The Water Environment Federation (WEF) is the leading organization dedicated to the quality of our nation's waters. WEF is a not-for-profit technical, educational, and professional organization providing leadership and guidance in the preservation and enhancement of the global water environment. Founded in 1928, WEF has 40,000 members including engineers, scientists, wastewater treatment plant operators and managers, and others working in state and local government, federal agencies, academia, industry, and private practice. WEF members are practitioners involved directly in protecting and restoring water quality throughout the United States and abroad. As leaders in the effort to protect public health and to improve our nation's water environment for more than 60 years, we possess a unique insight into national water quality needs.

Through the work of WEF members and others, the Clean Water Act has been highly successful in helping achieve national clean water goals. Federal, state, and local governments, as well as the private sector, have contributed enormous financial and technical resources toward solving water quality problems. We have witnessed a rebirth of countless lakes, streams, rivers, and coastal areas. High levels of wastewater treatment are the norm throughout the United States. Public awareness of, and support for, the value of clean water is extremely high. The United States enjoys one of the highest levels of water quality in the world.

Reauthorization of the Clean Water Act offers an unprecedented opportunity to evaluate our progress to date, and to apply those lessons to meet current and future clean water needs. The following statements outline primary issues - priority setting, funding, sound science, wet weather, and watershed management - that must be addressed by the U.S. federal government. A unifying theme among these statements is the need for a fresh approach to regulation that includes innovation and flexibility for water quality professionals. Future water quality problems will be more complicated than those already addressed. New levels of scientific understanding and technological development will be needed to preserve and enhance the quality of our water. New management tools and approaches to water quality protection also will be needed. New partnerships across many disciplines are crucial to the development of holistic solutions to environmental challenges. U.S. water policy and laws should incorporate the following concepts to continue our nation's remarkable success in cleaning our waters: 

1. The dynamics of wet weather situations are now challenging the profession to develop affordable programs, and current permits restrict discharges considered unachievable 25 years ago.
2. Innovative programs such as effluent trading need to be expanded by removing legal obstacles that limit their use.
3. Clearer requirements for critical issues of the day, including total maximum daily loads, nonpoint source pollution, and storm water runoff.
4. Support for operator certification to ensure the availability of adequately trained and certified personnel to operate and maintain wastewater systems. National guidelines for training and certification are required for consistency.
5. Strong enforcement is needed to protect the public health and environment. Enforcement should first seek to achieve compliance through technical support and voluntary compliance. Enforcement programs should be evaluated on measures of compliance, not of enforcement actions. Enforcement programs must recognize that environmental professionals achieve extraordinarily stringent levels of treatment on a consistent basis while dealing with dynamic conditions associated with wastewater treatment.

Addressing these will position us to meet our water quality goals in the 21st century. The Water Environment Federation looks forward to taking a leadership role in working with Congress and other parties to develop a consensus America's water quality policies in the new millennium.

Water Quality Research

The Water Environment Federation believes U.S. water quality programs demand a comprehensive, long-term research agenda that allocates scarce resources to the areas in which they will achieve the greatest benefit. Basic and applied research is the cornerstone of successful water quality programs.

Research will allow the United States to ensure water quality and protect human health. A current lack of research and research funding is hindering our ability to make further progress in preserving water quality and preventing degradation of irreplaceable natural resources. Our research deficit also is hurting our ability to participate in the global environmental technology market, in which the United States trails several much smaller nations.

Research Needs
Research needs are extensive. The country's regulatory program now covers microscopically small measures in exceedingly large contexts, such as rivers or entire industries. New technologies constantly challenge our understanding of the world around us. Our knowledge of the uses and impacts of new tools requires continual revision. New developments in the management of water and water resources require the attention of researchers in the physical and social sciences.

Research is critical for prioritizing and addressing these contemporary issues in a cost-effective manner. Priority research areas include:

Watershed Management

• Surface water quality protection and preservation
• Groundwater quality, protection, and conservation
• Wastewater treatment processes
• Industrial wastewater treatment and reduction
• Risk management and risk assessment techniques
• Responsible management of wastewater effluent and residuals
• Competition in the water industries
• Human and environmental health
• Technology for treatment, research, and communication
• Societal effects of water quality programs
• Funding mechanisms for water quality improvements
• Holistic approaches to address water quality challenges and restore ecological balance
• Water reclamation for reuse
• Global environmental technology trade
• Interactions among the items above

Recommendations
The Water Environment Federation recommends that Congress place the highest priority on water quality research. Congress should take the following actions to promote greater emphasis on water quality research:

• Provide appropriate funding for research on a predictable basis.
• Better coordinate water quality research, especially among federal agencies, to eliminate duplication and ensure priority research needs are met first.
• Increase support for cooperative research mechanisms, such as the Water Environment Research Foundation, which can leverage federal assistance into a wide range of research projects.

Sound Science in Water Quality Policy and Decision Making
 
Introduction
The Water Environment Federation believes that preserving and enhancing water quality is possible only through the application of sound scientific knowledge and effective technology.

WEF believes water quality decisions must be based on sound science. WEF also recognizes that public policy making often must take place before scientific inquiry into an issue is completed and before the scientific community reaches consensus. Thus, policy makers and the public must be able to assess the quality of the science and reasoning that supports a decision or a policy and must be able to ascertain reasonably whether a set of scientific findings supports that decision/policy.

To maintain credibility, public policy decisions should clearly identify and explain the body of technical information considered in the decision, the interpretations made of scientific and other information, and how additional significant issues were factored into the policy.

What is Sound Science?
The term "sound science" should be used only to describe a process by which scientific data and conclusions are supported by studies conducted following the scientific method. Sound science is based upon organized investigations and observations conducted by qualified personnel using documented methods and leading to verifiable results and conclusions.

The Attributes Of Sound Science
Sound science is conducted according to the precepts of the scientific method. The scientific method includes the formulation of a testable hypothesis; the use of systematic and well-documented experimental or analytical methods; the application of appropriate data analysis tools; and the articulation of conclusions that address the hypothesis and are supported by the results. The scientific method helps to ensure that data and results are reliable and conclusions are supported by data.

To be accepted as sound science, the underlying research and experiments of any conclusions must be performed by investigators with expertise, acquired by formal training or practical experience, in using descriptive and analytical tools appropriately, to design proper studies, and to responsibly communicate results. Documented methods enable researchers and others to reproduce the results of an experiment. Well-documented methods are essential to validate data and to allow peer review. Conclusions should be drawn within the boundaries of the data and the scope of the study. Conclusions also must be directly supported by the experiment and subject to validation through independent review. Peer review of experiments through manuscripts submitted to professional journals for publication is a very common form of independent verification. Scientific advisory boards and expert panels also are common tools.

Recommendations
To ensure that individual program components meet overall clean water goals and are based on the best available scientific information, water quality policy within the United States must be based upon the following principles:

• Significant water quality issues should be subjected to an independent peer review process to examine the scientific basis of proposed policies.
• Federal agencies involved in water quality policy development or implementation should be required to appoint a sound science "gatekeeper" at the senior management level to ensure that agency decisions are rooted in sound science.
• EPA's Science Advisory Board should be strengthened and directed to ensure that Agency programs are rooted in sound science.
• The National Academies of Science and/or Engineering should review complex or controversial water quality issues with major national implications.
• Risk assessment and cost-benefit analysis used to guide water quality policy development must be based on a firm scientific and technical foundation to determine that there exists a scientifically substantiated need and an achievable benefit from proposed policies.
• Scientific analyses should be used to evaluate the relative benefits of various environmental protection activities when setting environmental priorities.
• Cross-media impacts of specific requirements must be considered.
• Sufficient resources for increased research and development of scientific information and technologies must form the basis for future environmental programs.

Watershed Planning and Management

Introduction
The Water Environment Federation supports watershed planning and management as the key to meeting clean water goals. The watershed approach allows for a comprehensive and integrated approach to protecting all water resources, including uplands, drainage basins, wetlands, surface waters and groundwaters. The approach involves comprehensive input from all stakeholders to establish priorities for problems, goals, and restoration efforts.

Issues
The Clean Water Act of 1972 established goals of protecting and restoring the integrity of our nation's waters. Since the CWA's passage, the primary focus of restoration efforts has been on the advancement of wastewater treatment infrastructure and technology. Substantial improvements have been achieved in water quality, but still more than one-third of our nation's waters fails to meet their designated uses. No longer are the leading causes of these impairments related only to wastewater. Water quality impairments now are known to involve nonpoint sources of pollution, habitat loss, sediment, hydrologic modification, and a myriad of other issues and concerns.

Restoration of water quality and uses currently is addressed by a patchwork of legislative and regulatory programs. This approach often separates individual sources of water quality degradation from all others. Thus, the existing framework is ineffective in fully restoring waters to their designated uses and often fails to allocate resources to priority needs. The federal government's recent emphasis on integrated watershed analysis in support of the total maximum daily load requirements of the Clean Water Act is a sign of progress. Implementation of such analysis, however, may lack comprehensiveness and adequate focus on protection of appropriate uses.

Recommendations
The Water Environment Federation recommends that the U.S. federal government encourage water quality management on a watershed basis. Specifically, WEF recommends that:

• Water quality programs be designed, integrated, and implemented in the context of watershed units and based on sound science.
• All stakeholders have equitable participation in both the decision making process and responsibility for protecting and restoring the water environment.
• Water quality regulation consider all pollutant sources, ecological stressors, and cross-media (air, land and water) effects.
• Watershed management and planning should be a vehicle to focus government priorities for clean water and tailor regulatory flexibility.
• Regulatory timetables, control programs, and funding be prioritized and synchronized to gain the most cost-effective benefit to the individual watershed.
• State and local governments be provided the flexibility to establish individual watershed goals and protection/restoration priorities based on comprehensive stakeholder input, federal guidance, and basic minimum standards.
• To the maximum extent possible, existing government and institutional mechanisms be used to manage watershed programs with the federal or state governments providing the means for coordinating inter-jurisdictional issues.

Priority Setting

Issue
Great progress has been made under the Clean Water Act in preserving and enhancing the nation's water quality. However, available resources are not sufficient to address all significant remaining water quality problems in the immediate future. USEPA has identified many areas of needed water quality improvement, including wastewater treatment, nonpoint source pollution control, stormwater discharges, combined sewer overflows, and acute and bioaccumulative toxics. The Water Infrastructure Network (WIN), a coalition of local elected officials, drinking water and wastewater service providers, environmental groups, labor unions and construction and engineering professionals estimates a $23 billion per year gap between infrastructure needs and current spending. Further progress in enhancing the water environment will be achieved in a timely and effective manner only by setting and following well-defined priorities.

Recommendations
To ensure that priority setting becomes an integral part of the Clean Water Act, a new national environmental policy should be added to Section 101 that requires all environmental priority setting be based on

• Risk assessment;
• State-of-the-art scientific information with independent peer review;
• Evaluation of cost-effectiveness;
• Promoting pollution prevention; and
• Consideration of cross-media impacts.

The Clean Water Act also should establish a framework for setting water quality management priorities. This framework should be based on the following elements:

Protection and enhancement of water quality.

• Identifying the greatest opportunities for the greatest degree of water quality improvement.
• Adjusting the implementation and rule-making provisions of the CWA to give the Administrator greater flexibility in addressing priorities.
• Revising statutory deadlines to reflect priorities and allow greater administrative discretion.
• Setting priorities along logical geographic regions such as watersheds.
• Ensuring state flexibility in setting standards based on region-specific conditions.

EPA should be required to develop a policy document based on this framework, with full public review and comment, and including methods for identifying, selecting, and managing priorities under the Clean Water Act.

Financing To Meet Municipal Water Quality Needs

Issue
Federal funding is the cornerstone upon which the regulatory and wastewater treatment plant construction programs mandated by the Clean Water Act (CWA) of 1972 were financed. Billions of dollars have been invested to help state and local governments meet national clean water goals. Today, however, the estimated cost of municipal wastewater facilities construction needed to comply with enforceable requirements of the Act is rising even as overall federal financial support declines. Currently local governments pay more than 90% of the cost for this basic public health infrastructure, and an enhanced federal role is needed if our overall clean water standards are to be maintained.

Funding Needs
According to the Water Infrastructure Network (WIN) America's water and wastewater systems face an estimated funding gap of $23 billion a year between current investments in infrastructure and the investments that will be needed annually over the next 20 years to replace aging and failing pipes and meet mandates of the Clean Water Act and Safe Drinking Water Act. Of this total, wastewater systems account for $12 billion a year. WIN is a nonpartisan coalition of local elected officials, drinking water and wastewater service providers, environmental groups, labor unions and construction and engineering professionals.

Recommendations
The Water Environment Federation (WEF) has long supported federal financial assistance for clean water programs as part of a partnership between federal, state, and local governments. WEF also has encouraged the use of alternative and innovative sources of financing. In light of our commitment to achieving the nation's water quality goals, WEF recommends that the CWA be amended to

• Create a long-term, sustainable and reliable source of federal funding for clean and safe water.
• Provide adequate funds to EPA and states to support development of scientifically valid ecological risk assessment protocols, watershed management protocols, and water quality criteria.
• Provide expanded, targeted technical assistance to communities most in need.
• Streamline federal administration of the funding program and encourage continuous improvement in program administration at both the federal and state levels