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The Uneven Geography of Managing Urban Storm Water: A Comparison of Two State Programs Greg H. Lindsey |
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The Clean Water Act: A Frame Work for Implementation INDIANA AND MARYLAND: THE GEOGRAPHY OF IMPLEMENTATION CONSIDERATIONS IN EFFECTIVE EROSION AND SEDIMENT CONTROL |
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The basic approach to water pollution control in the United States, as Bauer explains in Chapter 12, is one of command-and-control regulation, in which ambient water quality standards are to be achieved through a federal permit system that establishes effluent limitations for sources of water pollution. Although the Clean Water Act (CWA) assigns primary responsibility for national water pollution control policy to the federal government, the CWA envisions a large role for state governments in the administration and management of regulatory programs. The severity of water quality problems, of course, varies widely across the 50 states, and the states vary considerably in their commitment and capacity to manage environmental problems. To gain a better understanding of the role of state governments in the administration of water pollution control programs, it is helpful to examine how two states have responded to recent initiatives in the CWA. |
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This chapter is a study of programs to control pollution in urban storm water in Indiana and Maryland. It illustrates fundamental issues associated with uneven implementation that arise in federal systems when federal governments rely on state and lower levels of government to establish and implement complex policies. First, recent federal initiatives to regulate pollution in urban storm water and the contexts for implementation in Maryland and Indiana are described. Next, substantive requirements for erosion and sediment control are explained, and the administration of the state programs is examined. Finally, the chapter offers a discussion of issues in implementation and their implications for policymakers and administrators. |
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The basic structure of the Clean Water Act has been described, but several key features warrant elaboration. The modern era of water pollution control began in 1972, when Congress asserted a national interest in clean water and established the National Pollutant Discharge Elimination System (NPDES), a permit program designed to achieve national goals of "fishable, swimmable" waters by linking ambient water quality standards with effluent limitations for discharges of industrial and municipal wastewater. All three levels of government play important roles in water pollution control and administration of the NPDES program. The U.S. Environmental Protection Agency (EPA) sets standards, issues permits, conducts research, oversees planning, and helps fund implementation of programs by state and local governments. States may assume authority for administration of the NPDES program (38 states have done so), set standards that are more stringent than those established by the federal government, or enact separate statutes under their own authorities. Local governments (i.e., counties and municipalities) operate wastewater treatment plants and work with industries in pretreatment programs designed to minimize the effects of industrial wastes on municipal treatment works and on receiving waters. Regulation remains the principal approach to intervention, although some experiments with marketization and trading of effluent rights have been undertaken. Compliance is achieved through systems of monitoring, reporting, inspections, and the use of civil and criminal penalties for violations of permit conditions. Depending on the state and local jurisdiction, enforcement may be brought under the authority of the CWA, state law, local ordinances, or some combination of the three. |
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Before Congress passed the Water Quality Act (WQA) in 1987, the focus of regulatory components of the CWA was on point sources (i.e., end-of-pipe discharges of process wastes from industries and effluents from municipal treatment plants). Nonpoint sources (i.e., pollution from diffuse sources such as agriculture and urban storm water runoff) typically were not regulated, although the EPA had been involved in litigation over whether storm water discharges should be included in the NPDES program. Experts had long recognized that nonpoint source (NPS) pollution, particularly agriculture, was the largest source of pollutants in the nation's waters; and many experts considered the biggest weakness of the CWA to be its failure to address diffuse sources of pollution in a meaningful way. Experts had cautioned, however, that failure to target new programs at the most significant sources could result in inefficient expenditures (Freeman 1990). In the 1987 WQA, Congress made two significant changes aimed at addressing NPS pollution and storm water. |
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First, Congress created a new Section 319 that required each state to assess its surface waters and to develop NPS management programs (U.S. EPA 1989). Although states were required to submit NPS assessment reports and management plans to the EPA for approval, implementation of specific programs outlined in management plans is voluntary. To assist with implementation, Congress annually has appropriated about $40 to $50 million to be awarded to states. The EPA has identified several important actions state and local governments can take to control NPS pollution. These include building institutions, installing best management practices (BMPs), using land conservation techniques, and enacting laws and ordinances. States have used grants for activities such as additional administrative staff to implement state efforts and for awards to other state, regional, and local governments and organizations to implement a range of capital, monitoring, and research projects. In most states, NPS programs have focused on agriculture, although urban land uses, mining, and other activities not regulated under the NPDES program also have been addressed. |
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Second, Congress added Section 402(p) to require NPDES permits for municipal and industrial storm water discharges (55 FR 47990). This amendment attempted to establish procedures by which municipalities could identify and eliminate illicit connections to storm sewers, clarify disputes over whether storm water discharges were point sources, and target the most important sources of pollution in urban storm water. The law affected approximately 173 municipalities and 47 urban counties with populations greater than 100,000 on separate storm sewer systems. The law also placed new requirements on perhaps as many as 250,000 firms and units of government in 11 categories of industry (i.e., Standard Industrial Classifications), including all construction sites greater than five acres. Among permit conditions, each regulated industry or firm was required to prepare a storm water pollution prevention plan or, in the case of construction sites, an erosion and sediment control plan. Because many of the industries covered under the amendment never before had been regulated under the CWA, this single amendment increased by more than five times the number of industries within the NPDES program. Congress neither authorized nor appropriated additional funds to assist with implementation, and states and municipalities were expressly prohibited from using NPS funds (i.e., Section 319 funds) for activities to comply with storm water permit requirements. |
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Because of the scope of the new requirements, the EPA introduced several innovations to streamline the storm water permitting system. With respect to municipal separate storm sewer (MS4) permits, the EPA recognized that it would be impractical and unwarranted to establish effluent limitations on concentrations of different pollutants for each of the hundreds of storm sewer outfalls in each municipality and thus moved to establish "programmatic" permits—NPDES permits that, instead of requiring effluent limitations for individual outfalls, required municipalities to commit to schedules for assessment of problems related to storm sewers, maintenance activities such as street sweeping, and regulatory activities such as control of erosion and sedimentation from construction sites. To manage the vast numbers of industries that would be regulated, the EPA established three types of permits: (1) group permits for small numbers of similar industries, (2) a general permit (i.e., permit by rule), through which individual industries would obtain coverage through submittal of a Notice of Intent (NOI) in which they certified their intention to comply, and (3) conventional individual permits. Most industries have obtained permit coverage through general permits. |
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To sum up these changes, Congress determined that: |
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In a significant departure from previous practices of specifying effluent limitations in NPDES permits, permits required preparation of plans and certification of intent to implement them. |
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The scope of these new programs was in certain respects unprecedented, establishing a federal presence in spheres of activity such as construction that previously had been the exclusive province of states or local governments. The new programs were, not surprisingly, controversial. State and municipal officials complained of unfunded mandates, and industrial representatives complained of needless and redundant regulation. State administrators were uncertain of the relationship between Section 319 and Section 402 and unsure of the priority that should be given to storm water permitting activities relative to existing activities. Most important, state officials varied tremendously in their capacity and willingness to respond to the new requirements. Study of efforts to implement the regulations therefore provides insight into issues that arise in implementation of national policy in federal systems. |
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This study focuses on the narrow case of erosion and sediment control for construction sites, although analyses could be undertaken for any of the new NPS programs under Section 319, the MS4 permit system, or any or all of the newly regulated categories of industry. Detailed review of a single category of regulated industry is useful because it illustrates the scope and complexity of the new federal requirements, the differences in the capacity of states to respond, and problems faced by administrators. Indiana and Maryland are used as examples because they historically have taken very different approaches to erosion and sediment control; the contrast between states is illustrative of the differences that can emerge when the federal government relies on states for implementation. |
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It is helpful to describe geographic factors in each state that establish the context for implementation of the storm water regulations. Table 13-1 displays facts about each state that bear on the state's response to the regulations. Table 13-1 also includes some findings by researchers who have attempted to rank state commitment to environmental protection. |
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Indiana is a midwestern, industrial, and agricultural state that is nearly three times the size of Maryland, a southern Atlantic state that is both more urbanized and more forested. Both states are water rich. Indiana withdraws more water for industrial, agricultural, and consumptive uses and relies more on surface water supplies, but it generally has poorer surface water quality. Nearly one-third of its streams either only partially support or do not support designated uses (i.e., human uses such as full-body-contact recreation). Agriculture NPS pollution is the largest single source of water pollution in Indiana. Maryland has more miles of streams, more than 90 percent of which are of sufficient quality to fully support all designated uses. Both agricultural and urban NPS pollution are sources of pollution in Maryland. Three northwestern counties in Indiana border on Lake Michigan, the third largest of the Great Lakes, but lake-related issues do not dominate environmental policy debates, partly because most of the state is not contiguous to Lake Michigan. Maryland's boundaries include most of the Chesapeake Bay, one of the world's most productive estuaries, and most of Maryland is within the Chesapeake Bay watershed. As a result, bay-related issues, including control of the effects of urbanization on water quality, are among the state's most important environmental policy debates. |
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Indiana has a slightly larger population than Maryland, but its population is more rural and poorer. As measured by gross domestic product, the economies of the two states are of comparable size, although manufacturing and agriculture are more important in Indiana and the services sector is more important in Maryland. State revenues also are comparable, but Maryland spends more on the environment, both per capita and as a percentage of total expenditures. In terms of financial commitment to environmental protection, Maryland ranks in the middle of the 50 states, while Indiana ranks near the bottom. Maryland relies more than Indiana on federal aid to fund environmental expenditures. |
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In part because of the rural nature of the state, Indiana has seven times the number of units of local government found in Maryland, including more than four times the number of counties and more than three times the number of municipalities. Maryland is unusual among states in that counties have more powers than municipalities and frequently provide services within municipal boundaries. Indiana has fewer special natural resource districts. |
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Several analysts have compared state environmental programs and attempted to determine how variables such as these correlate with state commitment to environmental protection. Maryland's programs in urban storm water management have been characterized as "pioneering" (Kaiser and Burby 1987). Davis and Lester (1989) used indicators of state commitment to environmental protection and the proportion of state expenditures on the environment funded by federal aid to classify state-federal relations in environmental protection as interdependent (14 states), dependent (19), independent (11), or passive (6). They characterized programs in Maryland as moderately strong relative to need and ranked federal-state environmental relations as interdependent. Indiana, which had weaker programs but relied less on the federal government for its environmental expenditures, was classified as independent. Ringquist (1993) found that Maryland's water program was stronger than Indiana's and that, across all states, the strength of state water programs correlated with more professional legislatures, more liberal public opinion, stronger environmental groups, and a strong agricultural sector. |
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To sum up, Indiana is larger, more rural and agricultural, and poorer than Maryland. Indiana generally is perceived to have less commitment to environmental protection and less capacity to manage complex environmental problems. Even though Indiana relies more on surface water for human uses, it has poorer surface water quality. Because of widespread concern about the Chesapeake Bay, Maryland officials are very committed to control of NPS pollution, including urban runoff. These geographic factors bear on each state's response to the federal storm water regulations. A discussion of substantive requirements for effective erosion and sediment control is necessary, however, before a comparison of their programs is made. |
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Sediment eroded from construction sites is an important pollutant in areas undergoing intensive urbanization and has a number of adverse effects on water quality. Sediment increases turbidity, smothers benthic communities and spawning beds, clogs fish gills, reduces prey capture, and fills impoundments. Best management practices (BMPs) for controlling erosion and sedimentation are well understood and involve, first, minimizing erosion during construction and, second, managing sedimentation through control of sediment-laden runoff. Methods of minimizing erosion include stabilization of denuded graded areas with erosion control blankets or vegetation and careful timing or sequencing of construction activities to minimize periods of time that graded areas are exposed to erosive forces of wind and rain. Practices for reducing sedimentation include site perimeter controls such as a silt fence to filter runoff, sediment basins to detain runoff and allow time for sediment to settle, and stone construction site entrances to minimize tracking of mud onto streets. |
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Effective erosion and sediment control requires careful management of the process of development, an activity historically regulated mainly by local governments. Experts have identified five components of effective erosion control programs. These include (Clevenger n.d.; Departments of Civil Engineering and City and Regional Planning 1990): |
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1. The regulated community must understand the regulatory requirements and attempt to comply (i.e., regulatory "coverage" must approach 100 percent). |
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2. Appropriate BMPs must be specified on erosionC and sedimentC control plans. |
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3. BMPs specified on plans must be installed and implemented correctly. |
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4. BMPs must be maintained for the duration of the construction process. |
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5. Enforcement tools (e.g., notices of violation, stop-work orders, and civil and criminal penalties) must be used as necessary to maintain BMPs. |
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Poor performance at any step in the process, from preparation of plans to maintenance of BMPs during construction, may result in degradation of water quality. Regulation, considered integral to implementation by experts, includes plan review by independent experts to ensure that the BMPs are appropriate and periodic inspections by responsible engineers or independent inspectors to ensure that BMPs are maintained. Effective regulation requires commitment, judgment, and intensive, frequent interaction with site operators. Given the tremendous scope of the federal storm water regulation, effective regulation of construction activity implies a commitment of significant financial resources. |
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The federal storm water regulation has been imposed over a complex system of existing regulation at the state and local levels. While institutional structures for the administration of environmental policy and regulation in Indiana and Maryland generally are comparable, some differences exist. The departments with principal responsibility for the administration of environmental and pollution control programs are the Indiana Department of Environmental Management (IDEM) and the Maryland Department of the Environment (MDE), cabinet-level agencies that were created in 1986 and 1987, respectively, from existing state programs in departments of public health and natural resources. While MDE functions like a "mini-EPA" and can both promulgate and enforce regulations, regulations in Indiana are promulgated by one of three boards (e.g., Water Pollution Control Board), the members of which are political appointees. IDEM therefore has somewhat less authority than MDE. The regulatory boards in Indiana may have greater political accountability. |
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Departments of natural resources (IDNR and MDNR, respectively) in each state have responsibility for resource management, including forestry, fisheries, wildlife, water resources, and soil conservation. Among agencies in Indiana, IDNR has the greatest expertise in soil conservation and coordinates with IDEM on many issues related to erosion and sediment control. MDNR, which housed all urban erosion control programs in Maryland prior to creation of MDE, now has few responsibilities for control of urban erosion and sediment control. Both IDNR and MDNR provide technical assistance and training for technicians in soil and water conservation districts (SWCDs). SWCDs are local units of government, generally coterminous with county boundaries, that work with farmers and other local land-owners to maintain farm productivity, conserve soil, and minimize pollution of water resources. SWCDs historically have provided free technical assistance to landowners who voluntarily seek it. Most SWCDs have not performed regulatory functions. |
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Prior to the WQA and promulgation of the federal storm water regulation, Indiana and Maryland pursued very different policies in erosion and sediment control. The key elements of effective erosion controlC scope, plan review, installation, maintenance, and enforcementC provide a useful framework for comparing state programs (Table 13-2). |
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Indiana began regulation only in response to the 1990 federal mandate. IDEM previously had no regulatory responsibilities for storm water or erosion and sediment control, and IDNR responsibilities were limited to technical assistance, primarily training of local technicians in SWCDs in urbanized counties near Indianapolis and in the heavily industrialized, steel-producing, northwest region of the state. Few Indiana municipalities had adopted erosion control ordinances. Hence, the federal storm water rule as codified in state regulation became the primary source of regulation of erosion control at construction sites in Indiana. In contrast, the Maryland legislature first mandated erosion and sediment control on construction sites in 1970, and erosion control is required on virtually all construction sites, including individual sites for single-family residences. Under Maryland law, erosionC and sedimentC control regulations apply to sites 43 times smaller than sites regulated under the federal rule. The number of sites regulated in Maryland is therefore many times greater than the number in Indiana. |
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Regulators in both states have recognized the expertise of technical staff in local SWCDs and have required participation by SWCDs in the regulatory process. Participation is required by statute in Maryland but only by regulation in Indiana, and SWCDs have greater authority in Maryland. In Maryland, developers cannot obtain county or municipal grading permits or disturb soil until SWCD staff have certified approval of their plans. In Indiana, state regulations require only submittal of plans to SWCDs for review; and, while SWCD staff are required to make recommendations, regulations do not explicitly require operators to incorporate them into plans. Under state rules, developers also are not prevented from disturbing soil prior to plan review. Both MDE and IDEM have signed memoranda of understanding that outline responsibilities for implementation of their respective resource agencies and statewide associations of SWCDs. Primarily because of differences in the stringency of regulation, SWCD staff in Maryland bear much heavier workloads. Maryland officials report tracking more than 18,000 major and minor projects that required custom or standard erosion and sediment control plans in 1993, more than 14 times the number of projects reviewed by IDNR and SWCD technicians in Indiana in 1994. |
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Both states have incorporated into regulation design guidelines and standards and specifications for BMPs. Installation of BMPs, however, is more thorough in Maryland: It is a violation of rules in Maryland to begin site modification without 48 hours prior notice to state or local inspectors. Inspectors require installation of perimeter controls and other BMPs prior to construction and emphasize use of BMPs that minimize erosion. In Indiana, municipal officials report that BMPs to control sedimentation after soil has eroded are used much more often than BMPs to minimize erosion. Both states require BMPs to be maintained for the duration of construction. Because of the many different problems that occur in the field (e.g., trucks run over silt fence; sediment basins fill after storms), frequent inspection and enforcement is required to ensure proper maintenance. |
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Perhaps the single largest difference in programs in Indiana and Maryland has to do with commitment to enforcement. Since adoption of state regulations, IDEM has added administrative staff to assist with NPDES, but not field personnel, and the state relies primarily on five urban conservation specialists with IDNR and local SWCD staff to inspect sites. IDNR officials reported 1,426 inspections by state and local technicians in 1994. Officials in municipalities in Indiana with erosion control ordinances report that sites are inspected mainly in response to complaints; no municipalities reported employment of inspectors whose sole responsibilities were erosion and sediment control. In Maryland, as part of a set of Chesapeake Bay initiatives in 1984, state legislators overhauled the sediment control statute and made enforcement of requirements for erosion control a state responsibility that could be delegated to local jurisdictions, much as the EPA delegates authority for administration of NPDES programs to states. Since then, commitment to enforcement has increased steadily. In 1993, state officials reported that state, county, and municipal agencies employed 121 full-time erosion and sediment control inspectors, who completed more than 138,000 inspections, almost 15 times the number of inspections in Indiana one year later. These inspectors issued more than 18,000 notices of violation and imposed more than half a million dollars in civil and criminal penalties. |
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The Maryland program dwarfs its Indiana counterpart both in scope and in commitment to enforcement of requirements. Regulators in Maryland have 20 years of experience in erosion and sediment control and have been able to respond to the federal rule with relative ease. The federal initiative merely buttressed long-standing state and local regulatory programs that were far more comprehensive, both in stringency of regulation and commitment to enforcement. On the other hand, regulators in Indiana have little experience in erosion and sediment control and, to respond to federal rules, have had to break new ground. They had to establish within months a new set of standards for most operators of construction sites. While Indiana officials believe that appropriate BMPs are being specified on site development plans, they realize that effective implementation lags, primarily because of the lack of enforcement. If the effort devoted to implementation in Maryland is taken as an approximation of the effort required for effective implementation in other states, then extraordinary measures will be required in Indiana. The effort devoted to erosion and sediment control in Maryland also is useful for placing in perspective the scope of federal initiatives under the WQA. Construction is just one of 11 categories of industry to be regulated under the storm water regulations, and regulatory agencies also are responsible for new programs to regulate entire storm water systems in the nation's largest municipalities. Many states, like Indiana, simply are not in a position to respond. |
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This sketch of state efforts to control erosion and sedimentation from construction sites has a number of implications for federal and state administrators responsible for implementation of environmental policy. New federal regulations always are imposed over existing systems of regulation. The need for federal regulation varies among states and local jurisdictions, and federal regulations have different effects in different places. For any system of regulation to have the desired effects, a complex set of actions and reactions must occur. Administrators must establish clear policy that, from a technical perspective, is capable of producing desired results. Regulated entities must know about and understand the regulations and attempt to comply. Technical components of their plans must be feasible and sufficient and, following installation or implementation, must be maintained for the duration of the regulated activity in dynamic physical and economic environments. Finally, if efforts by regulated entities are deemed inadequate, administrators must choose from an array of instruments to induce or force compliance. Political support is essential for effective implementation. |
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To achieve environmental objectives, new programs to control smaller and more diffuse sources of pollution will be necessary. This is true regardless of the medium of interest. Examples include efforts to control emissions from motor vehicles, programs to encourage individual firms and households to reduce waste and recycle residuals, and, in the case of water pollution control programs, to manage land use on individual parcels of land to reduce discharge of pollutants in storm water. The complexity, difficulty, and cost of regulatory initiatives grow geometrically with the number of sources to be controlled. |
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Concerns about the reach of the federal government and the scope of federal regulation, however, were factors in the watershed elections of 1994 that brought into Congress a more conservative group of legislators. Conservative leaders have vowed to reduce and devolve regulation in all substantive areas of government, including the environment. The CWA is among the laws targeted for overhaul. In the debate over the CWA, one issue that has emerged is the fate of the storm water regulations, and one possible outcome is the elimination of permit requirements for storm water discharges. Regulation of storm water discharges may prove to be a short-lived experiment, testimony to problems that emerge when Congress directs regulators to develop singular solutions for complex, diverse problems across 50 different states. From an environmental perspective, it is increasingly clear that the benefits of regulatory initiatives must be evaluated and that regulatory programs must be targeted. From the perspective of federal administrators concerned about implementation, the prospect of devolution makes it likely that significant disparities in efforts to redress particular problems will persist. Administrators at all levels of government will be challenged to develop effective programs that meet environmental, economic, and political objectives. Among the challenges they will face is the task of balancing needs to target regulatory efforts with concerns about evenness in implementation. |
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Clevenger, B. variously dated: 1993-1994. Miscellaneous unpublished materials. Baltimore: Maryland Department of the Environment, Sediment and Stormwater Administration. |
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Davis, Charles E., and James P. Lester. 1989. "In Federalism and Environmental Policy." Environmental Politics and Policy: Theories and Evidence, ed. James P. Lester. Durham, N.C.: Duke University Press. |
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Department of Civil Engineering and Department of City and Regional Planning. 1990. Evaluation of the North Carolina Erosion and Sedimentation Control Program. Raleigh, N.C.: North Carolina State University. |
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Division of Soil Conservation. 1995. "Urban Role Continues to Expand for Conservation Partnership." Topsoil, no. 384. Indianapolis, Ind.: Indiana Department of Natural Resources. |
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Freeman, A. M. 1990. "Water Pollution Policy." In Public Policies for Environmental Protection. ed. P. R. Portney. Washington, D.C.: Resources for the Future. |
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Kaiser, Edward J., and Raymond J. Burby. 1987. "Emerging State Roles in Urban Stormwater Management." In Water Resources Bulletin 23, no. 3 (June): 443-453. |
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Lester, James P. 1994. "A New Federalism? Environmental Policy in the States." In Environmental Policy in the 1990s. 2d ed. Washington, D.C.: Congressional Quarterly Press. |
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"National Pollutant Discharge Elimination System Permit Application Regulations for Storm Water Discharges: Final Rule." 1990. Federal Register 55, no. 222 (November 16): 47990-48091. |
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Ringquist, Evan J. 1993. Environmental Protection at the State Level: Politics and Progress in Controlling Pollution. New York: M. E. Sharpe. |
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Ulrich, Dana., Scott Burnham, Caroline Duncker, and Greg Lindsey. 1995. Urban Nonpoint Source Control in Indiana: An Assessment. 95-E03. Indianapolis, Ind.: School of Public and Environmental Affairs, Center for Urban Policy and the Environment. |
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U.S. Bureau of the Census. 1994. County and City Data Book, 1994. 1990 data, 12th ed. Washington, D.C.: U.S. Department of Commerce. |
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U.S. Bureau of the Census. 1994. Statistical Abstract of the United States, 1994. 14th ed. Washington, D.C.: U.S. Department of Commerce. |
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U.S. Environmental Protection Agency (EPA). 1989. Nonpoint Sources Agenda for the Future: Nonpoint Source Solutions. Office of Water (WH-556). Washington, D.C. |
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U.S. Geological Survey (USGS). 1993. National Water Summary 1990-91: Hydrologic Events and Stream Water Quality. Water-Supply Paper No. 2400. Washington, D.C.: |
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