Water Resources                                                             DOWNLOAD PDF
Approved: July 1997

Introduction
The availability and quality of water is a key factor in the nation's ability to protect public health, preserve ecological integrity, ensure sufficient agricultural production, and meet commercial needs. Issues impacting our nation's atmospheric water, surface water and groundwater (hereinafter referred to as "waters") must receive priority attention if the nation's public health and ecological and commercial objectives are to be met.

The engineering profession plays a key role in protecting and managing our nation's water resources. Engineers are leaders in developing the methods for ensuring that public health and ecological expectations for the country's water resources are satisfied.

Engineers are also the lead technical professionals in designing the infrastructure for managing water resources in areas such as flood control, water supply, water and wastewater treatment, channel and harbor construction and maintenance, and hydropower development.

Background and Objectives
Many national laws have been enacted that address water resource quality and management needs and objectives. Among them are laws specifically oriented to water policy, such as the Federal Water Pollution Control Act, the Safe Drinking Water Act, and the Water Resources Development Act. Other federal laws, while not focused solely on water issues, also impact water policy. These include solid and hazardous waste disposal, fish and wildlife protection, and energy laws.

In 1972, Congress passed the Federal Water Pollution Control Act -- commonly known as the Clean Water Act (CWA). The CWA is the primary national law for ensuring the "chemical, physical, and biological integrity of the nation's waters." The Act sets forth national goals and objectives and outlines the following activities to meet these goals: directs states to develop water quality standards for intrastate waters; develops effluent guidelines and best available technology (BAT) standards for industrial categories; establishes the National Pollutant Discharge Elimination System (NPDES) permit and enforcement program; establishes national technology-based limitations for municipal and industrial dischargers; regulates the discharge of dredge or fill material into navigable waters, including wetlands; assigns responsibilities to the states for non-point source pollution control; provides water quality-based controls for toxic pollutants; and establishes programs for funding the construction of wastewater treatment facilities.

The Safe Drinking Water Act (SDWA), first passed in 1974, strives to protect the quality of the nation's drinking water and provides limited protection of groundwater resources. The Act requires the following: issuance of BAT standards for tap water contaminants that threaten public health; monitoring and treatment of drinking water to meet federal standards; disinfection and filtration of water provided by public water ystems; regulation of the disposal of wastes through underground injection; establishment of wellhead protection areas to protect wells from underground contamination; and, establishment of programs for funding the construction of water treatment facilities.

The River and Harbor Act of 1899 and the Water Resources Development Act assign to the U.S. Army Corps of Engineers the responsibility for ensuring the navigability of the nation's rivers and harbors and providing flood protection. The Water Resources Development Act also provides funding for various water resource development projects that meet those objectives as well as for coastal erosion and levee construction projects.

Other national laws affecting our nation's water resources include the Resource Conservation and Recovery Act (RCRA), the Superfund Amendments and Reauthorization Act (SARA), the Coastal Zone Management Act (CZMA), and numerous fish and wildlife protection, federal land management, and energy laws. At present, procedures have been established through professional and occupational licensing laws and voluntary certification programs for ensuring the minimum competency of individuals engaged in water resource assessment, design, and management activities.

The Problem Identified
Overuse, misuse, or contamination of water harms both the users and the ecological systems that depend on water.

Quality of Water
Under the Clean Water Act, significant progress has been made in reducing point source discharges of pollutants. While the CWA has led to success in reducing many point source discharges, there are still many unaddressed water quality problems attributable to point source discharges. For example, wet weather overflows from combined storm and sanitary sewers (CSOs) and sanitary sewers (SSOs) remain a source of or contaminated discharge. Funding needs for water resource infrastructure have not been met and much more remains to be done. For example, a study prepared by Apogee Research estimates a minimum shortfall of $31 billion for wastewater capital spending.1

In addition, pollutants attributed to contaminated runoff or "nonpoint sources" have not received adequate attention. Contaminated runoff can be attributed both to agricultural sources and urban conditions, such as the storm water runoff from roads and construction sites, or the accidental discharges of hazardous wastes such as motor fuel spills. Because of the nature of nonpoint source degradation, i.e., the difficulty of defining the "point" of discharge, new approaches to water quality assurance must be devised.

Our nation's groundwater (the source of drinking water for about half of the nation) is also threatened, attributable not only to contaminated runoff, but also to contamination from hazardous waste disposal sites, septic tanks, and leaking underground storage tanks. While enactment of the Safe Drinking Water Act has heightened our awareness of a need for a safe drinking water supply, threats from microbiological and chemical contaminants remain.

Atmospheric deposition of toxic contaminants also contributes to water quality degradation. Acidification of lakes and streams has contributed to the reduction or destruction of aquatic plant and animal species.

Efforts by government and the private sector to ensure the competency of individuals providing water resources assessment, design, and management services conflict with state professional licensing laws.

Quantity of Water
Water shortages exist not only in the western states but at times throughout the nation. Many geographic regions have water shortages, particularly as population has shifted. Water quantity issues impact the ability to meet the population's diverse water resource needs, such as electricity generation through hydropower, sufficient water for agricultural purposes, and adequate water for navigation. The ability to preserve ecological integrity and maintain water quality is affected as well.

Flooding is one of the most disastrous forces of nature, but the one whose damage engineers are most called upon to mitigate. Many of the ravages of flooding are brought about by man's improper use of the land. Poor fallowing, occupancy of flood plains and flood ways, clearing of trees, paved surfaces replacing vegetated areas, altered wetlands, and poor soils management practices are some of the impacts civilization has brought that have exacerbated flooding. In addition to property damage, other impacts include sedimentation, nutrient discharge, debris deposits, and disease and pestilence.

Distribution and Political Jurisdiction
The distribution of our water resources and the rights to the use of this resource are extremely complex issues involving the transfer of the water resource across watershed and geopolitical boundaries, rights of downstream users, and international treaties. The resolution of competing interests for the use, rights, and distribution of the resource affect us all through the cost of expensive and time consuming litigation and the impacts resulting from the settlement of disputes.

Advocacy of NSPE
Because engineers are often charged with implementing laws governing water resources, and because their technical expertise is essential to the development of technically sound policies, the engineering profession should participate in the development of laws and regulations which affect water.

Guiding Principles
The National Society of Professional Engineers (NSPE) believes a clean and sufficient water supply is critical to the future of our nation. We advocate the development and implementation of a national water resource policy that addresses the public health, ecological, agricultural, and commercial needs of the nation. A national water resource policy should strive to maintain our waters in sufficient quality and quantity to support both the needs of those who benefit from the resource and the natural systems that depend upon it. A national water resource policy should:

• provide for long term protection of the public health, safety, and welfare;
• provide for adequate supplies of water of appropriate quality for potable use; 
• provide for adequate supplies of water of the appropriate quality for domestic, agricultural, and industrial uses, and navigational purposes; 
• provide for adequate supplies of water of the appropriate quality for aesthetics, fish and wildlife habitat, minimum flows for stream maintenance, and recreational use; 
• minimize the adverse impacts of extreme hydrologic events 
• provide water for future generations, including the preservation of selected areas in their natural state  
• represent a consensus among the public, regulated parties, and engineering and scientific professionals; 
• provide for the assesment of risks to public health and the environment and the analysis of costs and benefits in determining management standards and priorities; 
• promote scientific and engineering research and technology development to continuously improve water resources management.

Systems Approach
The various components of a national policy on water resources should be viewed as integrated units of a total system. Each component should be developed in the context of overall water resource goals. Issues concerning water quality and quantity must be addressed together. Planning for water should be integrated as well. Our national water resources policy should be crafted with consideration for its impacts on other issues and be consistent with policy objectives affecting other environmental media. Furthermore goals and policies should be harmonized with other public health, environmental protection, natural resources, infrastructure, energy, and commercial policies and goals. Current laws in all of these areas should be reevaluated as necessary for compatibility with national water policy objectives.

Implementation Principles
An effective plan for implementation of the many components of a national water resource policy is required if we expect the goals of that policy to be achieved. The following principles should serve as a guide when developing the framework for such a policy:

• Cost-benefit considerations should be factored into the evaluation of water resources management options. Economic impacts on all affected parties, including the public at large, should be assessed. Indirect costs and non-economic benefits should also be considered.
  
• The technical and scientific basis (such as Best Available Technology (BAT) standards, criteria documents, or Best Management Practices (BMP) guidance) for regulatory programs should be developed by individuals competent in the understanding and application of engineering or science. 
  
• Compliance with program requirements should be obtained through performance-based standards rather than technology-based requirements. Performance-based standards allow for flexibility in addressing the problems unique to each watershed. Permitting of waste dischargers should also be performance-based. 
  
•  All sources of water pollution, including national, state, and local government entities, should be held to the same compliance standards and subject to the same enforcement practices.
  
• A range of options for implementing water resource programs should be fashioned, including the establishment of incentives for voluntary participation and compliance and rigorous enforcement procedures to address non-compliance situations. 
  
• The effort required to address a water resource quality or quantity problem should primarily be underwritten, on a basis proportional to responsibility and benefit, by those who contribute to the problem and benefit from the solution to the problem. 
  
• Implementation timetables should realistically take into account the actual scientific, engineering and technical information available to address the situation. Timetables should also consider the financial and institutional capabilities of regulated parties to meet program requirements. Timetables should also allow adequate periods of time for the development of regulations and public comment. 
  
• Programs should be developed in a manner that allows for program administrators, particularly at state and regional levels of government, to address particular problems and variations within watersheds. 

Roles of Government
The roles of government agencies at the national, state, and local levels must be clearly delineated in the development and administration of water resource policy. Each unit should be entrusted with fulfilling its obligations. Unnecessary oversight by higher units of government should be eliminated. However, we recognize the need for preemption by a higher level of government if minimum national objectives are not achieved. While there is a clear national role for setting objectives for our water resources, management must be done on a watershed basis.

National Government Role—The national government should establish broad water resource goals and develop minimum guidelines for state, regional, and local government programs to implement and enforce those goals. Nationally-defined policies should encourage problem-solving on a regional, watershed, or drainage basin basis, where practical. As a result, the national government should devote attention and resources to assisting state, regional, and local government in developing watershed management strategies.

The national government should coordinate and provide funding for research, technical assistance, and public awareness activities in areas where the benefits or needs are clearly national in scope. The national government should also manage water resource development activities in cases where the project has a clear national strategic need, or when the benefit of such a project is truly national or international in scope.

A formal mechanism for coordinating water resources management at the federal agency level is necessary. Currently, numerous federal departments and agencies have authority over various water-related activities, and a formal mechanism for interaction between the agencies is lacking. A coordinating body would ensure that federal agencies are working in harmony toward the same national goals, streamline overlapping authorities, ensure that agencies are not duplicating each others' efforts, and ensure that various laws are compatible and contain the same level of governance.

State, Regional, and Local Government Role—Authority and responsibility for implementation and enforcement of water resource policies should be assigned to the lowest level of government that can effectively administer it. Some tasks currently assigned to the national government should be reassigned as appropriate to state, regional, and local governments. State government should be responsible for developing comprehensive water resource management plans for the state, implementing federally-specified programs, and ensuring completion of national objectives. Local governments should play an administrative and planning role as well.

Intergovernmental Cooperation
The distribution, allocation, and use of water resources transcends national, state, tribal, and local borders. Individual units of governments cannot assume sole responsibility for resolving these regional, interstate, or international issues pertaining to water rights, the transport of water across state or national boundaries, or other issues. We recognize the complexity of such issues and encourage interagency and intergovernmental coordination to solve them. We acknowledge, however, that intergovernmental efforts are not required for all water-related decisions, and instead encourage the establishment of such coordinating mechanisms only to address those particular concerns that require such an approach. Furthermore, only those governmental units with a specific charge to resolving such issues and with a unique technical understanding of the issue should participate. Conflicts between units of government, including the transfer of water between watersheds, should be resolved on a sound scientific and technical basis and with an accurate and complete assessment of the needs of the region. A socioeconomic or politically acceptable resolution should not compromise the need to maintain a sound and correct technical solution to the conflict.

Scientific, Engineering, and Technical Research
We support adequately funded government-sponsored, university-based, and private sector research that furthers understanding of pollution prevention and control technologies and strategies, and improves knowledge on the health and ecological impacts of water quality and quantity impairment. Under a systems approach to water resources management, there should be greater attention to public health and ecological impacts. As a result, efforts should be targeted to document those constituents that have true public health and ecological impacts, rather than developing technologies for controlling pollutants that have limited or no impact on public health or the environment. Rather than arbitrarily setting a water quality standard and then maximizing the technology to meet that standard, national policy should set water quality standards based on a scientific and technical evaluation of the appropriate quality needed for the water's intended use.

Education and Training
Greater emphasis should be placed on providing education and information to the public and agricultural and commercial users on the causes and consequences of and solutions to water resource degradation and allocation. A range of formal and informal activities for providing this information is encouraged, including the development of curricula for use in classrooms and public awareness campaigns initiated by the private sector and government. Pollution prevention, waste reduction and minimization, and resource conservation are among the themes that should be emphasized in these outreach efforts. To increase public understanding of the interconnectedness of water systems to other systems, these education and outreach activities should emphasize the impact of water resource decisions on other policies and goals. Attention should also be directed to supporting an education and training system adequate to ensure a stable supply of water resource professionals.

Professional Regulation
Management of water resources requires the knowledge and skills of individuals educated and trained in science, engineering, technology, and the trades. Professional and occupational licensing laws and recognized private certification programs are appropriate mechanisms for ensuring the competency of individuals providing water resources assessment, design, and management services.

The regulation of professional and occupational practice through licensure is an exercise of the constitutional power of the states to protect the public health, safety, and welfare -- the so-called "police powers." Accordingly, we oppose licensure or certification requirements at the national level for individuals engaged in water resources assessment or management activities. National licensing laws in the water resources field usurp the authority of state governments and conflict with the regulation of other professions and occupations.

We oppose national and state licensing laws and private certification programs that permit unqualified individuals to practice engineering, as governed by state law, without first obtaining a professional engineering license.

We also oppose national and state laws that require licensed professional engineers to obtain additional licenses or certificates in order to continue providing services that they are already authorized to provide under the professional engineering statutes.

Private sector organizations that issue certifications should have their credentialing processes accredited by a recognized accreditation body. Accreditation assures the public, or a government agency that elects to use the certification as a measure of competency, that the certificant has met the minimum criteria expected of a legitimate credentialing process.

Funding
National Obligations—Federal funding should be reserved for those programs and projects involving broadly diffused benefits and effects, including research, outreach, the development of program guidelines or standards, and some water resource development projects. The national government should also provide financial assistance to state and local governments to aid them in developing water resource management plans that implement federal standards. However, these planning funds should not be considered permanent expenditures but rather medium-term assistance for states to assume their traditional managerial roles.

Fee and Tax Structures—Costs for national, regional, state, and local water resource programs should be borne by the user group or problem contributor most closely identified with the expense through the collection of user fees or penalties.

To meet water quality and quantity objectives, we encourage state and local governments to establish water and sewer rates that adequately reflect the true cost of providing water and wastewater treatment or water supply services. We recommend a utility-based rate structure that would guarantee that the increased revenues are spent for their dedicated purpose. Further, we support the development of "enterprise funds" within state and local budgets to ensure that resultant revenues are collected, retained, and spent totally separate from general revenues.

We oppose the imposition of a national tax or user fee on water and sewer bills to fund water or wastewater treatment or water supply projects. Such a tax is an intrusion on state and local authority to establish such rates. Additionally, we oppose the establishment of a national water and wastewater trust fund. Collection of a national tax at the local level, only to be redistributed back to the local level, would be a very inefficient system that would not necessarily redistribute those revenues equitably. Such a system would also penalize rate payers of those communities that have already increased utility rates to comply with the requirements of federal law, only to be taxed again to meet the needs of other communities that have not yet met equivalent requirements.

Public-Private Partnerships—We support legislative and regulatory improvements that encourage private sector participation in providing water and wastewater treatment or water supply services. Given the limited public funds available for discretionary spending and the intense competition among various interests for these funds, it is appropriate to include private-public partnerships as a component of an overall water resource policy.

Water Resource Development Project Funding—Costs to the national government for water resource development or water and wastewater treatment projects with clear regional, state, or local, rather than national or international, benefits should be fully recovered. Project costs should be shared or fully repaid by project beneficiaries and problem contributors. A fair and equitable allocation of costs and cost recovery should be developed based on benefits and the relative impacts of the resources.

Wastewater Infrastructure Funding—We are a strong advocate for the State Revolving Fund (SRF) program authorized in the Clean Water Act. The program appropriately provides for the gradual transfer of responsibility for funding wastewater treatment back to the state and local level. By doing so, wastewater treatment services will be provided more efficiently, more expeditiously, and at less expense to the national treasury than was possible through the Construction Grants program. In addition, a loan program leads to better public policy decisions regarding wastewater.

We urge the Congress to uphold its commitment to provide full federal capitalization of the SRF program. A properly implemented and fully capitalized SRF program is a short-term commitment that is well worth the full initial investment. Federal contributions to the SRF should be terminated once the state revolving funds are capable of standing on their own.

We recommend that the U.S. Environmental Protection Agency implement what we believe was originally intended by the law -- payment of federal capitalization grants to the states in the form of cash. When the statute was passed by Congress, we felt, and still feel, that it would allow EPA to disburse funds to the states in advance of the state's obligations and on a fixed payment program. These federal payments, in conjunction with the repayment of loans made from the state SRF loan funds, could then be pledged for debt service for state-issued bonds, thereby "leveraging" the effects of the federal contributions. If the states were allowed to receive their SRF capitalization grants in advance of actually spending the funds, they could generate greater levels of capital for their revolving funds.

We also recommend the elimination of Clean Water Act provisions that subject facilities receiving SRF-financed loans to the same requirements that were placed on construction grant recipients. While these requirements may have been appropriate for the Construction Grants program, they are unduly burdensome and duplicative of state-managed efforts.

We oppose the expansion of activities eligible for SRF financing beyond those authorized in the original statute. Any additional water quality requirements should be structured so that state and local funding mechanisms are in place from the outset.

We oppose any attempt to extend the federal Construction Grants program of the Clean Water Act. The grants program creates disincentives for states and localities to provide their own funding for wastewater treatment, delays the construction of facilities, and imposes taxing regulatory criteria that result in an inefficient funding stream.

We recognize that small and economically disadvantaged communities are encountering difficulties in obtaining financing. To meet these needs, we support legislative and regulatory actions that facilitate the ability of these communities to obtain SRF loans. We strongly oppose the use of any funds for a construction grants program managed by the Environmental Protection Agency to meet these needs. Recognizing that a grants program may be the only source of funding for the most disadvantaged and the smallest communities, we urge Congress and the Administration to enhance federal programs that provide grant and loan assistance to small and economically disadvantaged communities already in place. These programs have far more experience addressing the special needs of small communities and are far more capable of integrating wastewater treatment funding with other economic development projects.

Water Infrastructure Funding—As the federal government is setting increasingly rigorous demands for drinking water, the establishment of a federally-supported state revolving loan program to assist localities in meeting their drinking water needs was justifiable. This program should include the principles we have recommended concerning the SRF program for wastewater treatment infrastructure.

We are supportive of establishment of the drinking water SRF program currently in place; however, we hope its existence does not diminish the level of appropriations made to the wastewater SRF. It is counterproductive to both the wastewater and drinking water programs to underfund either/or both programs.

Pollution Prevention
Agricultural, industrial, municipal, and residential dischargers can eliminate, reduce, or minimize many of the pollutants entering our waters. In most cases, pollution prevention, waste reduction, or waste minimization is preferable to end-of-pipe treatment or post-contamination cleanup from a public health, ecological, and economic perspective. As a result, pollution prevention, waste minimization, and waste reduction techniques should be fully integrated into water quality goals. Dischargers should be required to implement reasonable pollution prevention technologies and strategies in their processes or activities. Because the understanding of pollution prevention is still a growing field, requirements should be flexible to account for emerging methods and technologies. We encourage a regulated system whereby dischargers are provided incentives to enact pollution prevention, waste reduction, and waste minimization, rather than penalties for inaction.

Significant resources should be devoted to educating the public about pollution prevention strategies. Many such strategies will only be successful if attitudinal changes are fostered. In addition, dischargers should be provided technical assistance so that they gain information and access to the available pollution prevention techniques and technologies.

Additionally, we advocate government-sponsored, university-based, and private sector research into pollution prevention research and technology development.

Water Reuse and Conservation
Water shortages should be addressed by carefully allocating the resource according to its quality and intended use. Uncontaminated water should be reserved for meeting the potable water needs of the nation. Water that meets higher quality standards should not necessarily be used to meet needs that can be met with water of a lower quality standard, if sufficient quantity of lower standard water is available to meet that need. For example, potable water should not be used for irrigation purposes if nonpotable water of an adequate standard is available. Demand management in areas of shortage should incorporate plans to reuse water rather than discard it after a single use. Shortages should also be addressed by prioritizing water resource needs and balancing the allocation of needs between atmospheric water, surface water and groundwater.

Water conservation practices should be based on reasonable beneficial use rather than simply reduction of demand. The agricultural, industrial, residential, and public sectors can all institute changes that promote water conservation. For example, modified land use practices in agriculture, redesign of industrial or residential equipment or appliances, and proper design of water infrastructure facilities all can contribute to water conservation. Agricultural practices should also conform to water conservation.

Public education, regulatory controls, and user cost measures should be adopted to foster water conservation and reuse.

Desalinization
Technological processes to demineralize water containing salts, other minerals, or contaminants are currently available to address water shortages. However, many communities are unwilling to utilize this technology because of its high cost relative to other options available to them for obtaining potable water. We support continued research into and development of innovative technologies that would lower the cost of utilizing this water resource option.

Wet Weather Flows
We support governmental efforts to address the adverse impacts of wet weather flow conditions, including storm water management and the elimination of sanitary sewer overflows (SSOs) and combined storm and sanitary sewer overflows (CSOs). We recognize, however, that wet weather flows are only one of many sources of watershed impairment. Accordingly, requirements to eliminate or manage wet weather flow conditions should be adopted with full consideration also being given to the elimination or reduction of discharges from these other sources.

The national government should develop a minimum standard for SSO, CSO and storm water discharges and design a framework through which dischargers will be required to comply with the standard. Discharge standards should recognize the nature of the problem and the incompatibility with normal water discharge conditions. The national program should provide state, regional, and local governments with the flexibility to address wet weather corrections on a site-specific basis. Maximum flexibility in the use of technologies available should be provided. Compliance schedules should be reasonable and cost implications should be considered when imposing requirements.

Contaminated Runoff
More attention to curbing water quality impairment resulting from contaminated runoff is necessary if the nation is to meet its water quality goals. The contaminated runoff problem should be addressed at a watershed level because the causes of contaminated runoff are specific to each watershed.

Because both point and nonpoint sources contribute to water quality impairment, pollutant contributors from both sources should be responsible for water resource protection. Point and nonpoint sources should be allowed to "trade" pollution prevention and control credits as long as water quality goals for the receiving waters are met.

The national government should set minimum management requirements for a single nonpoint source program, but state and local governments should be given management responsibilities. The national guidelines should provide the states flexibility to design programs that address the pollution contributors in their jurisdictions.

Unlike point source discharges, nonpoint source contamination is far more difficult to track and regulate. Therefore, traditional regulatory approaches may be inadequate to solve water quality impairment. Public understanding of the causes of contaminated runoff and corresponding behavioral changes are essential. Accordingly, nonpoint source contributors should be first provided incentives to reduce contaminated runoff before punitive enforcement actions are taken. Technology-based corrections should also be implemented. This combination of technological controls, voluntary incentives, and compliance and enforcement measures should be incorporated into any nonpoint source management strategy.

Groundwater
We emphasize the need for coordination between all levels of government to protect the quality of groundwater resources and assure their recharge. The national government should coordinate research and public education on groundwater protection and provide broad policy guidelines. Groundwater resources should be managed on an aquifer basis, with state and local government participation. Groundwater management plans must be appropriate for each underground system, and, therefore, national laws should not be overly specific or inflexible.

Wetlands
The national government should develop a policy on wetlands protection that respects the need to protect these environmentally sensitive and valued lands and to develop land use practice compatible and appropriate with the value of the wetland, while balancing these needs with equally necessary economic and infrastructure development.

No Net Loss Goal—We endorse the goal of no net loss of the value of wetlands. We urge the linkage of this goal to a value-based classification system so that no net loss of wetlands of significant value is achieved.

Research Activities—We urge that greater resources be dedicated to scientific research into the ecological functions of wetlands. In addition, government should commit greater resources to scientific and technical inquiry as to the effectiveness of restoration and creation activities.

Identification of Wetlands—While we acknowledge the necessity of national government leadership in developing a broad national consensus for the identification of wetlands, we urge Congress and the federal agencies to delegate authority for adjusting and implementing the identification and delineation activities to the states. When doing so, the national government should permit each state the flexibility to include or exclude certain features as may be necessary for particular ecosystems and their associated values.

Inventory, Classification, and Indexing of Wetlands—We support a regulated system that includes the inventory, classification, and indexing of wetlands according to their functions and values.

Enhancement, Restoration, and Creation of Wetlands—Wetlands enhancement, restoration, and creation are technical solutions to wetlands losses that deserve further attention. We strongly encourage activities that provide technically sound solutions that compensate for adverse environmental impacts.

Compensation and Mitigation Banking—The classification of wetlands in the category of "highest value" in effect could constitute a "taking" for which just compensation should be made. As an alternative mitigation measure where less valued wetlands are proposed for development, payments could be made to a wetlands fund for their replacement with more valued wetlands in lieu of other mitigation measures.

Roles of Government—The national government should maintain responsibility for the development of a standard for the wetlands identification, inventory, classification, and indexing system, certification of state wetlands conservation and management plans, and the funding of research, education, and outreach activities. The state level of government should have primary responsibility for overall coordination of wetlands protection in the state, and should be required to develop a state wetlands management plan that meets the no net loss objectives. Also included among the state's responsibilities would be implementation and adjustment of the federally designed identification, inventory, classification, and indexing system, management of mitigation banks, and coordination of development activities that cross local boundaries. The regulation of wetlands protection and development should be administered at the local level of government through the development of wetlands conservation plans or the incorporation of such planning in already existing land use planning activities. Local units of government should have the primary responsibility for issuing wetlands land use permits.

Flood Control
We support flood control and storm water management practices and regulations to reduce the impacts that flooding has on people and the environment. Properly engineered improvements for flood control and storm water management practices must accommodate and be coordinated with long-term land use planning and property development. We support the construction of such improvements, with careful attention to other environmental impacts. The costs for construction for flood control and storm water improvements should be borne primarily by properties contributing to the condition and benefitting from the improvement. Federal funding should be reserved for those programs and projects involving widespread basin considerations and broadly diffused benefits and effects.

Navigable Waters
Projects that preserve the navigability of our nation's waters, such as channelization and harbor maintenance, should be supported by the national government only when there is a clear economic or national strategic interest. Projects should be developed with particular attention to the potential environmental impacts.

Hydropower
The harnessing of our nation's water resources for the purpose of energy supply is one component for achieving the national goal of energy independence. Hydropower is a renewable and "clean" energy resource. However, hydropower generation is not without its environmental or water resource impacts. Decisions regarding the utilization of our water resources for electricity generation must be made in a systems context where energy, commercial, and ecological needs are also considered.

Impact on Related Issues
The development of a water resources policy that protects the public health and ecological, agricultural, and commercial needs of the nation will undoubtedly affect a number of other policies, particularly environmental, energy, and economic. Protection of watersheds, the allocation of water rights, and elimination or reduction of sources of pollution will affect land use, agricultural practices, industry, and communities.

A water resources policy for the United States encompasses a large number of issues. This position statement addresses only those issues that we have reviewed from a professional society standpoint. We encourage the utilization of the expertise within the engineering, scientific, and water resource community to address the entirety of water resource issues.

Citations
America's Environmental Infrastructure: A Water and Wastewater Investment Study, Apogee Research, Inc., Washington, DC, 1990.