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July 30, 2010 - ASCE Comments - to the EPA on its draft Strategic Plan for Fiscal Year 2001-2015

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The U.S. Environmental Protection Agency
Draft FY 2011-2015 EPA Strategic Plan
75 Fed. Reg. 34736 (Jun. 18, 2010)

July 30, 2010 


The American Society of Civil Engineers (ASCE) is pleased to provide these comments to the Environmental Protection Agency (EPA) on its draft Strategic Plan for Fiscal Years 2011-2015. The draft plan touches upon a
number of important environmental programs related to the Society’s mission to protect the public health, safety and welfare through the application of the highest engineering standards.

The Agency’s draft Strategic Plan maps out Agency priorities over the next five years and contains five strategic goals to protect human health and the environment. The five goals are to take action on climate change and
improve air quality; protect the nation’s waters; accelerate the Superfund cleanup program for hazardous-waste sites; prevent pollution by ensuring the sage management of chemicals; and enforce environmental laws.


ASCE wishes to comment in some detail on three of the five goals that are within the unique expertise of civil engineers.

Goal 1: Taking Action on Climate Change and Improving Air Quality

Reduce greenhouse gas emissions and develop adaptation strategies to address climate change and protect and improve air quality.

ASCE concurs. We support public and private sector strategies and efforts to achieve significant reductions in greenhouse gas emissions. These are:

• Establishing a comprehensive, long-term infrastructure development and maintenance plan at federal, state and local levels. This plan must support sustainable development through a substantial reduction of greenhouse gas emissions and timely adaptation to the effects of climate change, while maintaining and/or enhancing environmental quality.

• Establishing clear and reasonable targets and schedules for the reduction of greenhouse gas emissions.

• Improving the energy efficiency of, and the reduction of greenhouse gas emissions from, infrastructure systems over their entire life cycles by making cost-effective use of existing technologies. These improvements should cover all sectors, and include both stationary and mobile sources.

• Encouraging the use of non-greenhouse gas emitting energygenerating sources such as nuclear, hydropower, wind and solar.

• Researching and implementing new technologies and materials to further improve energy efficiency and reduce greenhouse gas emissions.

• Incorporating additional incentives for the short term development and implementation of high efficiency and low or zero greenhouse gas emitting technologies and cost-effective carbon capture and storage.

• Stimulating private investment in greenhouse gas reducing technologies by establishing a market value for greenhouse gas emissions over the long term.

• Authorizing the allocation, under existing federal infrastructure programs, of revenue from greenhouse gas emissions credits for infrastructure projects that will reduce greenhouse gas emissions. Examples of such projects include new public transportation systems; projects to reduce major chokepoints that cause transportation congestion; and improved intercity rail transportation.

• Including credit for early action to reduce greenhouse gas emissions.

• Encouraging actions by other countries to reduce their greenhouse gas emissions.

• Exploring the utilization of forests and the ocean as carbon sinks or other mitigation technologies.

By the end of this century, if current trends continue, atmospheric greenhouse gas concentrations could be twice what they were at the beginning of the industrial revolution. The expected results will be increases in the severity of storms, floods and droughts, all of which will have substantial effects on our infrastructure, economy and quality of life.

ASCE’s members are central to the planning, design, construction, operation, maintenance, and renewal of infrastructure systems that facilitate economic development and protect human health and welfare and the environment. Improvements in the durability and resiliency of our infrastructure systems will make them less vulnerable to effects of climate disruption. Improvements in the design and construction of our infrastructure systems can also increase their functionality and safety, and reduce greenhouse gas emissions during their construction and use.

Goal 2: Protecting America’s Waters

Protect and restore our waters to ensure that drinking water is safe, and that aquatic ecosystems sustain fish, plants, and wildlife, and economic, recreational, and subsistence activities.

This remains one of the nation’s most daunting environmental challenges.

Since 1972, Congress has directly invested approximately $80 billion in the construction of publicly owned treatment works and their related facilities. State and local governments have spent billions more over the years. Total nonfederal spending on sewer and water between 1991 and 2005 was $841 billion. Nevertheless, the physical condition of many of the nation's 16,000 wastewater treatment systems is declining due to a lack of investment in plants, equipment, and other capital improvements over the years.

In 2008, EPA reported that the total investment needs of America's publicly owned treatment works as of January 1, 2004, were $202.5 billion. This reflects an increase of $16.1 billion (8.6 percent) since the previous analysis was published in January 2004.

The nation’s drinking-water systems face staggering public investment needs over the next 20 years. Although America spends billions on infrastructure each year, drinking water systems face an annual shortfall of at least $11 billion in funding needed to replace aging facilities that are near the end of their useful life and to comply with existing and future federal water regulations. The shortfall does not account for any growth in the demand for drinking water over the next 20 years.

ASCE believes that federal policymakers need to adopt a number of approaches to solving the water infrastructure crisis. We support legislative efforts to:

• Increase funding for water infrastructure system improvements and associated operations through a comprehensive program.

• Create a Water Infrastructure Trust Fund to finance the national shortfall in funding of infrastructure systems under the Clean Water Act and the Safe Drinking Water Act, including stormwater management and other projects designed to improve the nation's water quality.

• Retain traditional financing mechanisms, such as appropriations from general treasury funds, issuance of revenue bonds and tax exempt financing at state and local levels, public-private partnerships, state infrastructure banks, and user fees on certain consumer products.

• Expand innovative financing mechanisms, including broad-based environmental restoration taxes.

The case for increased federal investment is compelling. Needs are large and unprecedented; in many locations, local sources cannot be expected to meet this challenge alone and, because waters are shared across local and state boundaries, the benefits of federal help will accrue to the entire nation.

Goal 3: Cleaning Up Our Communities

Promote sustainable, healthier communities and protect vulnerable populations and disproportionately impacted low income, minority, and tribal communities. Prevent releases of harmful substances and clean up and restore contaminated areas.

Between 1981 and mid-2010, the Agency completed cleanups at 1,084 hazardous-waste sites officially added to the National Priorities List (NPL), which represents the worst waste sites nationally. The NPL, however, still contains more than 1,200 sites that await final cleanup.

While the number of sites remains relatively constant, federal funding during the 1990s systematically decreased. Until the mid-1990s, the trust fund received approximately $1.5 billion per year; the legislative authority to
collect the taxes expired on December 31, 1995. While there has been some interest in reinstating the taxes, there has been little legislative action. Superfund cleanup is currently funded through the ongoing appropriations process.

Meanwhile, the Agency’s 2004 report Cleaning up the Nation’s Wastes Sites estimated that as many as 350,000 contaminated sites will require cleanup during the next 25 years. Assuming that current regulations and
practices remain the same, it could cost as much as $250 billion to clean up those sites. No updated data have been released, but current cleanup costs could be much higher when inflation is taken into account.

ASCE applauds the Administration’s recent recommendation of legislation to reinstate the Superfund taxes on petrochemicals and major corporations to revitalize the cleanup program. We support enactment of H.R. 564, the Superfund Investment Act, which would amend the Internal Revenue Code by reinstating until January 1, 2018, the Hazardous Substance Superfund financing rate and the corporate environmental income tax.

In the interim, the Agency’s strategic plan should outline steps the EPA intends to take to:

• Push Congress to reauthorize federal Superfund taxes on chemicals, petroleum, and corporations or create another federal funding mechanism to revive the Hazardous Substance Superfund cleanup program and remove the cost of cleanup from the general fund.

• Urge the president to support and implement legislation—incentive programs, for example—that considers environmental costs and encourages the reduction of hazardous waste at the source and the design of reuse programs.

• Continue to fund existing federal programs to finance the revitalization of America’s brownfields.

• Create a Brownfields Redevelopment Action Grant program within the Agency to provide investment funds for local governments that would allow private investments to be leveraged in order to help preserve farmland and open spaces.

EPA supports urban, suburban, and rural community goals of improving environmental, human health, and quality-of-life outcomes through partnerships that also promote economic opportunities, energy efficiency, and revitalized neighborhoods. EPA’s smart growth program accomplishes these outcomes by working with communities, other federal agencies, states, and national experts to develop and encourage development strategies that have better outcomes for air quality, water quality, and land preservation and revitalization.

ASCE defines sustainability as a set of economic, environmental and social conditions in which all of society has the capacity and opportunity to maintain and improve its quality of life indefinitely, without degrading the
quantity, quality or the availability of natural resources and ecosystems.

Moreover, sustainable development is the process of converting natural resources into products and services that are more profitable, productive, and useful, while maintaining or enhancing the quantity, quality, availability and productivity of the remaining natural resource base and the ecological systems on which they depend.

The civil engineering profession recognizes the reality of limited natural resources, the desire for sustainable practices (including life-cycle analysis and sustainable design techniques), and the need for social equity in the consumption of resources. To achieve these objectives, ASCE supports the following implementation strategies:

• Promote broad understanding of economic, environmental, political, social, and technical issues and processes as related to sustainable development;

• Advance the skills, knowledge and information necessary for a sustainable future; including habitats, natural systems, system flows, and the effects of all phases of the life cycle of projects on the ecosystem;

• Advocate economic approaches that recognize natural resources and our environment as capital assets;

• Promote multidisciplinary, whole system, integrated and multiobjective goals in all phases of project planning, design, construction, operations, and decommissioning;

• Promote reduction of vulnerability to natural, accidental, and willful hazards to be part of sustainable development; and

• Promote performance based standards and guidelines as bases for voluntary actions and for regulations in sustainable development for new and existing infrastructure.

ASCE recognizes the leadership role of engineers in sustainable development, and their responsibility to provide effective and innovative solutions in addressing the challenges of sustainability. The ASCE Code of Ethics requires civil engineers to strive to comply with the principles of sustainable development in the performance of their professional duties. ASCE will work on a global scale to promote public recognition and
understanding of the needs and opportunities for sustainable development.

Environmental, economic, social and technological development must be seen as interdependent and complementary concepts, where economic competitiveness and ecological sustainability are complementary aspects of the common goal of improving the quality of life.

Engineers have a leading role in planning, designing, building and ensuring a sustainable future. Engineers provide the bridge between science and society. In this role, engineers must actively promote and participate in
multidisciplinary teams with other professionals, such as ecologists, economists, and sociologists to effectively address the issues and challenges of sustainable development.

Respectfully submitted,