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For the most effective use of Federal aid in metropolitan developments, projects should be consistent with comprehensive plans rather than single-function plans, and the plans should cover the entire metropolitan area. Hospital construction can be planned best, for example, if a hospital project is not only coordinated with other hospital construction, but also with the anticipated distribution of population and with the network of highways and public transportation serving the site that is chosen.

Most Federal urban development programs require some form of planning, but generally it is special-purpose planning for the specific program only. Only a handful of programs require or encourage comprehensive planning on a metropolitan basis. Several of the more recent ones contain these provisions, and additional encouragement for such planning is likely in future Federal programs. The Urban Mass Transportation Act of 1964, for example, specifies that grants can be made only to carry out a program "for a unified or officially coordinated urban transportation system as part of the comprehensively planned development of the urban area." And the 1965 amendments to the Federal Water Pollution Control Act authorize an additional 10 percent grant for sewage treatment plant projects that are certified by an official State, regional, or metropolitan planning agency as being in conformity with a comprehensive plan of development.

Metropolitan planning for coordinated urban development offers great promise both for dealing with many areawide problems and for the efficient administration of Federal aid programs. The Commission accordingly has recommended that local applications for Federal aid under the major urban development programs be submitted for prior review, but not necessarily approval, to an official metropolitan planning agency. A Federal requirement to this effect would provide powerful incentives to establish metropolitan planning in areas where it does not yet exist. It would greatly strengthen the position of metropolitan planning by requiring additional involvement with local development proposals and by bringing it into the important channel between local governments and Washington. At the same time metropolitan planning agencies can provide the Federal Government with a useful level of information and review close to the local scene but with an areawide perspective.

5. The Commission recommends that the Congress enact legislation to establish the principle of Federal interagency coordination in the full range of programs affecting urban development; and that the executive branch of the Federal Government implement the congressionally stated principle by preparing and adopting a unified urban development policy establishing coordinating procedures.

The number and complexity of Federal urban development programs has created formidable problems of coordination within the Federal Government. Working relationships among different Federal agencies administering related programs have been established in several ways: by legislation, by Presidential direction, by formal interagency agreement, and by informal agreements. Informal relationships between agencies and departments, and between major component units within the larger agencies and departments, are by far the most common. These cover about two-thirds of the programs.

About one-quarter operate under formal interagency agreements for sharing review responsibilities for plans or projects, and slightly more than one-quarter have legislatively established working relationships. Less than one-fifth have working relationships established by formal Presidential policy. There is no evidence of any general urban development policy for coordinating all Federal programs in the field.

Congressional action should state a basic urban development objective and make it the unifying principle applicable to all Federal programs affecting urban development. The statement should incorporate desirable objectives of individual programs that have stood the test of time, political consensus, and administrative workability. In addition, individual programs should state the positive objective of helping to fulfill the locally prepared and adopted development plans for urban areas.

Federal measures to unify policy and administration of programs can be illustrated in the field of water resource development, where administrative responsibility is distributed among a number of departments and agencies. Congress has taken action in the Flood Control Act, the River and Harbor Act, and the Fish and Wildlife Coordination Act, among others, to direct that interagency coordination take place before the approval of projects.

The interagency water resource policy appears in many respects to set a useful precedent for a unified urban development policy. It establishes planning objectives in terms of physical and economic development, natural resource preservation, and the well-being of people. It establishes planning policies and procedures under the headings of (a) National, regional, State, and local viewpoints, (b) multiple-purpose planning, (c) river basin planning, (d) individual project planning, (e) coordination within the Federal Government and with non-Federal interests, and (f) relation to existing law and Executive orders. It establishes functional standards for water resource planning. Finally, it requires that plans and project proposals comply with the objectives, policies, and standards thus established. More recently, culminating nearly 30 years of interagency efforts, an interagency coordination, policy affecting water and related land resources was promulgated. It is a combination of a formal interagency agreement, a presidentially approved interagency coordination policy, and a legislatively established policy which provides not only unified policy guidelines for all water projects but also specific interagency review procedures.

The Bureau of the Budget, on behalf of the President, reviews water resources programs and projects for compliance.

SHARING RESPONSIBILITIES FOR WATER SUPPLY AND SEWAGE DISPOSAL

The above recommendations are directed at general improvements in the ability of governments to handle urban problems. The resources of the federal system need to be marshaled in slightly different ways to cope with particular service problems rather than general structural

17 U.S. President's Water Resources Council, "Policies, Standards, and Procedures in the Formulation. Evaluation, and Review of Plans for Use and Development of Water and Related Land Resources," S. Doc. 97, 87th Cong., 2d sess. (Washington: U.S. Government Printing Office, 1962).

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METROPOLITAN AMERICA: CHALLENGE TO FEDERALISM

goals. The closely related urban functions of water supply and sewage disposal, described in chapter 4, have many intergovernmental ramifications. As a result, they serve as a useful illustration of the specific measures that can be taken to deal with problems of urban services.

1. INCREASED LOCAL INVESTMENTS FOR SEWAGE TREATMENT FACILITIES

The Commission recommends that public officials in urban areas make greater efforts to increase public investments in urban water facilities, particularly for sewage treatment.

Sewage treatment and water quality are more pressing problems than water supply and distribution. The failure of a community or industry to treat wastes usually burdens others, while an inadequate water supply directly affects the welfare of the community or industry itself.

In most instances the failure to invest in water and sewer utilities, particularly sewage treatment facilities, is not the result of such factors as legal restrictions on the community's ability to float bonds or increase taxes. Instead it is a product of the unwillingness of the localities to spend money. This unwillingness is a product of apathy, dislike of new taxes, and competing demands on the public and private dollar.

2. CENTRAL CITIES' RESPONSIBILITY

FOR COMPREHENSIVE AREA WIDE UTILITY PLANNING

Where central cities, counties, and other jurisdictions provide water or sewer service to other units of government on a contract basis, they should assume the responsibility for comprehensive areawide facility planning. In addition, these jurisdictions should encourage the most economical development of service lines to the contracting areas. Supplier-buyer relationships between municipality and suburb might be eased through provision for suburban representation on water and sewer policy agencies.

Only occasionally does the central city value regional considerations over its own economic interests. Fear of aggravating the Lake Erie pollution caused by inadequate sewage treatment in the suburbs led Cleveland to ban extending water services to suburban developments not also served by sewage disposal systems. A few central cities, such as Nashville and Seattle, which provide water for nearly the entire metropolitan area, have engaged in long-range planning on a metropolitan basis and have avoided many of the shortcomings found in other areas where contracting is prevalent.

3. COMPREHENSIVE PLANNING FOR INTEGRATING WATER AND SEWER SERVICE PLANS WITH OTHER METROPOLITAN FUNCTIONS AND COORDINATED POLICYMAKING BY ELECTED OFFICIALS IN MEETING AREA WATER AND SEWER NEEDS

Comprehensive water utility planning, based on the metropolitan area as well as on watersheds and drainage basins, should be undertaken in each metropolitan area. This planning should integrate the provision of water and sewer services with other metropolitan functions, insure economies of scale, and promote sound overall patterns

of metropolitan development. Full use should be made of water and sewage planning and development as a basic tool for directing overall urban expansion along desirable and orderly lines. Primary responsibility for this function is best lodged in an area wide comprehensive planning agency. The metropolitan planning agency should tie together the technical planning efforts of the various local, regional, State, and Federal agencies whose activities affect urban water supply and waste disposal. Local units of government should coordinate utility policymaking on a regional basis, regardless of the number of operating agencies in the metropolitan area.

The creation of an operating metropolitan utility does not of itself guarantee adequate planning. Metropolitan water and sewer agencies staffed solely by engineers, as many are, are likely to concentrate on utility-oriented planning and to ignore broader questions of urban development. Usually it is not possible for a single-function metropolitan water or sewer agency to undertake comprehensive planning, and it should not be necessary. The metropolitan planning agency should have primary responsibility for urban development planning and for relating utility plans, developed by the technical staff of the water agency, to overall metropolitan plans.

4. ESTABLISHMENT OF A UNIT OF STATE GOVERNMENT FOR OVERALL STATE WATER RESOURCE PLANNING AND POLICYMAKING

The Commission recommends that States enact legislation giving responsibility for overall State water resource planning, policymaking, and program coordination to a single agency.18 State water resource planning and policy development should give urgent consideration to the requirements and problems of urban areas. Each State also should insure that the interests of its urban areas are included in the State's representation on interstate water agencies.

Arrangements developed in recent years in Maryland, New York, North Carolina, and Connecticut give a State water resources agency primary responsibility for planning and policymaking for all phases of water development, with the State health department retaining its traditional role in those areas where it possesses technical capabilities. This approach offers the best opportunity for improving the administration of State water functions. California and New Jersey have also developed strong water resource agencies with powers over a wide range of water activities, which may serve as models for other States.

5. ENFORCEMENT OF WATER POLLUTION AND PUBLIC HEALTH LEGISLATION BY THE STATES

The Commission recommends that the States enforce water pollution legislation and regulations affecting public health and recreation, and municipal, industrial, and other uses with greater vigor and thoroughness. Specifically, it recommends: (a) strengthened legislation to permit States, singly and jointly, to control and abate pollution of rivers and streams; (b) more vigorous administration of State

See "State Water Resource Planning and Coordination Act," ACIR 1966 State Legislative Program (Washington, D.C.: October 1965), pp. 360–367.

water pollution control programs, including adequate financial support; and (c) legislation giving appropriate State and local agencies regulatory authority over individual wells and septic tank installations, with a view to minimizing their use and limiting it to exceptional situations.19 To insure that cooperative techniques in enforcement of water pollution control programs do not become facades for delay and inaction, the State legislatures should provide time limits for each step in the enforcement procedures.

Substandard enforcement can be explained in part by the failure of the State legislatures to appropriate adequate funds, the lack of trained personnel to enforce water quality regulations, lack of followthrough in the supervision, operation, and maintenance of waste treatment plants after construction, and insufficient data on the costs and benefits of pollution abatement.

Much more important, however, are political factors in most States. The politics of pollution control involve high stakes, particularly for the municipal and industrial users who must bear the brunt of providing adequate treatment facilities. State water pollution control agencies are faced with the difficult task of balancing these interests, which normally possess considerable political influence at the State capital, against the interests of those who favor or are likely to benefit from improved water quality. The lack of precise economic guidelines on the cost of pollution and the economic benefits resulting from improved water quality increase the likelihood of basing State decisions largely on relative political influence. The obvious general benefits to health, recreation, conservation, property values, and general development usually do not generate concerted political activity. Further, these benefits offer few incentives to those directly responsible for pollution, particularly industrial water users, since the benefits do not accrue primarily to those who must make the necessary investments to improve water quality.

The compacts establishing the Interstate Sanitary Commission (with jurisdiction over New York Harbor), the Ohio River Valley Water Sanitation Commission, and the Tennessee River Basin Water Pollution Control Commission empower these interstate agencies to coordinate State programs, investigate pollution, conduct hearings, and issue orders to stop pollution. These compacts may serve as appropriate models for other States with major interstate waterways that serve highly urbanized areas.

Suggested legislation has been developed to establish a framework within which the necessary planning and regulation for the development of water and sewerage systems can be undertaken. It provides for the development of official community plans delineating the areas within which community systems must be provided, the areas where individual wells and septic tanks can be used on an interim basis, and the areas where individual systems are generally permissible. Once a plan is approved by the State health authority, no individual or community water supply or sewage systems can be installed in the area covered by the plan unless they are consistent with the plan and no State or local agency can grant building permits or approve subdivision

19 See "Control of Urban Water Supply and Sewerage Systems," ACIR 1966 State Legislative Program (Washington, D.C.: October 1965), pp. 174-220.

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