DEAR CONGRESSMAN DINGELL: This is in further reference to your letter o January 20, 1971 concerning the expiration on June 30, 1971 of the reimbursabl grant authorization under the Clean Water Restoration Act of 1966. As you know, by now, the Administration has proposed an extension of th grant authorization for the next three years ending June 30, 1974. Senator Muski in his proposed bill has suggested an extension until June 30, 1976. Provision for reimbursements have also been recommended for extension in each of th proposed bills. Virginia's municipal sewage treatment needs as we know them today are a follows: Based on the Administration's recommendation of $2 billion per year fo this program, it will take Virginia some four or five years to meet all of th needs about which we know today, and I know that this list will have to updated from time to time. Based on my recommendations, the General A sembly initiated in 1970 a State grant matching program by appropriating $7 million for 1970-1971. The 1971 General Assembly appropriated a total of $13.8 million for continuation of the grant matching program in 1971-1972, plus $3.5 million for additional needs in 1970-1971. As you can see, Virginia is now dedicated to the principle of State matching grants, and I believe that the Federal grant provisions and reimbursement should be continued for the next five years, at least. Cordially yours, LINWOOD HOLTON. WASHINGTON STATE OF WASHINGTON, Hon. JOHN D. DINGELL, Rayburn House Office Building, DEAR REPRESENTATIVE DINGELL: This is in response to your letter of January 20, 1971, requesting an appraisal of the construction grants program authorized under the Clean Water Restoration Act of 1966. As requested, I offer the following comments: IMPACT Fiscally, the program has been adequate to satisfy the construction grant needs in Washington during FY 1970. By mid-FY 1971, however, funds were unavailable for 45 percent of the projects requesting grants. It is expected that this deficiency will increase to 62 percent by the end of FY 1971. Higher levels of funding are needed to match the increase in the momentum of the construction program. Our funding requirements are presented below under the heading, "Estimate of Financial Needs." SHORTCOMINGS 1. Regulations printed on July 2, 1970, in the Federal Register entitled 18 CFR 601 require that certain worthwhile planning requirements be fulfilled according to specific deadlines as a prerequisite to receiving construction grants. These requirements carry a substantial fiscal and program impact. Section 3(c) of PL 84-660 as amended by the Clean Water Restoration Act, provides funds for this type of activity. However, the level of funds available are severely limited and cannot meet the planning requirements generated by the July 2, regulations. Planning needs for this state are presented below under the heading "Estimates of Financial Needs." 2. The existing program participates in the funding of treatment facilities on a "pay-as-you-build" basis. The administration of construction projects involves two distinct phases: the preconstruction phase, representing about 10 percent of the total project cost; and the construction phase, representing the remaining 90 percent of the total cost. At the time of construction, a project is fully supported by local, State and Federal dollars. Local bond issues have been successful and construction grants are available. However, with the existing "pay-as-you-build" approach, there is a paucity of funds available for preconstruction activities. We have found in Washington that the unavailability of funds for these activities is one of the most limiting factors which delay the timely implementation of our water quality management program. There is a need for a major revision in the existing program to provide preconstruction funds for those legal, fiscal and engineering design preparations necessary prior to construction. 3. It is evident in Washington that some of the most severe effects on water quality arise from uncontrolled storm water. The previously mentioned July 2, 1970 regulations require that planning for basins and regional/metropolitan areas reflect a sound water quality management program. There is a need to place available funds in the areas of highest need. Since 1967, municipalities within the State which are most adversely affected by storm water initiated a program of separation and control as an integral part of their water pollution control responsibilities. A report entitled "Problems of Combined Sewer Facilities and Overflows," 1967, prepared by the Federal Water Quality Administration, demonstrates that Washington State has a financial need in the area of $600 million for storm separation projects. Unfortunately, no significant amounts of funds have been made available for this activity. There is a need to include storm separation as an eligible item in the program. Funding needs for Washington are listed below. 4. Each grant project which is presently being constructed in the State has been critically examined in view of the regional approach to solving water pollution problems. If it is feasible to build a single treatment facility to serve several dischargers in lieu of separate facilities for individual dischargers, it is required that the regional approach be selected. The regulations of the Washington State Department of Ecology and the Federal Water Quality Office lend full support to this approach. It is unfortunate, however, that the decisions made concerning "feasibility" are limited by currently available funds. There is a need to further the success in this worthwhile effort. The existing program provides no financial incentive for making the regional approach the more desirable one. SUGGESTIONS FOR PROGRAM IMPROVEMENT It is recommended that adequate appropriations be made to the Environmental Protection Agency to provide planning grants to complete basin and regional/ metropolitan plans as required by 18 CFR 601. It is recommended that the existing program be altered to allow 100 percent funding of preconstruction activities leading to the construction of facilities eligible for construction grant participation. The grant should range in the area of 10-15 percent of the preliminary estimates of total eligible costs. It is recommended that grant eligibility be extended to cover storm water control and separation as well as treatment. It is recommended that an incentive grant be given to those projects which elect to construct a more costly project which conforms to the regional approach to water pollution control. Estimate of Financial Needs: [In millions] Fiscal year 1972-76 Eligible known waste treatment construction costs_ treatment Storm water treatment, control and/or separation__. If further information is required, please contact John A. Biggs, Director, Department of Ecology, P.O. Box 829, Olympia, Washington 98501. Sincerely, DANIEL J. EVANS, Governor. WEST VIRGINIA STATE OF WEST VIRGINIA, OFFICE OF THE GOVERNOR, Charleston, February 23, 1971. Hon. JOHN D. DINGELL, Congress of the United States, DEAR CONGRESSMAN DINGELL: As you may recall, I have written to you earlier on our concern related to the federal funding for municipal construction of waste water treatment plants. West Virginia happens to be one of the states which has not, up to this time, had a state program for financing. I have recommended, in the past, an increase in federal funding in West Virginia due to our relative economic status under Appalachia for financing. Due to the limited federal funding, under the 30 per cent matching program, West Virginia has had the unfortunate experience of returning a sizeable portion of its federal grant funds for reallocation. This occurred during 1969-70 and will occur during 1970-71. In view of the federal grants program limitation of 30 per cent, it would seem most appropriate to initiate a state program to accelerate the construction program. For this reason, it is my intention to request state funds to provide the 25 per cent matching effort during this current term of the state legislature. Due to the limited size of our cities and towns in West Virginia, I do not believe that the problems which are being experienced by the larger states will prevail. Also, since the State has set up a priority system for grants, it would appear that we would not experience any great difficulty in taking care of the short-range needs. As to the extended needs, five to ten years, it may be that the federal funding may be inadequate, however, it is not firmly established at this time what the proposed federal funding program will be five to ten years bence. Enclosed is a report that was jointly authored by West Virginia and the Environmental Protection Agency. It gives a good appraisal of West Virginia's water pollution control program and its areas of deficiencies. It is my intent to correct the deficiencies, wherever they exist, to the best of my ability. Sincerely, DEAR REPRESENTIVE DINGELL: This is in reply to your letter dated January 20, 1971, regarding the impact of the Clean Water Restoration Act of 1966 on the Virgin Islands sewage disposal construction program. Allocations to the Virgin Islands for Construction Grants for the last four years have been as follows: 1968 1969 1970 1971 $1,440, 600 1, 424, 400 Please note that in 1968 with a grants total of $214 million, allocations to the Virgin Islands were $1,440,600. In 1971 with a grants total of $800 million, allocations to the Virgin Islands were $1,523,200, an increase of $82,600. It is thus clearly indicated that an increase in construction grant funds will not benefit the Virgin Islands unless the present formula for allocations is changed. The Construction Grant Funds have had a tremendous impact on the Virgin Islands sewage disposal construction program. We have embarked on an ambitious program to provide sewage collection systems and sewage treatment plants for our three major islands within the next six years. As the Virgin Islands qualify for fifty-five (55) percent federal grant assistance we cannot complete these projects without federal aid. Our estimate of financial aid required over the next five years is as follows: Accordingly I strongly urge your support of any legislative proposals which will increase the rate of Federal funding commensurate with our needs. Sincerely, MELVIN H. EVANS, M.D., Governor. |