IMPLICATIONS OF C.A.R.E. VS. SOUTHVIEW FARM ON THE U.S. LIVESTOCK AND POULTRY INDUSTRY1

ABSTRACT: On May 19, 1993, a jury in the U.S. District Court for the Western District of New York found Southview Farm and Richard H. Popp guilty of violating the Clean Water Act on five occasions. The violations were the result of storm water runoff from a site used for disposal of dairy cattle manure from an unpermitted concentrated animal feeding operation. The presiding District Court judge later dismissed the jury verdict, and subsequently a U.S. Court of Appeals for the Second Circuit reversed the dismissal. The Court of Appeals concluded that the discharges were not exempt as agricultural storm water discharges, and that the manure spreaders involved were point sources. Because the use of animal manures in crop production activities will result, unavoidably, in the discharge of some pollutants to adjacent surface waters, a rational and universally applicable basis is needed to determine when such discharges are point versus nonpoint source. Current statutes and regulations do not delineate clearly such a boundary. To address this lack of specificity, I propose that application rates be based on recommended crop nutrient needs.     

USING STREAM BIOASSESSMENT PROTOCOLS TO MONITOR IMPACTS OF A CONFINED SWINE OPERATION1

ABSTRACT: The processing of waste from confined animal feeding operations (CAFOs) presents a major environmental challenge. Treatment of waste and subsequent land application is a common best management practice (BMP) for these operations in Kentucky, USA, but there are few data assessing the effect of runoff from such operations on aquatic communities. The authors sampled a stream bordering a CAFO with a land application program to determine if runoff from the fertilized fields was adversely affecting stream communities. Water chemistry, periphyton, and macroinvertebrate samples from riffle habitats downstream of the CAFO were compared to samples collected from an upstream site and a control stream in 1999 and 2000. Riffle communities downstream of the fertilized fields had higher chlorophyll a levels than other sites, but there were no significant differences in macroinvertebrate numbers or in biometrics such as taxa richness among the sites. The BMP in place at this site may be effective in reducing this CAFO's impact on the stream; however, similar assessments at other CAFO sites should be done to assess their impacts. Functional measures such as nutrient retention and litter decomposition of streams impacted by CAFOs should also be investigated to ensure that these operations are not adversely affecting stream communities.     

Long-Term Effects of Changing Land Use Practices on Surface Water Quality in a Coastal River and Lagoonal Estuary

The watershed of the Neuse River, a major tributary of the largest lagoonal estuary on the U.S. mainland, has sustained rapid growth of human and swine populations. This study integrated a decade of available land cover and water quality data to examine relationships between land use changes and surface water quality. Geographic Information Systems (GIS) analysis was used to characterize 26 subbasins throughout the watershed for changes in land use during 1992–2001, considering urban, agricultural (cropland, animal as pasture, and densities of confined animal feed operations [CAFOs]), forested, grassland, and wetland categories and numbers of wastewater treatment plants (WWTPs). GIS was also used together with longitudinal regression analysis to identify specific land use characteristics that influenced surface water quality. Total phosphorus concentrations were significantly higher during summer in subbasins with high densities of WWTPs and CAFOs. Nitrate was significantly higher during winter in subbasins with high numbers of WWTPs, and organic nitrogen was higher in subbasins with higher agricultural coverage, especially with high coverage of pastures fertilized with animal manure. Ammonium concentrations were elevated after high precipitation. Overall, wastewater discharges in the upper, increasingly urbanized Neuse basin and intensive swine agriculture in the lower basin have been the highest contributors of nitrogen and phosphorus to receiving surface waters. Although nonpoint sources have been emphasized in the eutrophication of rivers and estuaries such as the Neuse, point sources continue to be major nutrient contributors in watersheds sustaining increasing human population growth. The described correlation and regression analyses represent a rapid, reliable method to relate land use patterns to water quality, and they can be adapted to watersheds in any region.     

Contribution of Wastewater Treatment Plant Effluents to Nutrient Dynamics in Aquatic Systems: A Review

Excessive nutrient loading (considering nitrogen and phosphorus) is a major ongoing threat to water quality and here we review the impact of nutrient discharges from wastewater treatment plants (WWTPs) to United States (U.S.) freshwater systems. While urban and agricultural land uses are significant nonpoint nutrient contributors, effluent from point sources such as WWTPs can overwhelm receiving waters, effectively dominating hydrological characteristics and regulating instream nutrient processes. Population growth, increased wastewater volumes, and sustainability of critical water resources have all been key factors influencing the extent of wastewater treatment. Reducing nutrient concentrations in wastewater is an important aspect of water quality management because excessive nutrient concentrations often prevent water bodies from meeting designated uses. WWTPs employ numerous physical, chemical, and biological methods to improve effluent water quality but nutrient removal requires advanced treatment and infrastructure that may be economically prohibitive. Therefore, effluent nutrient concentrations vary depending on the particular processes used to treat influent wastewater. Increasingly stringent regulations regarding nutrient concentrations in discharged effluent, along with greater freshwater demand in populous areas, have led to the development of extensive water recycling programs within many U.S. regions. Reuse programs provide an opportunity to reduce or eliminate direct nutrient discharges to receiving waters while allowing for the beneficial use of reclaimed water. However, nutrients in reclaimed water can still be a concern for reuse applications, such as agricultural and landscape irrigation.     

Nutrient and Phytoplankton Analysis of a Mediterranean Coastal Area

Identifying and quantifying the key anthropogenic nutrient input sources are essential to adopting management measures that can target input for maximum effect in controlling the phytoplankton biomass. In this study, three systems characterized by distinctive main nutrient sources were sampled along a Mediterranean coast transect. These sources were groundwater discharge in the Ahuir area, the Serpis river discharge in the Venecia area, and a submarine wastewater outfall 1,900 m from the coast. The study area includes factors considered important in determining a coastal area as a sensitive area: it has significant nutrient sources, tourism is a major source of income in the region, and it includes an area of high water residence time (Venecia area) which is affected by the harbor facilities and by wastewater discharges. We found that in the Ahuir and the submarine wastewater outfall areas, the effects of freshwater inputs were reduced because of a greater water exchange with the oligotrophic Mediterranean waters. On the other hand, in the Venecia area, the highest levels of nutrient concentration and phytoplankton biomass were attributed to the greatest water residence time. In this enclosed area, harmful dinoflagellates were detected (Alexandrium sp. and Dinophysis caudata). If the planned enlargement of the Gandia Harbor proceeds, it may increase the vulnerability of this system and provide the proper conditions of confinement for the dinoflagellate blooms’ development. Management measures should first target phosphorus inputs as this is the most potential-limiting nutrient in the Venecia area and comes from a point source that is easier to control. Finally, we recommend that harbor environmental management plans include regular monitoring of water quality in adjacent waters to identify adverse phytoplankton community changes.     

THE MILWAUKEE POLLUTION CASE - IMPLICATIONS FOR WATER RESOURCES PLANNING1

ABSTRACT: The Illinois v. Milwaukee Federal District Court decision is the most far reaching application yet of the federal common law of nuisance to interstate water pollution conflicts. Although a Federal Appelate Court recently rescinded part of the district court decision, Milwaukee must still upgrade its metropolitan sewage system to a level beyond that required by federal and state regulations. The improvements must be completed with or without federal aid. The case points out the apparent inability of the Clean Water Act, the most comprehensive federal legislation affecting the nation's water quality, to deal with certain interstate water quality conflicts. The Milwaukee decision could set a precedent for similar settlements elsewhere which may in turn affect the U.S. Environmental Protection Agency's water quality clean up program. A more integrated, ecosystem conscious approach to management of shared water resources (e.g., the Great Lakes) would help reduce the need for court decisions like Illinois v. Milwaukee.     

The Role of Headwater Streams in Downstream Water Quality1

Abstract: Knowledge of headwater influences on the water‐quality and flow conditions of downstream waters is essential to water‐resource management at all governmental levels; this includes recent court decisions on the jurisdiction of the Federal Clean Water Act (CWA) over upland areas that contribute to larger downstream water bodies. We review current watershed research and use a water‐quality model to investigate headwater influences on downstream receiving waters. Our evaluations demonstrate the intrinsic connections of headwaters to landscape processes and downstream waters through their influence on the supply, transport, and fate of water and solutes in watersheds. Hydrological processes in headwater catchments control the recharge of subsurface water stores, flow paths, and residence times of water throughout landscapes. The dynamic coupling of hydrological and biogeochemical processes in upland streams further controls the chemical form, timing, and longitudinal distances of solute transport to downstream waters. We apply the spatially explicit, mass‐balance watershed model SPARROW to consider transport and transformations of water and nutrients throughout stream networks in the northeastern United States. We simulate fluxes of nitrogen, a primary nutrient that is a water‐quality concern for acidification of streams and lakes and eutrophication of coastal waters, and refine the model structure to include literature observations of nitrogen removal in streams and lakes. We quantify nitrogen transport from headwaters to downstream navigable waters, where headwaters are defined within the model as first‐order, perennial streams that include flow and nitrogen contributions from smaller, intermittent and ephemeral streams. We find that first‐order headwaters contribute approximately 70% of the mean‐annual water volume and 65% of the nitrogen flux in second‐order streams. Their contributions to mean water volume and nitrogen flux decline only marginally to about 55% and 40% in fourth‐ and higher‐order rivers that include navigable waters and their tributaries. These results underscore the profound influence that headwater areas have on shaping downstream water quantity and water quality. The results have relevance to water‐resource management and regulatory decisions and potentially broaden understanding of the spatial extent of Federal CWA jurisdiction in U.S. waters.     

Evaluating livestock system environmental performance with whole-farm nutrient balance

As a part of the USEPA's concentrated animal feeding operation (CAFO) final rule, all CAFOs are required to develop and implement a nutrient management plan (NMP). The USEPA's emphasis on better management of nutrients appropriately targets a critical environmental issue associated with animal production. The concentration of animals in livestock feeding operations, often separate from feed grain production, requires importing of substantial quantities of feed nutrients. Due to the inefficiencies of nutrient utilization in livestock production, quantities of nitrogen (N) and phosphorus (P) in manure greater than can be utilized in local crop production often result. With the focus of the USEPA's NMP rules on internal farm manure management planning, nutrient concentrations resulting from animal concentration may not be adequately addressed by compliance with the USEPA rules alone. A review of two mandatory and two voluntary nutrient management strategies is made by comparing whole-farm nutrient balance for a case-study beef cattle feedlot. The results suggest that voluntary BMPs, such as modification to animal feeding program and exporting of manure, can have greater environmental benefits (30-60% reduction in P accumulation for case-study farm) than mandatory NMPs and buffers (5-7% reduction in P accumulation for case-study farm) for a typical beef cattle feedlot. Whole-farm nutrient balance procedures can also be valuable for reviewing the nutrient performance of livestock systems.     

SEWAGE DISCHARGES FROM SHIPS TRANSITING COASTAL SALT WATERS1

ABSTRACT: A number of aspects of the discharging of non-oily wastewaters by transiting ships are treated in this overview paper. In the introduction, options to discharging (the use of holding tank, on board treatment) and the impact of changing regulations are discussed. Assessment of the effects of sewage discharges on coastal waters required that data, at first not available, be generated. An account is given of the characterization of Navy shipboard wastewaters and of experiments involving sewage discharges at sea, measurements of water quality before, during and after an amphibious operation, and fore and aft of transitting Navy ships. A better understanding of sewage dilution after discharge led to the verification of a method for controlled discharging of sewage (and other wastewaters). This method permits limiting the coliform bacteria count in the ship's wake to values below acceptable limits. The final sections contain information on long range effects of ships’sewage discharges, obtained in studies by the U.S. Navy and others, as well as public health considerations.     

INDUSTRY COMPLIANCE WITH STORM WATER POLLUTION PREVENTION REGULATIONS: THE CASE OF TRANSPORTATION INDUSTRY FACILITIES IN CALIFORNIA AND THE LOS ANGELES REGION1

ABSTRACT: Pollutants in urban storm water runoff, a significant and increasing fraction of pollutants in some waters of the U.S., originate from multiple activities. The industrial sector, one source category, is subject to federal and state-level storm water pollution prevention regulations, primarily General NPDES Permits that rely heavily on facility operators to identify themselves and develop appropriate site-specific pollutant controls. Degree of compliance is not readily determined and enforcement is inhibited because no publicly-available inventories contain data necessary to comprehensively identify facilities required to comply. This research evaluates the first stage of compliance, facility self-identification, concentrating on the motor-vehicle, transportation industry category using data at three scales: statewide, regional, and local or watershed. Data for California statewide and for the Los Angeles region show about 8 percent to 15 percent of motor-vehicle transportation facilities have complied with first-stage requirements. However, facility-specific evaluation in one Los Angeles County watershed suggests less than 50 percent of facilities in the industry conduct industrial activities of the kind covered by regulations; others need not comply. Results show strong variation by industry category. Second-stage compliance, follow-up reporting, is also evaluated for the Los Angeles region. About 17 percent to 34 percent of facilities completing first-stage requirements have also completed second-stage requirements.     

Stream Discharge and Riparian Land Use Influence In-Stream Concentrations and Loads of Phosphorus from Central Plains Watersheds

Total annual nutrient loads are a function of both watershed characteristics and the magnitude of nutrient mobilizing events. We investigated linkages among land cover, discharge and total phosphorus (TP) concentrations, and loads in 25 Kansas streams. Stream monitoring locations were selected from the Kansas Department of Health and Environment stream chemistry long-term monitoring network sites at or near U.S. Geological Survey stream gauges. We linked each sample with concurrent discharge data to improve our ability to estimate TP concentrations and loads across the full range of possible flow conditions. Median TP concentration was strongly linked (R ² = 76%) to the presence of cropland in the riparian zones of the mostly perennial streams. At baseflow, discharge data did not improve prediction of TP, but at high flows discharge was strongly linked to concentration (a threshold response occurred). Our data suggest that on average 88% of the total load occurred during the 10% of the time with the greatest discharge. Modeled reductions in peak discharges, representing increased hydrologic retention, predicted greater decreases in total annual loads than reductions of ambient concentrations because high discharge and elevated phosphorus concentrations had multiplicative effects. No measure of land use provided significant predictive power for concentrations when discharge was elevated or for concentration rise rates under increasing discharge. These results suggest that reductions of baseflow concentrations of TP in streams without wastewater dischargers may be managed by reductions of cropland uses in the riparian corridor. Additional measures may be needed to manage TP annual loads, due to the large percentage of the TP load occurring during a few high-flow events each year.     

NUTRIENT LOADING ASSESSMENT IN THE ILLINOIS RIVER USING A SYNTHETIC APPROACH1

ABSTRACT: A synthetic relationship is developed between nutrient concentrations and discharge rates at two river gauging sites in the Illinois River Basin. Analysis is performed on data collected by the U.S. Geological Survey (USGS) on nutrients in 1990 through 1997 and 1999 and on discharge rates in 1988 through 1997 and 1999. The Illinois River Basin is in western Arkansas and northeastern Oklahoma and is designated as an Oklahoma Scenic River. Consistently high nutrient concentrations in the river and receiving water bodies conflict with recreational water use, leading to intense stakeholder debate on how best to manage water quality. Results show that the majority of annual phosphorus (P) loading is transported by direct runoff, with high concentrations transported by high discharge rates and low concentrations by low discharge rates. A synthetic relationship is derived and used to generate daily phosphorus concentrations, laying the foundation for analysis of annual loading and evaluation of alternative management practices. Total nitrogen (N) concentration does not have as clear a relationship with discharge. Using a simple regression relationship, annual P loadings are estimated as having a root mean squared error (RMSE) of 39.8 t/yr and 31.9 t/yr and mean absolute percentage errors of 19 percent and 28 percent at Watts and Tahlequah, respectively. P is the limiting nutrient over the full range of discharges. Given that the majority of P is derived from Arkansas, management practices that control P would have the most benefit if applied on the Arkansas side of the border.     

Hydrological Connectivity Between Headwater Streams and Downstream Waters: How Science Can Inform Policy1

Abstract: In January 2001, the U.S. Supreme Court ruled that the U.S. Army Corps of Engineers exceeded its statutory authority by asserting Clean Water Act (CWA) jurisdiction over non‐navigable, isolated, intrastate waters based solely on their use by migratory birds. The Supreme Court’s majority opinion addressed broader issues of CWA jurisdiction by implying that the CWA intended some “connection” to navigability and that isolated waters need a “significant nexus” to navigable waters to be jurisdictional. Subsequent to this decision (SWANCC), there have been many lawsuits challenging CWA jurisdiction, many of which are focused on headwater, intermittent, and ephemeral streams. To inform the legal and policy debate surrounding this issue, we present information on the geographic distribution of headwater streams and intermittent and ephemeral streams throughout the U.S., summarize major findings from the scientific literature in considering hydrological connectivity between headwater streams and downstream waters, and relate the scientific information presented to policy issues surrounding the scope of waters protected under the CWA. Headwater streams comprise approximately 53% (2,900,000 km) of the total stream length in the U.S., excluding Alaska, and intermittent and ephemeral streams comprise approximately 59% (3,200,000 km) of the total stream length and approximately 50% (1,460,000 km) of the headwater stream length in the U.S., excluding Alaska. Hillslopes, headwater streams, and downstream waters are best described as individual elements of integrated hydrological systems. Hydrological connectivity allows for the exchange of mass, momentum, energy, and organisms longitudinally, laterally, vertically, and temporally between headwater streams and downstream waters. Via hydrological connectivity, headwater, intermittent and ephemeral streams cumulatively contribute to the functional integrity of downstream waters; hydrologically and ecologically, they are a part of the tributary system. As this debate continues, scientific input from multiple fields will be important for policymaking at the federal, state, and local levels and to inform water resource management regardless of the level at which those decisions are being made. Strengthening the interface between science, policy, and public participation is critical if we are going to achieve effective water resource management.     

Project XL: cheaper,cleaner, and smarter ways to protect the environment

Are you interested in making the job of complying with federal environmental requirements cheaper and smarter for your business? The U.S. Environmental Protection Agency is committed to helping business and other sectors make more sense of environmental requirements through a number of innovative programs, one of the most far‐reaching being Project XL. © 2000 John Wiley & Sons, Inc.     

A Nationally Consistent NHDPlus Framework for Identifying Interstate Waters: Implications for Integrated Assessments and Interjurisdictional TMDLs

The US Environmental Protection Agency’s (EPA’s) Total Maximum Daily Loads (TMDL) program promotes nationally consistent approaches for documenting the progress in restoring impaired waters. EPA’s TMDL program provides tracking systems comprising both database and geographic information systems (GIS) mapping components. The GIS mapping is implemented using the National Hydrography Dataset (NHD). The EPA and the US Geological Survey have developed an enhanced NHD product (NHDPlus) that is applied in this study to define an interstate waters framework for the conterminous United States. This NHDPlus-based framework provides an efficient watershed-oriented approach for selecting interstate waters. Greater consistency in approaches for interstate waters is essential for providing improved techniques for integrated assessment and management programs. Improved analysis tools for interstate waters are clearly important from a federal perspective. Insights based on tools for federal interstate waters are also of interest for state water quality agencies when they deal with complicated interjurisdictional challenges that can require leveraging support from a wide range of stakeholders. Summaries are provided on the degree of consistency documented for inland waters where states have provided TMDL listing GIS information for shared interstate NHD reaches, and summaries are provided on the patterns for interstate assessments organized according to the ecoregions developed for EPA’s Wadeable Streams Assessment. The relevance of this interstate waters framework in leveraging the TMDL program to provide enhanced support for watershed oriented management approaches is also explored.     

A Case Study of Form-Based Solutions for Watershed Protection

Despite an array of policies at the federal and state level aimed at regulating stormwater discharges, engineered solutions enforced by local governments often fall short of meeting water quality standards. Although the implications of land use planning and development regulations are important for stormwater management, they are often overlooked as critical initial steps to improving water quality. This study explores the role of ‘form-based’ regulations as tools for achieving urban planning and water quality objectives. Form-based codes are a new generation of development codes aimed at regulating urban development based on urban form and density, rather than land use. We present an exploratory case study of the feasibility of form-based codes in the Jordan Lake Watershed in North Carolina, a rapidly growing region where fragmented local governments face stringent nutrient reduction standards under new state regulations. Through program analysis and interviews, we explore the viability of form-based codes for reducing development impacts on Jordan Lake’s water quality. We consider the legal feasibility of code enforcement, regional and local barriers and opportunities, and implementation given existing regulatory frameworks. Our findings suggest that high quality information and data modeling are foundational to gaining support for a consensus agreement on the sources and degree of water quality impairment. Furthermore, implementing form-based solutions for water quality is greatly aided by (1) experienced regional planning bodies that have regulatory authority, and (2) local governments whose staff are experienced in implementing complex development ordinances, reviewing architectural renderings, and communicating development requirements with the public and developers.     

A CRITIQUE OF WATERSHED MANAGEMENT EFFORTS IN THE LOWER MISSISSIPPI ALLUVIAL PLAIN1

ABSTRACT: Integrated watershed management in the Lower Mississippi Alluvial Plain (Delta) requires blending federal, state, and local authority. The federal government has preeminent authority over interstate navigable waters. Conversely, state and local governments have authority vital for comprehensive watershed management. In the Delta, integrating three broad legal and administrative regimes: (1) flood control, (2) agricultural watershed management, and (3) natural resources and environmental management, is vital for comprehensive intrastate watershed, and interstate river basin management. Federal Mississippi River flood control projects incorporated previous state and local efforts. Similarly, federal agricultural programs in the River's tributary headwaters adopted watershed management and were integrated into flood control efforts. These legal and administrative regimes implement national policy largely in cooperation with and through technical and financial assistance to local agencies such as levee commissions and soil and water conservation districts. This administrative infrastructure could address new national concerns such as nonpoint source pollution which require a watershed scale management approach. However, the natural resources and environmental management regime lacks a local administrative infrastructure. Many governmental and non governmental coordinating organizations have recently formed to address this shortcoming in the Delta. With federal and state leadership and support, these organizations could provide mechanisms to better integrate natural resources and environmental issues into the Delta's existing local administrative infrastructure.     

EFFICIENCY PROBLEMS FROM USER FEES IN MUNICIPAL WASTEWATER TREATMENT1

ABSTRACT: The Environmental Protection Agency administers a construction grant program to encourage abatement of wastewater pollution by sharing with municipalities the costs of wastewater treatment facilities. The enabling legislation (P.L. 92–500) specifies that EPA's cost share will be 75% of construction costs. It further requires municipalities to collect user fees from industrial users of the facilities to repay that part of the federal grant allocable to the treatment of industrial wastewater. The municipality must return half of the user fees collected to the U.S. Treasury; the municipality is allowed to retain the remaining half. Retention by municipalities of these user fees lowers their effective cost shares and results in the following consequences: (1) a bias for municipalities to select certain kinds of abatement techniques regardless of whether or not they are the least-cost techniques from the national perspective; (2) a bias for municipalities to select larger-than-optimal scales of abatement facilities; (3) a hidden federal subsidy to industry; and (4) grants that favor industrial communities. This article examines the legislative and regulatory requirements for user charges, derives the algebraic expressions for calculating the real federal, municipal, and industrial cost shares with user fees; computes municipal cost shares for selected values of the determinant factors; evaluates efficiency and other consequences of current user fee arrangements; and concludes that the efficiency distortions brought about by the impacts of user fees on cost sharing could be eliminated by requiring that all user fees collected from industry against the federal cost share be returned to the U.S. Treasury.     

Regulating Industrial Stormwater: State Permits,Municipal Implementation,and a Protocol for Prioritization1

Abstract:  This research evaluated the effectiveness of regulations for stormwater pollutants originating from industrial facilities. Industrial facilities discharging stormwater are subject to General Permits implemented by state and federal agencies, which require facility operators to identify themselves and to implement pollution prevention measures. An overlying system of permits require Municipal Separate Storm Sewer System operators to identify and inspect facilities in their jurisdictions capable of discharging substantial pollutant loads into stormwater conveyances, introducing more active regulation and strategic prioritization, but with unequal implementation in different urban regions. This research evaluated the interaction between the regulations and ways in which the regulations succeed, or fail, at protecting water quality. The research evaluated potential for pollutant discharges at 136 industrial facilities in Pinellas County, Florida, using telephone interviews; off-site facility visits; and on-site facility inspections, targeting four industrial categories: wood products; stone, clay, glass, and concrete products; fabricated metal products; and electronic products. Results documented that a large proportion of facilities subject to General Permits conduct few or no activities likely to produce stormwater pollutants, indicating that the regulations’ equal treatment of all facilities may constitute overregulation. The research developed a methodology to assess facilities using intensity of industrial activities exposed to stormwater, a rational measurement that could regularize municipal agencies’ requirements and prioritize implementation toward facilities with the potential to impact receiving water quality.     

Public Participation in Natural Hazard Mitigation Policy Formation: Challenges for Comprehensive Planning

Democratic theory holds that active participation in governmental planning and decision making is critical to furthering the public interest. As a result, public participation in urban planning in the US is arguably the most extensive and intensive in the world. Required by federal, state and local laws, citizen involvement is a staple of local plan making. However, as this paper shows, citizen interest in participating in the formulation of hazard mitigation policies in comprehensive plans is low, despite mounting evidence of perils to life and property from floods, hurricanes and earthquakes. Using evidence from case studies in Florida and Washington, the causes of disinterest are dissected and ways to increase public input to hazard mitigation policies in local comprehensive plans are recommended.