Conducting the Environmental Impact Analysis and Assessment - Environmental Impact Analysis: Process and Methods - page 195

discussed in Section 5.3.4 represent research done for the environmental
analysis to determine impact significance. Similar studies can be conducted
as described in Section 7.2 for ecological risk assessment to determine accept-
able levels of impact. As with original investigations as part of affected envi-
ronment description, such research should be approached cautiously. The
resources and schedule of most environmental impact analyses are not com-
patible with extensive impact criteria research, and if not adequately planned,
conducted, and reviewed, the results may not be acceptable to stakeholders.
An alternative, as described in the next section, is to implement a comprehen-
sive research effort to develop significance criteria applicable to a broad pro-
gram or conditions applicable to multiple actions and then apply the criteria
to specific environmental analyses.
5.3.3.3 Programmatic Significance Criteria: Clean Water
Act Section 201 Wastewater Management
Next to NEPA, the passage of the Clean Water Act in 1972 (33 U.S.C. §1251 et
seq. 1972) was the largest environmental protection leap forward in the early
years of environmental awareness. The Act had the lofty goals of creating
fishable swimmable waters within 10 years of passage and achieving zero
discharge of pollutants five years later. The Act included the following major
initiatives to achieve the goals:
r Regulation of all industrial and municipal discharges to waters of
the United States
r Development of water quality standards by each state
r Promoting research into water quality and wastewater treatment
r Federal financial assistance for municipal wastewater management
including treatment plant construction
The funding of municipal wastewater management under Section 201 of
the Clean Water Act was the largest government-financed environmental
improvement program ever undertaken. The “201 Grant Program” with the
addition of state assistance provided up to 90% of the funds for every munici-
pality in the United States to plan, design, and construct new or upgraded
wastewater treatment facilities. Since at the time there were very few cities or
towns that had adequate wastewater treatment systems in place, the program
required a huge commitment of funds. For example, most of New York City
had only primary treatment and the entire west side of Manhattan had no
sewage treatment at all and discharged raw sewage to the Hudson River. An
estimated $202.5 billion in federal funds and an additional $50 billion in state
and local funds were necessary to fulfill the municipal wastewater manage-
ment mandate of the Clean Water Act (Copeland 2010).
EPA promulgated regulations to implement the Clean Water Act 201 Grant
program, which included a mandate for all municipal wastewater systems