars on wastewater infrastructure. In 1972 Congress

established the Construction Grants Program to provide grants to assist local governments in

constructing wastewater treatment facilities. The federal grants constituted a large percentage of

the funding for these projects. In 1987 the grant program began a phaseout with a transition to a

state revolving loan program. States now receive CWSRF capitalization grants, which are

matched at a rate of one state dollar for every five federal dollars. Loans are then made by the

states for eligible projects and activities. Repayments on the initial loans are reloaned, thus

establishing the “revolving” nature of the CWSRF program.

The states have considerable flexibility to develop and operate CWSRF programs that meet their

particular needs. Two types of federal requirements are imposed on state CWSRF programs:

"cross-cutting" authorities, which are the environmental, economic, and social policy requirements

that apply to all federal grant programs (e.g., equal employment opportunity, participation by

minority-owned businesses) and CWA Title II requirements (which include federal wage rate

requirements, value engineering, cost-effectiveness requirements, and so forth). Title II

requirements apply to only those projects wholly or partially financed before fiscal year 1995 with

funds directly made available by federal capitalization grants.

Despite outstanding progress since 1972 in reducing water pollution and restoring our rivers,

lakes, and coastal water, serious water pollution problems persist. About 40 percent of the

nation’s waterways assessed by states are still unsafe for fishing and swimming. A continued

federal financial commitment will be necessary to meet the promise of clean, safe water for all

Americans. This is particularly true as states continue to expand use of the CWSRF to address

estuary, storm water, and NPS pollution management projects to preserve past water quality gains

and strengthen our future efforts.

Funding Summary

The EPA Office of Wastewater Management tracks the financial performance of projects funded

through the CWSRF. During the period 1988 to 1999, the CWSRF program provided

approximately $26.1 billion in assistance to a variety of projects throughout the nation. Of this

total, approximately 95 percent of the CWSRF funding was used to support wastewater

treatment-related projects for publicly owned treatment works (POTWs), about 4 percent of the

funding was directed to nonpoint source projects, and less than 1 percent went to estuary projects

(Figure 1). Although the latter two categories of projects represented 20 percent of the number 
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

March 2001 1-3

Secondary Treatment

45.1%

New Interceptor Sewers

12.5%

New Collector Sewers

7.0%

Infiltration/Inflow Correction

3.2%

Advanced Treatment

14.9%

Combined Sewer Overflow 

Correction 

6.4%

Storm Sewers

0.2%

Rehabilitation of Sewer Systems

5.7%

Nonpoint Source

3.9%

Estuaries

1.1%

Figure 1. Percent of $26.1 Billion Total CWSRF Assistance (1988-1999) by Category.
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

1-4 March 2001

of projects funded by the CWSRF program, the projects tended to be of much smaller scale than

the wastewater treatment-related projects. For example, the average wastewater treatment

project used $3.71 million of CWSRF funds, whereas the average nonpoint source project

received $1.06 million and the average estuary project only $550,000. It also should be noted

that five states—Delaware, Minnesota, Ohio, New Jersey, and Wyoming—accounted for almost

84 percent of all of the nonpoint source projects. Only Washington State used CWSRF funding

for estuary projects.

Wastewater treatment-related projects accounted for over half of the CWSRF funding. These

monies were allocated among the following eight categories of projects: secondary treatment,

advanced treatment, infiltration/inflow correction, rehabilitation of sewer systems, new collector

sewers, new interceptor sewers, combined sewer overflow correction, and storm water/storm

sewers. Secondary treatment projects accounted for over one-half of the total funding ($11.79

billion), followed by advanced treatment ($3.9 billion) and new interceptor sewers ($3.28 billion). 

Storm sewer projects accounted for only $46.4 million of the funding compared to approximately

$1.5 billion each for combined sewer overflow, new collector sewers, and rehabilitation of sewers. 

Finally, funding for infiltration/inflow correction totaled approximately $846 million.

Figure 2 presents the change in percentage of total 1988 to 1999 CWSRF funding dollars by year. 

Figure 3 compares the percentage of CWSRF assistance allocated between treatment (advanced

and secondary) and collection (new interceptor sewers and new collector sewers) projects.
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

March 2001 1-5

0.00

0.10

0.20

0.30

0.40

0.50

0.60

0.70

1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999

% of Yearly Funding

Secondary Treatment

Advanced Treatment

Infiltration/Inflow Correction

Rehabilitation of Sewer Systems

New Collector Sewers

New Interceptor Sewers

Combined Sewer Overflow Correction 

Storm Sewers

Figure 2. Percent of Yearly Total CWSRF Funding for Eight Categories of Wastewater Treatment.

0.00

0.10

0.20

0.30

0.40

0.50

0.60

0.70

0.80

0.90

1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999

% of Yearly Funding

Collection (New Collector

and New Interceptor Sewers)

Treatment (Advanced and

Secondary)

Figure 3. Percent of Yearly Total CWSRF Assistance Funding for Collection and Treatment Projects.
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

1-6 March 2001

Most CWSRF agreements have focused on areas where the population served is less than 10,000,

although these projects represent only 21 percent of the total CWSRF funds provided. Projects in

large population centers (areas with population greater than 100,000), on the other hand,

represent only 12 percent of the agreements but received 44 percent of the funding.

Although the CWSRF is a loan program, not a grant program, it provides a substantial subsidy to

communities through discounted interest rates on the assistance provided. The loan principal

repayments and interest payments are made available for future projects and represent

approximately 14 percent of the total funds available.

CWSRF Indicator Development and Implementation

A Task Force (subgroup of the State/EPA Clean Water State Revolving Fund Work Group) was

created to investigate the development of environmental indicators for potential use in the

CWSRF program. The Task Force includes 15 to 20 participants (listed in Appendix A) who

have worked on this assignment one or two days per month since January 1999. Members were

drawn from states, EPA regions, and EPA headquarters. Their objective was to develop a set of 

indicators mostly drawn from a preliminary list developed by Tetra Tech, Inc., and as contained in

Environmental Indicators for the Clean Water State Revolving Fund, and to pilot test a set of

environmental indicators for the CWSRF program. 

California, Ohio, and Texas were selected to conduct environmental indicator pilot projects.

Michigan, New Jersey, and Utah also agreed to participate as pilot states. Each state reviewed a

subset of its projects funded through the use of CWSRF and applied environmental indicators to

measure environmental improvement as a result of the implementation of the projects. 

Information also is included from an effort to gather data from several other states for use in

testing the feasibility of the indicators. This effort met with only limited success. The

environmental indicators for the CWSRF program selected to be pilot tested are presented below. 

Note that these environmental indicators are not ranked, and their presentation in this order does

not reflect relative priorities.

• Number of pounds of pollutants removed from the environment through CWSRF-funded

projects.

• Number of pounds of pollutants prevented from entering the environment through CWSRFfunded projects. 

• Increase in biophysical benefits or reduction in biophysical stressors by changing land use

practices and resource harvesting and extraction practices through CWSRF-funded projects.

• Waterbodies, expressed as river and riparian miles, lake acres, estuary square miles, and

wetland acres, previously impaired, now meeting designated uses as a result of CWSRFfunded projects.

• Waterbodies, expressed as river and riparian miles, lake acres, estuary square miles, and

wetland acres, protected or improved as a result of CWSRF-funded projects.

• Benefits of reduced health risks and/or increased recreational use attributable to CWSRFfunded projects.

The Task Force used the first four meetings (conference calls) to review, revise, and comment on

the environmental indicators as they could be applied to the CWSRF program. An informal rating
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

March 2001 1-7

and evaluation format was produced and applied by each Task Force member to the six proposed

environmental indicators to do this preliminary evaluation. Ultimately, however, it was agreed

that further refinements to this language should await the states’ experience during the actual pilot

testing phase. Chapter 2 provides a more detailed discussion of each proposed environmental

indicator.

The objective of this pilot phase was to examine more closely the feasibility of measuring

environmental outcomes and making linkages back to the CWSRF program activity with the

proposed environmental indicators. The pilot states investigated and reported on the availability

of data and the mechanisms (systems) to provide those data. States received a generic scope of

work (Appendix B), which was intended to help establish consistency among the pilot projects

and allow the results to be compared more consistently.

The steps of the generic scope of work included the following:

1. Identification of Type and Scope of Projects to Evaluate

States determined the type and number of CWSRF projects to be evaluated. Each state used a

consistent methodology to identify its own projects, although this methodology differed between

states.

2. Data Collection

States searched electronic and paper databases and project files to collect baseline data on each

CWSRF project. The purpose of this task was not only to collect the necessary data to apply

each indicator, but also to document the ease or difficulty of collecting the data. Data collected

for each selected project would encompass project-specific information as well as the

environmental data related to the project. Water quality conditions before and after project

implementation are critical environmental data sets.

The states were asked to document data collected using data source criteria, including

• Availability/accessibility of data (ease of acquiring information; were data out there?)

• Temporal coverage (period of time the data covered?)

• Spatial coverage (latitude/longitude, watershed, stream length)

• Technical credibility (quantity, diversity, robustness; comfort level with the data)

One tool used for managing collected project data was a questionnaire, which was available to

states online and in hard copy (Appendix C). The web-based questionnaire was presented in three

successive pages entitled Project Information, Indicator Information, and Data Information. A

respondent could enter information for one project at a time, continuing through the three pages

for each project. Upon entry of the last input screen, the data were stored in a database.

3. Data Synthesis and Analysis

All data collected were synthesized in tabular or other format for display and analysis. Types of

CWSRF-funded projects were tallied along with water quality and environmental condition data. 

The analyses of the results are presented in brief written descriptions from New Jersey, Michigan,

California, Ohio, Utah, and Texas, with discussions on validity/accuracy, data comparability, and
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

1-8 March 2001

scope/applicability. Finally, results of assessing the data from the states that Tetra Tech evaluated

(Delaware, Maryland, and Washington) also are presented.

4. Indicator Evaluation

The environmental indicators applied in each state were evaluated. A brief narrative is presented

about the application of the environmental indicator against the following evaluation criteria:

• Data sources

• Data quality/quantity

• Data availability (how available; how long did it take to evaluate and compile the data?)

• Data accessibility

• Representativeness

• Comparability

• Cost-effectiveness

• Ease of implementation

5. Reports

Each state prepared and submitted a written report on its findings. Recommendations about how

to best incorporate data requirements and identification of any barriers to using or accessing data

were included in the narrative. Chapter 3 presents a summary of results of the states’

participation in the environmental indicator pilot project. Appendix D provides a more detailed

summary of states’ projects and the full state reports are presented in Appendix E and F.
Chapter 2. Environmental Indicators for the Clean Water SRF Program
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

March 2001 2-1

Chapter 2. Environmental Indicators for the Clean Water SRF Program

Introduction

This chapter presents, in tabular format, the environmental indicators identified in the 1998 EPA

Report “Environmental Indicators for the Clean Water State Revolving Fund” and describes the

environmental indicators, based on this report, that were developed by the Task Force for pilot

testing by the participating states. The results for each state’s experience with the pilot set of

indicators are presented in Chapter 3. The final set of environmental indicators is found in

Chapter 4. 

Table 2-1. Evolution of CWSRF Indicators from Draft 1998 Report to Pilot Testing

October 1998 Indicators April 1999 Pilot Indicators

1. Pounds of pollutants removed from the environment

through CWSRF-funded projects.

1. Number of pounds of pollutants removed from the

environment through CWSRF-funded projects. (Point

source oriented)

2. Pounds of pollutants prevented from entering the

environment through CWSRF-funded projects.

2. Number of pounds of pollutants prevented from

entering the environment through CWSRF-funded

projects. (Oriented toward NPS or no discharge)

3. Reduction in biophysical stressors by changing

land use practices, resource harvesting practices, and

resource extraction practices through CWSRF-funded

projects.

3. Increase in biophysical benefits or reduction in

biophysical stressors by changing land use practices,

and resource harvesting and extraction practices

through CWSRF-funded projects.

4. Waterbodies, expressed as river and riparian miles,

lake acres, estuary square miles, and wetland acres,

previously impaired, now meeting designated uses, as

a result of CWSRF-funded projects 

4. Waterbodies, expressed as river and riparian miles,

lake acres, estuary square miles, and wetland acres,

previously impaired, now meeting designated uses, as

a result of CWSRF-funded projects.

5. Waterbodies, expressed as river and riparian miles,

lake acres, estuary square miles, and wetland acres,

protected, improved, or restored as a result of

CWSRF-funded projects.

5. Waterbodies, expressed as river and riparian miles,

lake acres, estuary square miles, and wetland acres,

protected, improved, or restored as a result of

CWSRF-funded projects.

6. Benefits of reduced health risks or increased

recreational use attributable to CWSRF-funded

projects.
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

2-2 March 2001

Indicator Development

1. Number of pounds of pollutants removed from the environment through CWSRF-funded

projects.

This indicator is suitable for projects where influent and effluent data is widely available. It may

also apply where loading levels in a receiving stream are quantified and are expected to decrease

as a result of the CWSRF-funded project. 

2. Number of pounds of pollutants prevented from entering the environment through

CWSRF-funded projects.

This indicator is proposed as a prevention measure. It is suitable for projects that reduce loadings

either to or by a treatment facility, expand plants to handle increased flows, and prevent nonpoint

sources of pollution. 

3. Increase in biophysical benefits or reduction in biophysical stressors by changing land

use practices, and resource harvesting and extraction practices through CWSRF-funded

projects.

In October 1998 this indicator read, “Reduction in biophysical stressors by changing land use

practices, resource harvesting practices, and resource extraction practices through CWSRFfunded projects.” The Task Force revised the indicator in 1999 by adding the possibility of an

increase in biophysical benefits as another measure of the land use and resource extraction

practices. 

This indicator is proposed for the category of CWSRF-funded projects that cannot be measured

by load reduction or projected load prevention. This indicator can help quantify the wide variety

of nonpoint source, restoration, and preservation activities funded by the CWSRF.

4. Waterbodies, expressed as river and riparian miles, lake acres, estuary square miles, and

wetland acres, previously impaired, now meeting designated uses, as a result of CWSRFfunded projects.

This indicator proposes to measure water quality conditions for a distinct subset of waterbodies

where impairment is quantified and reported as not meeting water quality standards and

designated uses. This indicator focuses on waterbodies that were determined to be degraded to

some extent by a cause or source attributable to a problem that was remedied by a CWSRF

project(s). The criteria that are used to determine the degradation may be the same as those used
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

March 2001 2-3

to establish a state’s 303(d) list. These data could include chemical, physical and/or biological

criteria, but will vary from state to state. Information should be available in each state’s 305(b)

water quality report as to the condition of waterbodies with respect to their designated aquatic life

habitat uses. The problems addressed by the CWSRF project should be clearly described in the

environmental assessment for that project.

5. Waterbodies, expressed as river and riparian miles, lake acres, estuary square miles, and

wetland acres, protected, improved, or restored as a result of CWSRF-funded projects.

This indicator is a more comprehensive measure of ambient water quality conditions than

Indicator 4. This indicator, as proposed, initially would be less precise by not having an

established baseline of impairment against which to measure progress (unless the CWSRF project

quantifies the level of impairment prior to the start of the project). 

With the current emphasis through the Total Maximum Daily Load (TMDL) process on impaired

waters, the group wanted to identify the importance of keeping fully attaining surface waters from

becoming impaired. The CWSRF program should address problems that will cause impairments to

water quality before the problems become apparent and before enforcement action is required. 

This indicator serves to focus attention on areas of attainment and the importance of using

CWSRF resources to ensure maintenance of attainment. 

6. Benefits of reduced health risks or increased recreational use attributable to CWSRFfunded projects.

The indicator is important because it monitors a Clean Water Act objective. The data used for this

indicator should be collected by a regulatory agency or collected in a manner that is subject to

quality assurance and quality control procedures to ensure their accuracy. Although it may be

difficult to establish distinctions as to the degree of human health risk posed by different sources

of pollution, the presence of indicator bacteria (e.g., E. coli, fecal coliform) associated with fecal

matter at levels above established threshold concentrations indicates the presence of health risks

from pathogens. If an CWSRF project addressed a source of this problem, then reduction of

bacterial concentration subsequent to project completion would indicate that the CWSRF project

contributed to reducing risks to human health.
Chapter 3. State Pilot Projects to Test the CWSRF Environmental Indicators
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

March 2001 3-1

Chapter 3. State Pilot Projects to Test the CWSRF Environmental Indicators

Selection of States

California, Ohio, Texas, New Jersey, Michigan, and Utah participated as pilot states for the

testing of CWSRF environmental indicators. Tetra Tech also contacted other states, including

Delaware, Maryland, and Washington, to test the data collection process.

Analysis Type

Projects were selected by the pilot states on a program-wide, project-specific, or watershed/

subwatershed-level basis. California originally proposed to evaluate a randomly selected number

of projects (approximately 20 to 30) that were completed during the 1992 to 1993 period. Ohio

proposed to identify all projects funded through the CWSRF and then select for evaluation only

those projects for which water quality and other project-specific data were available and could be

applied to the six pilot environmental indicators. Texas employed a subwatershed or stream

segment approach and evaluated all projects completed within each subwatershed. Table 3-1

gives a brief summary of state project analyses.

Table 3-1. Partial Summary of State Pilot Projects

Pilot States Type of Analysis No. of Relevant CWSRF Projects Reported

 California program-wide 4

 Ohio project-specific 15

 Texas watershed-level 22

 Michigan program-wide 0

 New Jersey project-specific 9 

 Utah project-specific 8

Other States

 Delaware project-specific 0

 Washington project-specific 0

 Maryland project-specific 4
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

1

In February 2000 two additional indicators were suggested–Indicators A and B. Ohio and New Jersey

evaluated these indicators.

3-2 March 2001

State Pilot Projects

This report reflects the state evaluations of the April 1999 indicators1 and subsequent information

collected from the states. 

See Appendix A for the state contacts and Appendix D for a detailed summary of project data for

each state. Appendix E contains individual state write-ups of their projects.

California

From a program-wide perspective, California evaluated a total of 10 to 12 projects, some of

which were nonpoint source projects. California has collected information on four projects to

date, all of which were related to publicly owned treatment works (POTWs) (Table 3-2). 

Different people involved in the CWSRF projects filled out questionnaires by hand to submit the

data to Tetra Tech. Data came from the project files, health departments, regional water quality

districts, and self-monitoring data. To date, only the self-monitoring data from POTWs are easily

available. These types of data satisfy Indicators 1 and 2 (loadings-related indicators). A cursory

search for information on nonpoint source projects was not productive.

Table 3-2. Partial Summary of California Analysis

April 1999 Indicator Used CWSRF Project Type Number of Projects

1, 2 Secondary treatment 2

None New interceptor sewers 1

5 Advanced treatment; infiltration/inflow

correction

1

Ohio

The state of Ohio has a wealth of in-stream monitoring data, including biological, physical, and

chemical data. A total of fifteen projects were evaluated using Ohio’s Water Quality Inventories,

technical and permit support documents, Water Pollution Control Loan Fund (Ohio’s CWSRF)

environmental assessments and project records, water quality standards, and field notes from the

monitoring staff (Table 3-3). These projects consisted of predominantly wastewater treatment

plant (WWTP) improvements. In general, project evaluation reflected a reduction of one or more

chemical or bacteriological pollutants to the receiving streams and a corresponding response in

the biological communities.
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

March 2001 3-3

Table 3-3. Partial Summary of Ohio Analysis

April 1999 Indicator Used CWSRF Project Type Number of Projects

A, 1, 4, 5, 6 WWTP improvements 10

A, 1, 2, 4, 5, 6 WWTP improvements 1

A, 1, 4, 5 Landfill; new interceptor sewers/WWTP improvements 2

A, 1, 2, 4, 5, 6, B WWTP improvements 1

A, 4, 5 Centralized collection system 1

Texas

Texas used a subwatershed or stream segment approach to identify its pilot projects. Texas

focused on comparing the current 303(d) list to 305(b) data from 1983-1987. Texas used these

as a before-and-after picture to identify three types of waterbodies: (1) waters previously impaired

that are no longer impaired, (2) waters previously impaired and still impaired, and (3) waters

previously unimpaired and currently unimpaired.

Texas submitted data to Tetra Tech on faxed questionnaires describing waters previously

impaired that are no longer impaired. Although the state listed the project indicator as Indicator 1

(Number of pounds of pollutants removed from the environment through CWSRF-funded

projects), the actual data are qualitative. For example, loadings from nutrients might have been a

reason a stream segment was listed as impaired on the 305(b) report, and when it was listed on

the 303(d) list as no longer impaired, it was assumed the nutrient loadings had been reduced in the

stream segment.

Texas later evaluated approximately 22 projects in various CWSRF project categories, ranging

from wastewater treatment plant expansions to nonpoint source pollution projects (Table 3-4).

Table 3-4. Partial Summary of Texas Analysis

April 1999 Indicator Used CWSRF Project Type Number of Projects

1, 2, 4 Texas did not explicitly distinguish project type. 22

New Jersey

New Jersey provided information on nine projects completed in 1993 and 1994, six of which were

POTWs (Table 3-5). None of the projects addressed nonpoint source pollution. New Jersey also

reviewed information on other projects that received CWSRF loans to determine if other means to

establish quantitative or qualitative information were available to support the six pilot indicators. 

New Jersey also provided support for the new indicator A by evaluating state and CWSRF funds

as an indirect indicator of potential water quality improvement.

Tetra Tech retrieved data from EPA’s Storage and Retrieval (STORET) database system to

evaluate some of the New Jersey projects. Trends before and after projects could be identified in
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

3-4 March 2001

only two cases for some pollutant parameters. However, the state could not directly link the

CWSRF as a cause of the changes, as opposed to other factors involved.

Table 3-5. Partial Summary of New Jersey Analysis

April 1999 Indicator Used CWSRF Project Type Number of Projects

1 Secondary treatment 5

2 Advanced treatment 1

None Sewer replacement/rehabilitation 1

2 New collector sewers 1

None Pump station rehabilitation/replacement 1

Michigan

Michigan did not provide project-specific information, but did produce a detailed description of

its Priority Listing Procedure for ranking projects for which CWSRF funding has been requested. 

The system relies on measures of environmental needs. Modeling is used to estimate in-stream

conditions resulting from existing discharges and those expected after project completion. The

differences between these two simulations are used to assign funding priority to projects.

Historically, Michigan maintained an ambient monitoring network of surface water quality

sampling sites, but nearly all of these efforts have been eliminated over the past 15 years. 

Discharge Monitoring Report (DMR) data are available only for permitted point source

dischargers, and no reliable sampling record of nonpermitted discharges or discharges to

groundwater is available. Hence, although the Michigan priority models simulate pre-project

conditions, they can be used for Indicators 1 and 2.

Utah

Utah originally worked with eight CWSRF projects (all point sources—treatment plants and

interceptors, as well as new systems replacing failed on-site disposal systems [septic systems])

(Table 3-6). They investigated loading reductions to support Indicators 1 and 2, but faced

challenges different from those posed to surface water discharges. As data sources Utah relied on

DMRs (referred to as Monthly Operating Reports in Utah), STORET data, and self-monitoring

reports from POTWs. Loadings extrapolated from septic systems were also evaluated, but the

data are less obvious than discharges to a receiving waterbody.

Utah reported on projects by using the on-line questionnaire. They provided specific loading

numbers for Indicators 1 and 2. Utah also compared a 1987 (pre-CWSRF) 303(d) list of impaired

water to the most recent list. No information was evident to support water quality improvement

identifiable under indicators 4 and 5.
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

March 2001 3-5

Table 3-6. Partial Summary of Utah Analysis

April 1999 Indicator Used CWSRF Project Type Number of Projects

None applicable Secondary treatment (biosolids) 1

2, 4 Advanced treatment 1

2 Secondary treatment; new collector sewers; new

interceptor sewers

2

2 Secondary treatment; new interceptor sewers 2

2 New interceptor sewers 1

2 New collector sewers; new interceptor sewers 1

Other States

Delaware

To obtain past CWSRF project information from Delaware, Tetra Tech contacted the Department

of Natural Resources and Environmental Control (DNREC). In response to questions about the

number, type, and location of projects funded by CWSRF loans, the program manager of the

DNREC Division of Water Resources, Financial Assistance Branch, stated that most of the

information was related to individual homeowners and septic system replacement/repair. Because

this is proprietary information, Tetra Tech did not pursue the information, which might have

violated the involved parties’ privacy.

Next, Tetra Tech contacted the U.S. EPA Region 3 office in Philadelphia, Pennsylvania. EPA

said it did not have quantitative information on specific projects because that kind of decision is

made only at the state level. Qualitatively, EPA added that the CWSRF projects in Delaware

were funded on a first-come, first-served basis, and not according to any priority system based on

water quality needs. EPA had access to the total amount that Delaware loaned out in its CWSRF

program, but any information on specific projects (location, description, type) was maintained at

the state level.

Because Tetra Tech was able to obtain information on only one project (City of Seaford sewer

system upgrade) and information on the majority of the projects was not available, the Delaware

data were not particularly useful.

Washington

Tetra Tech developed a list of 12 specific completed CWSRF projects in Washington State. The

list consisted of a combination of the three types of projects (point, nonpoint, estuary) to be

evaluated using the indicators. Target projects were chosen based on date of completion and

project type.
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

3-6 March 2001

The Washington Department of Ecology stated that in-depth project information was not housed

at state headquarters and suggested that the regional office or specific project managers in the

cities or counties where projects were completed be contacted. Contacts in the regional office of

the Washington Department of Ecology informed Tetra Tech that it is likely that project

information for completed CWSRF projects is archived off site. Access to on-site files in the

regional office was limited due to a recent fire in the office. Attempts to contact project managers

at the city level were largely unsuccessful.

Maryland

Tetra Tech visited the Maryland Department of the Environment to gather information on

CWSRF projects. This effort was intended to test the data collection process, including the use of

the CWSRF indicator questionnaire. Tetra Tech collected data on two POTW projects and two

nonpoint source projects (Table 3-7). STORET data were used to evaluate ambient (receiving

water) pollutant parameter trends for the point source projects. For one nonpoint source project,

the Safe Drinking Water Information Database was used to represent a reduced potential health

risk, which would be applicable to Indicator 6.

The Maryland Department of the Environment also provided information on its CWSRF

Application process, which uses an environmental information document, preliminary environment

screening checklist, and financial loan application. The environmental information document

requests information on the water quality/public health problems being corrected and the potential

impacts of the project on water quality, water supply, biology, wetlands, and biosolids

management.

Table 3-7. Partial Summary of Maryland Analysis

April 1999 Indicator Used CWSRF Project Type Number of Projects

1, 2 Advanced treatment 2

5 Nonpoint source: agriculture 1

6 Secondary treatment; new collector sewers 1
 

 

Chapter 4. Evolution of Environmental Indicators
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

March 2001 4-1

Chapter 4. Evolution of Environmental Indicators

This chapter describes the final set or suite of environmental indicators as they have evolved based

on the states’ experience in testing them on a pilot basis.

Table 4-1. Evolution of CWSRF Indicators from Draft 1998 Report Through Pilot Testing Process

and Final Proposed Indicators

October 1998 Indicators April 1999 Pilot Indicators September 2000 Final

Indicators

Administrative indicators

• EPA/State Actions 

• Actions by Regulated

Community

February 2000 Indicator A. Actions

funded by CWSRF programs.

(Evaluated by Ohio only)

1. Actions funded by CWSRF

programs.

1. Pounds of pollutants removed

from the environment through

CWSRF-funded projects.

1. Number of pounds of pollutants

removed from the environment

through CWSRF-funded projects.

2. Number of pounds of pollutants

removed from the environment

through CWSRF-funded projects. 

2. Pounds of pollutants prevented

from entering the environment

through CWSRF-funded projects.

2. Number of pounds of pollutants

prevented from entering the

environment through CWSRFfunded projects.

3. Number of pounds of pollutants

prevented from entering the

environment through CWSRFfunded projects.

3. Reduction in biophysical

stressors by changing land use

practices, resource harvesting

practices, and resource extraction

practices through CWSRF-funded

projects.

3. Increase in biophysical benefits

or reduction in biophysical

stressors by changing land use

practices, and resource harvesting

and extraction practices through

CWSRF-funded projects.

4. Physical changes to the

terrestrial, riparian, or aquatic

habitat and hydrology resulting

from CWSRF-funded projects.

February 2000 Indicator B.

Changes in habitat of a waterbody

as a result of an CWSRF-funded

project. (Changes in ambient

habitat ) (Evaluated by Ohio only)

4. Waterbodies, expressed as river

and riparian miles, lake acres,

estuary square miles, and wetland

acres, previously impaired, now

meeting designated uses, as a

result of CWSRF-funded projects. 

4. Waterbodies, expressed as river

and riparian miles, lake acres,

estuary square miles, and wetland

acres, previously impaired, now

meeting designated uses, as a

result of CWSRF-funded projects.

5. Waterbodies, expressed as river

and riparian miles, lake acres,

estuary square miles, and wetland

acres, previously impaired, now

improved or meeting designated

uses, as a result of CWSRFfunded projects.

5. Waterbodies, expressed as river

and riparian miles, lake acres,

estuary square miles, and wetland

acres, protected, improved, or

restored as a result of CWSRFfunded projects.

5. Waterbodies, expressed as river

and riparian miles, lake acres,

estuary square miles, and wetland

acres, protected, improved, or

restored as a result of CWSRFfunded projects.

6. Waterbodies, expressed as river

and riparian miles, lake acres,

estuary square miles, and wetland

acres, protected as a result of

CWSRF-funded projects.

6. Benefits of reduced health risks

or increased recreational use

attributable to CWSRF-funded

projects.

7. Reduced health risks and/or

increased recreational use

attributable to CWSRF-funded

projects.
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

4-2 March 2001

Final Indicator Development

1. Actions funded by CWSRF programs.

Although the October 1998 version of indicators included administrative indicators, they were

dropped from the April 1999 pilot testing stage, which focused specifically on “environmental”

indicators. Indicator 1 was re-proposed after the other pilot indicators were tested. The Task

Force recommends using this indicator as an initial indicator of the contribution state CWSRF

programs make to achieving Clean Water Act objectives. This indicator would be useful in

situations where there is an absence of any other evidence regarding environmental improvements

brought about by CWSRF-financed projects.

The issue of measuring some CWSRF projects that did not fit under the April 1999 list of pilot

environmental indicators arose in February 2000. Some categories of CWSRF projects could be

measured only by Indicator A (final Indicator 1). This indicator is the most basic measure of

actions to improve the environment because it counts the number of funded projects. It is the

minimal reporting indicator, and it assumes project initiations result in environmental benefits. 

The number as well as the total dollar amount funded for projects by type may also provide useful

information for some CWSRF projects.

2. Number of pounds of pollutants removed from the environment through CWSRF-funded

projects.

This indicator is suitable for projects where influent and effluent data is available. It is also

suitable where loading levels in a receiving stream are quantified and are expected to change as a

result of the CWSRF-funded project. Indicator 2 may also be used for projects that convert

failing septic systems to centralized sewer systems.

3. Number of pounds of pollutants prevented from entering the environment through

CWSRF-funded projects.

This indicator is proposed as a prevention measure. It is suitable for projects that prevent

loadings either to or by a treatment facility, expand plants to handle increased flows, and prevent

NPS pollution. 

C This indicator is expected to be derived from load reductions reported by states, by using

the Permit Compliance System database or the actual monthly Discharge Monitoring 

Reports. Load reduction projections would most likely be estimated through established

engineering practices using modeling tools.
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

March 2001 4-3

4. Physical changes to the terrestrial, riparian, or aquatic habitat and hydrology as a result

of CWSRF-funded projects.

In October 1998 this indicator read, “Reduction in biophysical stressors by changing land use

practices, resource harvesting practices, and resource extraction practices through CWSRFfunded projects.” The Task Force revised the indicator in 1999 by adding the possibility of an

increase in biophysical benefits as another measure of the land use and resource extraction

practices. In February 2000 the Task Force agreed to add Indicator B— “Changes in habitat of a

waterbody as a result of an CWSRF-funded project. (Changes in ambient habitat)”— to

complement the language of the previous April 1999 indicator 3.

Indicator B was proposed in February 2000 after other pilot indicators had been reviewed. This

indicator would allow measurement of CWSRF project accomplishments in terms of habitat

improvement. It would be particularly useful for those projects (mainly nonpoint source) whose

main benefit is to provide habitat restoration. The Task Force acknowledged that various types of

physical habitat measures, such as the Qualitative Habitat Evaluation Index (QHEI) and Zig-Zag

Pebble Count, might be useful with this indicator.

The Task Force decided to combine Indicator B and the interim version of Indicator 4 to reach

the June 2000 version. The final version of Indicator 4 reflects a move to categorize biophysical

benefits or reduction in biophysical stressors as “physical changes” and move away from the

potentially misunderstood language of “land use practices.” Physical changes to terrestrial and instream habitat types now may be reported under Indicator 4.

This indicator is proposed for the category of CWSRF-funded projects that cannot be measured

by load reduction or projected load prevention. Habitat destruction and hydromodification are

major causes of aquatic life impairment, surpassing organic enrichment and dissolved oxygen

impacts in some states. This indicator measures changes in land use (such as a change in

agricultural tillage practices or restoration of riparian stream corridor) and other attributes of the

physical environment (such as biosolids entering the stream from a POTW) that could affect the

aquatic community.

• This indicator can help quantify the wide variety of nonpoint source, restoration, and

preservation activities funded by the CWSRFs. Coupled with Indicator 5, this indicator

can show the effectiveness of CWSRF-funded activities.

• Biological monitoring will show effects of increased sedimentation. Macroinvertebrate

populations decline when substrates become embedded. Absent biological data, it is

possible to track sediment embeddedness. Used alone or in combination with biological

data, embeddedness can indicate the success of various types of activities/best

management practices on aquatic habitat improvement.
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

4-4 March 2001

• After much discussion by the states, it was decided that this indicator is valuable because

of the correlation between habitat quality and attainment of Clean Water Act goals.

• States are encouraged to further investigate the techniques (field surveys, Zig-Zag Pebble

Count Method), tools (QHEI, geographic information systems), and units (acres, river

miles, degree of embeddedness) used to measure progress under this indicator (See

Appendix G and H). 

5. Waterbodies, expressed as river and riparian miles, lake acres, estuary square miles, and

wetland acres, previously impaired, now improved or meeting designated uses, as a result of

CWSRF-funded projects.

This indicator focuses on waterbodies that were determined to be degraded to some extent by a

cause or source attributable to a problem that was remedied by a CWSRF project(s). The criteria

that were used to determine the degradation may be the same as those used to establish a state’s

303(d) list. These data could include chemical, physical, and/or biological criteria, but this will

vary from state to state. Information should be available in each state’s 305(b) water quality

report as to the condition of waterbodies with respect to their designated aquatic life habitat uses. 

The problems addressed by the CWSRF project should be clearly described in the environmental

assessment for that project.

By comparing the miles impaired and degree of impairment before and after the completion of a

CWSRF project, changes in the degree of use attainment can be correlated with CWSRF-funded

projects within the range of river miles that the project influences. In some cases, the major

source of impairment will not be related to the CWSRF project, and so a minor improvement in

stream condition will be seen. In other cases, the problem that was addressed by the CWSRF

project may have been the only source of impairment, and so the subsequent restoration of that

waterbody segment will be entirely attributable to the CWSRF-funded activities. In still other

situations, a number of causes may have contributed to impaired water quality, all of which were

addressed, but only some of which were CWSRF-funded, and so only a portion of the improved

water quality will be attributable to CWSRF financing.

C EPA and the states have developed an up-to-date, comprehensive list of impaired waters

(303(d)). Ideally, this proposed Indicator 5 could measure progress against this nationally

established “baseline” of impaired waters. At the state and project levels, the indicator can

be developed using state or locally generated information on water quality conditions

without necessarily aggregating it with other states’ results. Often, water data exist at the

state or local level which might be more useful in demonstrating results.
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

March 2001 4-5

• It was decided that showing improvements in the environment is important even if

designated uses were not met. The indicator now includes measuring improved

waterbodies that may have partially attained designated uses.

6. Waterbodies, expressed as river and riparian miles, lake acres, estuary square miles, and

wetland acres, protected as a result of CWSRF-funded projects.

This indicator originally read, “Waterbodies, expressed as river and riparian miles, lake acres,

estuary square miles, and wetland acres, protected, improved, or restored as a result of CWSRFfunded projects.” It was determined that with the original wording there was too much overlap

between Indicators 5 and 6. Rather than combining the two indicators into one, the group

decided to keep improvement of impaired waters in Indicator 5 and put protection activities in a

different category, Indicator 6. With the current emphasis through the TMDL process on

impaired waters, the group wanted to identify the importance of keeping fully attaining surface

waters from becoming impaired. The CWSRF program should address problems that will cause

impairments to water quality before the problems become apparent and before enforcement action

is required. This indicator serves to focus attention on areas of attainment and the importance of

using CWSRF resources to ensure maintenance of attainment. 

• The Task Force felt that Indicators 5 and 6 would (1) measure key environmental

objectives of all water protection programs, (2) help establish stronger linkages with other

federal water programs with similar indicators and objectives, and (3) encourage the

development of data sets that document before-and-after conditions. 

C Data from EPA’s 305(b) reports, STORET, and other data systems can be used to

support this indicator. Project-specific information, where available, could also support

the use of this indicator.

C Indicator 6 provides a means to capture some of the less traditional CWSRF activities that

contribute to the protection and preservation of unimpacted resources, such as land

acquisition, easement purchase, and riparian stream corridor restoration.

The final indicator 6 removed the words “improved” and “restored.” Indicator 5 will address

improvements in waterbodies, as well as cases where waters meet designated uses. Indicator 6

has a clear focus on protection of unimpaired resources.

7. Reduced health risks and/or increased recreational use attributable to CWSRF-funded

projects.

The indicator is important because it monitors a Clean Water Act objective. Although it may be

difficult to establish distinctions as to the degree of human health risk posed by different sources
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

4-6 March 2001

of pollution, the presence of bacteria (e.g., E. coli, fecal coliform) associated with fecal matter at

levels above established threshold concentrations indicates the presence of health risks. If a

CWSRF project addressed a source of this problem, then reduction of bacteria concentration

subsequent to project completion indicates that the CWSRF project contributed to reducing risks

to human health.

Sampling upstream and downstream of a POTW outfall can provide information regarding the

plant operations with respect to bacterial contributions. If the project addressed failing septic

systems or sewer bypasses, health department records of bacterial concentration violations in

pools, ditches, basements, and water wells should be used if available to document the problems

addressed. Such locations are not considered official waterbodies, but would nonetheless pose a

threat to human health. Frequently, these data are not in any known database or report, but are

often gathered on an individual project basis from local health departments. Some ambient stream

data may be available at the state level to determine recreational use attainment.

Problems in using this indicator occur when sampling is lacking or inadequate to allow drawing

conclusions. Ideally, bacteriological samples should be taken during low seasonal flows and at

strategic locations, and the sampling should be done before and after project completion. 
 

 

Chapter 5. Observations and Recommendations
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

March 2001 5-1

Chapter 5. Observations and Recommendations

This project was conducted at the state level for the purpose of developing and testing a range of

environmental indicators that could assist states in both setting priorities for project selection and

demonstrating CWSRF program and project success. Accordingly, the six environmental

indicators identified in Chapter 2 were tested and evaluated for use by several states through the

formation of a Task Force, which met monthly during this phase of the project. Based on the

review, revision, and pilot testing of the environmental indicators, the Task Force submits the

following observations and recommendations grouped broadly under the categories of “data” and

“programmatic issues.”

Observations Related to Data

• Access to environmental monitoring data and other sources of information that could help

support the use of environmental indicators is difficult and at best time-consuming when

data are available. Many of the states discovered through this pilot project that identifying

and accessing environmental data related to CWSRF-funded projects ranges from

problematic to extremely difficult. Discharge Monitoring Reports submitted monthly by

National Pollutant Discharge Elimination System permit holders. They cover treatment

facilities and would account for a majority of CWSRF project funds. Sources of

monitoring data are usually collected and maintained by agencies, offices, or programs

other than the state CWSRF lead agency, resulting in problems and time delays in

accessing data for indicator analysis.

• Applying environmental indicators to CWSRF-funded projects other than wastewater

treatment upgrades or expansions is difficult at the present time. This is due, in part, to

the fact that many states have not funded a large number of nonpoint source (NPS)

projects, as well as the fact that there are fewer data available for NPS pollution than for

point sources. Lack of data to evaluate the effects of some CWSRF NPS projects may be

a temporary problem, because as more projects are funded, one would expect the effects

to eventually show up in water quality monitoring information. Further, because it takes

several years after project implementation before the benefits of NPS projects are realized,

there will be an additional time lag in having the benefits reflected through physical,

chemical, and biological monitoring.

• Substantial modeling would be necessary to apply final Indicator 3 (Pounds of pollutants

prevented from entering the environment from CWSRF-funded projects). This approach

would be costly, controversial, and time-consuming to develop. In the alternative,

nationally accepted estimation approaches might be able to establish load reductions by

estimating reductions in loads. Estimations may be possible. The objective should be to

get general indicators of CWSRF contributions to water quality improvement.
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

5-2 March 2001

• Chapter 3 contains documentation on the experience from each of the state pilot projects. 

Each state presented its findings and individual recommendations. Variability between

states was observed, with the major problem being the availability of data to support each

environmental indicator.

Observations Related to Programmatic Issues

• The CWSRF Program information tracking system traditionally has used fiscal measures

(e.g., number of loans initiated per year) to evaluate program performance. The current

CWSRF information tracking system contains a significant source of information

regarding the amount of capitalization funds provided to states and, together with states’

matching funds, the funds available for projects. Environmental data at the project level

are not reported or tracked by most of the states, and none of the information is compiled

and submitted to EPA.

• Within a state, decisions on funding of projects through the CWSRF are often driven by

factors other than environmental protection or improvement. The projects on a state’s

priority list are included on the list because of the state’s objective to improve or expand

wastewater treatment or otherwise achieve water quality benefits. Projects often receive

loans regardless of their location on a state’s priority funding list, however, because of

their “readiness to proceed.” Although EPA has encouraged states to keep the funds

moving and to initiate as many projects as possible, use of CWSRF indicators provides an

opportunity to integrate environmental outcomes into the state priority ranking process.

• Measurement or collection of data to document environmental improvements directly

related to CWSRF projects does not follow a standard operating procedure. States do not

have procedures in place to collect information on environmental outcomes related to

CWSRF projects, or whether they were the result of the combined efforts of many

programs. In defense of the states, they have not been requested or required to collect

such data in the past.

• Although some states can correlate trends with CWSRF projects, currently available

environmental monitoring data collected by many states do not necessarily help to assess

CWSRF outcomes because the monitoring was not designed for such purposes. 

However, it may be possible to correlate water quality changes with CWSRF projects

when states have monitoring data (biological, chemical, bacteriological, and/or physical). 

Even though the monitoring was not designed to evaluate the success of the CWSRF

program, much of the 303(d) and 305(b) data can be used directly or indirectly for that

purpose.

• This project has demonstrated that there is a wide variety of approaches at the state level

that could be used to report on environmental improvements associated with CWSRF-
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March 2001 5-3

funded projects. Most of the pilot states agreed that loading reductions from CWSRFfunded treatment projects could be either directly measured or estimated. The states also

agreed that connecting these load reductions to actual stream improvements in the absence

of the other indicators does not necessarily provide evidence of improvement in the

attainment of designated uses by waterbodies. The Task Force has discussed using the

environmental indicators together as a “suite” of indicators to get a complete picture,

when possible, of how the water quality and the aquatic organisms have responded to the

changes brought about the CWSRF projects. Indicators 1-3 used in combination with

indicators 4-7 give the most complete picture of environmental outcomes. For example,

Indicator 1 in conjunction with Indicator 6 might show the relationship between load

reduction and improvement in biological quality.

• There are many factors relating to stream water quality, and habitat conditions that might

or might not be affected by improvements in a wastewater discharge. Load reductions

from one POTW could have a major beneficial effect on a stream or could be lost

completely given the many other sources of pollution or stream degradation. The states

emphasized that the indicators should be used together. It is important to keep in mind

the nature of the information that each indicator provides, and not to extrapolate beyond

the limits of each indicator. It is important to realize the limitations of individual

indicators in order to avoid making invalid assumptions regarding water quality and

aquatic community condition.

• Because most of the current CWSRF funding is directed to POTW upgrades, expansions,

or improvements to maintain operational reliability, pilot states reported difficulty in

attributing incremental pounds of pollutant removed due to CWSRF funding. Clear,

specific, and uniformly applied guidance would need to be developed if all states were to

calculate load reduction benefits. An alternative to measuring load reduction might be to

measure reduction in concentration of pollutants. Also, the addition of the administrative

indicator measuring project types funded helps to address the issue of measuring financing

of improvements to existing, complying facilities. In addition, gains in treatment might be

offset by additional influent flows when a plant is upgraded because of increased overall

loadings if the plant also is expanded. Some states reported that despite POTW projects

providing treatment upgrades, such projects often concurrently involve expansion to

provide capacity to serve 20-year needs, rendering post-project loads larger than preproject loads. Discharge monitoring report data could be used to calculate these load

variations.

• Most states predict that establishing confirmed links between CWSRF funding and specific

reduced health risks (Indicator 7) will be very challenging. In addition to POTW

discharges, there are many potential point and nonpoint sources of disease and health risks

in watersheds and coastal estuaries that are attributable to sources such as storm water,
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators

5-4 March 2001

combined sewer overflows, contaminated sediment removal, wildlife, and livestock. 

However, establishing links between CWSRF funding and specific reduced health risks

(Indicator 7) is possible if bacteriological data are available from project areas during

periods before and after project completion. Although it may be very difficult to establish

distinctions as to the degree of human health risk posed by different sources of pollution,

the presence of pathogenic indicator bacteria (e.g., E. coli, fecal coliform, etc.) with or

without a water-borne disease outbreak in an area, is something than can be monitored. If

a CWSRF project addressed a source of this problem, then the lack of high levels of

potentially pathogenic bacteria subsequent to the project completion would indicate that

the CWSRF project had contributed toward reducing human health risk.

Recommendations Related to Data

• Many states have suffered budget cutbacks in the area of environmental monitoring,

including ambient monitoring. This lack of environmental baseline data undermines a

state’s ability to directly measure environmental improvements that may be evident as a

result of implementing environmental programs and improvements such as the CWSRF. 

Without ambient monitoring data, states that conduct only limited water quality

monitoring would be hard-pressed to demonstrate actual environmental improvements as a

result of environmental infrastructure improvements through CWSRF funding. 

• More data are needed to support environmental indicators for NPS projects. A broader

scope of data types beyond traditional water quality parameters should be included for

NPS projects, such as biological and habitat indices (e.g., the zigzag count). Documenting

environmental changes attributable to a NPS project funded by the CWSRF Program may

require a longer period of time in order for the funded best management practices to be

reflected in improvements to water quality and aquatic biota. Indicators such as final

Indicator 4 may need more development and refinement in order to accurately capture the

benefits resulting from NPS activities.

• Several states suggested that they will collect data during the determination of TMDLs

and develop loading assumptions that could help support final Indicator 5 (waterbodies

previously impaired and now meeting designated uses as a result of CWSRF projects).
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March 2001 5-5

Recommendations Related to Programmatic Issues

• Measuring environmental outcomes requires data. All states must report on the status of

their water to EPA through their water quality inventories, but the criteria for assessing

these waters vary greatly because of differing monitoring strategies, assessment

techniques, and program budgets. Consequently, the data available to use for the CWSRF

environmental indicators are inconsistent between the states. In many cases this may not

be due to a lack of water quality data, but rather to a lack of a system for assembling and

reporting the data. While some states may have biological data that directly measure the

response of the aquatic community to environmental changes, other states simply have

chemical data from the end of a pipe. States should be supported in their efforts to

monitor the environment in a manner that accurately portrays the condition of their

aquatic resources and the changes to these resources attributable to activities such as the

CWSRF Program. Until this is done, only a few states will have the data to accurately use

the indicators developed by this Task Force.

• Implementation of environmental indicators by the states should be discretionary and

should be viewed as an evolutionary process.

• The environmental indicators should be considered as a “suite” of indicators to be used at

each state’s discretion and according to each state’s individual needs.

• The environmental indicators would need to be accompanied by appropriate guidance

materials and concrete examples of successful application by the states prior to

implementation.