Approved April 19, 1991, by the WEF Executive Committee

The Water Environment Federation is proud of the progress made under the Federal Water Pollution Control Act Amendments during the past 20 years. WEF believes, however, that the country will be able to allocate sufficient resources to address remaining water quality problems in a timely and effective manner only by carefully setting and following well-defined priorities for achieving our water quality goals.

The Clean Water Act should establish the process by which water quality and environmental priorities are set. These priorities should emphasize protection and enhancement of water quality and biological integrity, and should identify the greatest opportunities for accomplishing the greatest degree of water quality improvement to the nation's rivers, lakes, coastal waters, and groundwater. Successful setting and management of priorities under the Act will provide a model for environmental priority setting and management beyond the water environment.

To promote water quality and environmental priority setting and management, WEF offers the following recommendations.

Establishing New Goals to the Clean Water Act
Since passage of the Clean Water Act, WEF has seen the emergence of difficult nonpoint source water quality problems, increased regulatory complexity, and dwindling financial resources. In light of these developments, we believe it is appropriate for Congress to revisit the goals of the Act, as follows:

Priority Setting
A goal should be added to the Act which establishes environmental priority setting and management in accordance with other goals of the Act. Environmental priority setting means setting priorities based upon the greatest opportunities to gain needed water quality improvements. This goal should state that as we continue to work to eliminate discharges of pollutants and restore and maintain the chemical, physical, and biological integrity of the nation's waters, activities for improving water quality must be based upon scientifically valid analyses of the relative environmental benefit of that activity compared to other programs required under the Act. Resources must be focused on those activities which will achieve the greatest benefit to the environment.

Cross-Media Impacts
Another goal should be added to the Act which promotes the examination of cross-media (i.e., water, air, soil, etc.) impacts of water pollution control, prevention, and water quality management actions. This goal should state that all activities required under the Act will be carried out only after full consideration is given to the potential impact in all media. A classic example of cross-media impact occurs when considering the management of biosolids (treated wastewater solids). Biosolids management activities offer tradeoffs between air quality (incineration), groundwater quality (landfill leachates), and ocean disposal.

Pollution Prevention
A third goal should be added to the Act which encourages methods for pollution prevention. This new goal should establish as national policy the role of pollution prevention, recycling, reuse, use of Best Management Practices, and waste minimization in improving water quality. Once again, biosolids management activities provide a classic example: appropriate wastewater treatment and industrial pretreatment will enable wastewater residuals to be utilized as a valuable soil conditioner and nutrient source.

Policy To Set Environmental Priorities
EPA should publish a draft policy detailing how environmental priorities would be identified, selected, and managed under this and other federal laws. Similar draft policies on cross-media impacts and pollution prevention also should be published. These draft policies should be subject to full public review and comment.

Scientific Basis for Priorities
Environmental priorities must be based upon state-of-the-art scientific information. Priorities should be periodically re-evaluated to incorporate new scientific and technical knowledge.

Independent Review Process
An independent review process should be conducted to evaluate EPA's methodology and progress toward implementing the new goals of the Clean Water Act. This agency-wide review should assess and report on the priority setting process, the benefits to be attained through the ordering of priorities, cross-media impact studies, and efforts to achieve the goal of pollution prevention.

Implementation of Priorities
The setting of environmental priorities under the Clean Water Act should result in water quality program implementation which provides the greatest degree of water quality improvement for the available resources.

Regional Water Quality Priorities
Wherever possible, efforts should be made to prioritize water quality improvement programs along logical geographic regions. Regional programs should be implemented in a manner which continues to guarantee state primacy in setting water quality standards, based upon region-specific natural conditions.

Enforcement
Environmental priority setting and management proposals must incorporate enforcement mechanisms appropriate to attaining maximum water quality improvements. Maintaining and enhancing water quality and biological integrity must be the primary objective when setting environmental enforcement priorities.