ous to Congress that the return on investment from an environmental, public, and political viewpoint would be great. The costs, though considerable, would be met with widespread public support. Beaches and fisheries could be improved. The public would see results—dramatic results, it was hoped—that would give this new public policy tangible value.

Finally, even though understanding of water pollution causes and effects was somewhat limited, it was time to get on with the task of improving the country's waters. Previous attempts by the federal government, beginning with the Federal Water Pollution Control Act of 1948 and the uneven and sometimes half-hearted attempts of the states to improve water quality in the 1950s and 1960s, had left a patchwork quilt of water quality problems. Directing massive amounts of federal, state, and local dollars to the problem, though arguably inefficient, would result in significant improvements in the most adversely impacted water bodies of the country. Thus Congress converted the high hopes of "fishable and swimmable"1 waters into a national mandate and a six-year plan.

Undercontrol and Overcontrol

As sensible as the strategy appeared in 1972, and as understandable as it looks today, its goals have not been universally achieved. For example, it appears that the act has led to frequent instances of undercontrol and overcontrol. Undercontrol occurs when mandated levels of treatment do not or are not expected to meet water quality goals. Although the act permits the Environmental Protection Agency to set more stringent standards in cases of undercontrol, solving these problems has proved far more daunting than the relatively simple task of implementing uniform technology-based regulations. In fact, significant portions of the coastal zone remain adversely affected and still short of being fishable and swimmable.

Available evidence suggests cases of overcontrol as well, but the Clean Water Act has no present cure for this problem. Overcontrol means that some part of mandated treatment is not considered justified by the resulting environmental improvement. This implies that spending some of the money elsewhere could produce a larger overall environmental improvement. Identification of overcontrol requires careful analysis of incremental ecosystem effects as well as value judgements on social, and economic effects, e.g., are the environmental quality improvements too small? are social goals still satisfied? is the cost too great? Ideally, these judgements should be


One of the goals declared by Congress is to achieve ". . .water quality which provides for the protection and propagation of fish, shellfish, and wildlife and provides for recreation in and on the water be achieved. . ." (Federal Water Pollution Control Act, as amended, Section 101[a][2]).

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