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Wastewater Planning


Section 208

Pima Association of Governments is the Designated Planning Agency (DPA) under Section 208 of the federal Clean Water Act and, as such, is responsible for regional water quality planning throughout Pima County, excluding tribal lands.

PAG maintains and updates the Areawide Water Quality Management Plan (208 Plan) for the region. Under state and federal regulations, all new or significantly changed wastewater treatment facilities must gain consistency with the 208 Plan before permits may be issued. PAG’s 208 amendment process is outlined in the 208 Plan, which was approved by the Regional Council in March 2006. If a facility is not consistent with the plan, an amendment must be approved before the facility can be permitted by the Arizona Department of Environmental Quality (ADEQ).

PAG conducts regional wastewater planning in coordination with the region’s three Designated Management Agencies (DMA) are responsible for ensuring that wastewater service is provided in their management areas.

Page index

PAG DPA 208 Process Resources

PAG 208 Plan Update 2019

PAG is required to update the Areawide Water Quality Management Plan every five years or as needed to fulfill mandatory designated watershed planning responsibilities. The most recent plan was created in 2006. Since that time changes have included amendments to the plan for new wastewater facilities and new designated management areas. PAG will update, streamline and modernize the 208 Plan.


The Draft 208 Plan documents and instructions for providing feedback are located on the Watershed Planning Subcommittee page.

Interested parties may contact Mead Mier, Lead Watershed Planner, at, to join an advisory team.  

The guiding principles of the update are to:

  • Develop procedures for streamlining the PAG 208 Plan Amendment process.
  • Verify and update obsolete information in the PAG 2006 AWQMP including new 208 Plan Amendment information.
  • Save PAG, DMAs and private stakeholders time by easing navigation and increasing efficiency through the 208 Plan amendment process.
  • Make clear the value of a regional planning process and municipal coordination which has steps to ensure stakeholder agreements are in place, reducing surprises or conflicts later.​

Participation Timeline

The designated management agencies of the Town of Marana, Town of Sahuarita and Pima County assisted PAG in reviewing the scope of work. Westland Resources is on contract, approved by Regional Council on Feb. 23, 2017, to assist with the update. The effort is anticipated to span through 2019 with a planning, engagement, review and approval process.

Updates will be posted and provided to WPS & EPAC.

  • Documents for EPAC 03-01-2019
  • Brownfields and groundwater quality presentations will be posted here 

PAG is working with ADEQ and the other Designated Planning Agencies (DPA) in  the state for recommendations and lessons learned from their Plan updates.

Local DMA Resources

Pima County
Pima County Regional Wastewater Reclamation Department designs, manages and maintains the sanitary sewer system in Pima County, including the conveyance system and treatment system. The Treatment Division operates and maintains the treatment facilities that receive, treat, and dispose of over 62 million gallons per day (MGD) of sanitary sewage. Two major facilities handle sewage from the metropolitan Tucson area, and seven facilities serve remote areas scattered throughout several areas of eastern Pima County.

In 2009, Pima County gained approval for a 208 amendment to ensure that it can meet near-term future effluent water quality standards as established by ADEQ. As of Jan. 8, 2014, the last flows to the Roger Road wastewater reclamation facility (WRF) were diverted from the old plant to the new facility, Agua Nueva WRF. Since December 16, 2013, the Pima County Regional Wastewater Reclamation Department (RWRD) has been diverting flows from the Roger Road WRF to the Agua Nueva Water Reclamation Facility (WRF). The Agua Nueva WRF is a new state-of-the-art water reclamation facility that will allow Pima County to meet new strict environmental standards for effluent discharges into the Santa Cruz River. The Tres Rios WRF has a current capacity of 25 MGD. Work to increase the facility's capacity to 37.5 MGD is underway; construction began in January 1998. The total two-plant capacity of 82 MGD serves the county’s municipal treatment needs through the 2030 planning horizon.

Town of Sahuarita
The Town of Sahuarita became a Designated Management Agency in 1999. The DMA was revised in consultation with PAG, the Town and Pima County with the March 2006 208 Plan.  Because some areas near Sahuarita could be served in the future by either the Town or Pima County, the March 2006 208 Plan designated Joint Planning Areas around the Town’s DMA. These areas are not officially assigned to either DMA at this time. Instead, Pima County and the Town of Sahuarita will work together to decide who will serve these areas when the need for service arises.

The Town currently operates the Sahuarita Water Reclamation Facility.  In February 2014, ADEQ issued a significant amendment to the aquifer protection permit authorizing the Town to operate the facility at a maximum monthly flow of 3.0 mgd upon completion of phased improvements.  The current physical capacity of the facility is 1.50 mgd.

Planning for wastewater service in other areas within the Sahuarita DMA is ongoing.

Town of Marana
In 2014, the Town of Marana became a Designated Management Agency and now provides wastewater service in the boundary area agreed upon by Pima County and the Town of Marana.  On April 25, 2013, PAG's Regional Council directed PAG convene the Scope of Work Task Force.   The PAG Regional Council approved the amendment to PAG’s Water Quality Management Plan on September 25, 2013, and the Statewide Water Quality Management Working Group forwarded a positive recommendation to ADEQ on Oct. 8, 2013.  The final certification letter from ADEQ was signed on March 27, 2014.

The Marana Water Reclamation division provides design, management, and operations and maintenance of the North Marana sanitary sewer system. This includes the conveyance and treatment systems for over 48 miles of sewer, and two water reclamation facilities. Marana assumed management of the wastewater system in the northern part of the town in January of 2012, acquiring the plant and its collection lines from Pima County in April of 2013. The town paid Pima County for the facility northwest of Luckett and Marana roads. The 208 Amendment enabled the Town to become a Designated Management Agency (DMA) and to provide wastewater service in the areas tributary to the Lucket Road and Rillito Vista Water Reclamation Facilities.   

208 Plan Frequently Asked Questions

What Do The Laws and Regulations Say About 208 Planning?


Arizona Administrative Code

Why is PAG Responsible for 208 Planning?

PAG was designated as the regional water quality planning agency for all of Pima County (excluding tribal lands) in 1974 by the Governor of Arizona. As a result, PAG is responsible for administering the 208 Plan in Pima County, ensuring that a regional approach is taken to wastewater planning. Pima County was as the first wastewater management agency in the PAG region designated as a Designated Management Agencies.

PAG works closely with the three Designated Management Agencies and the Arizona Department of Environmental Quality to ensure implementation of the 208 Plan.

Why is 208 Planning Necessary?

Areawide wastewater treatment management plans, otherwise known as "208 Plans," are required by Section 208 of the Clean Water Act. In addition, Section 208 states that no National Pollution Discharge Elimination System (NPDES) permits shall be issued for any point source of pollution which is in conflict with a 208 Plan. In Arizona, ADEQ will not issue an AZPDES permit, which is the state equivalent for the national permit or an aquifer protection permit. Also, the Arizona Department of Environmental Quality will not issue an approval to construct treatment facilities that are not consistent with a 208 Plan.
The goal of 208 Planning is to coordinate the efforts of all the water management agencies as they relate to waste treatment planning. By coordinating efforts, duplication is minimized, consensus is built, and communication is enhanced. All parties are provided with the opportunity to be involved in the planning affecting their operation. The process also helps ensure that adequate public input occurs.

PAG’s 208 Plan emphasizes the regionalization of wastewater treatment, and discourages the proliferation of small, privately owned treatment facilities because of potential accessibility issues if adjacent privately owned properties become land-locked. Long-term reliability of small facilities and potential impacts to water quality further lend support to the concept of regionalization of wastewater treatment.

What is a 208 Plan Amendment?
A 208 Plan Amendment is any approved change to the Areawide Water Quality Management Plan. Areawide Water Quality Management Plans are required under Section 208 of the Clean Water Act.

In the PAG region, most 208 Plan Amendments since 1990 have related to proposals to construct wastewater treatment facilities that were not included in the original 208 Plan adopted in 1978. Many 208 Plan Amendments adopted in the 1980s addressed policy changes, pollution source assessments, groundwater quality investigations, and long-range plans for meeting regional wastewater treatment needs.

A 208 Plan Amendment is generally in the form of a detailed document that contains a variety of information that is required by the Arizona Department of Environmental Quality in order to approve a 208 Plan Amendment.

What Is the Process for Amending PAG’s 208 Plan?

The approved process for amending PAG’s 208 Plan is presented below. The planning process includes participation from local jurisdictions, the business community, environmental groups, public interest groups and the general public. In the case of proposals for private wastewater treatment facilities, the party requesting the amendment must first contact Pima County Wastewater Management Department or the Town of Sahuarita depending on the facility location, because they are the designated management agencies in Pima County (excluding tribal lands). Pima County or the Town of Sahuarita must first decline to serve the area in question in order for a 208 Plan Amendment for a private facility to proceed.

PAG will charge a processing fee for each 208 Plan Amendment in order to recover the process administration costs. The 208 Plan Amendment process is as follows:

1. The party requesting a change to the 208 Plan contacts the jurisdiction where the facility will be located and requests jurisdictional sponsorship of the project. Sponsorship does not mean support; it only indicates a willingness to investigate the possibility of such a project. Jurisdictions in Pima County include Tucson, South Tucson, Marana, Oro Valley, Sahuarita, and Pima County.

2. The jurisdiction contacts PAG to initiate the 208 planning process. This request may come from an elected official or a representative of the Manager’s office. The item will be placed on the agenda for the Regional Council’s monthly meeting.

3. The Regional Council directs staff to begin the 208 planning process.

4. A "Scope of Work" Task Force is convened to determine the scope of work for the plan amendment report.

5. A draft report is prepared by the party requesting the amendment; several copies are submitted to the Scope of Work Committee for review.

6. The Scope of Work Committee determines if the draft plan amendment report contains the necessary elements and adequately addresses any issues. If so, the report is submitted to the Water Quality Subcommittee of PAG’s Environmental Planning Advisory Committee (EPAC).

7. The Water Quality Subcommittee of EPAC reviews the report and makes a recommendation to EPAC. (This subcommittee usually meets the third Thursday of every month.)

8. EPAC reviews the report and makes a recommendation to the Regional Council. (EPAC usually meets the first Friday of every month).

9. A public hearing is held (requires 45-day legal notice).

10. PAG’s Management Committee reviews the proposal, EPAC’s recommendation, and the results of the public hearing, and determines whether the proposal will be forwarded to the Regional Council. (The Management Committee usually meets once a month.)

11. PAG Regional Council action. (The Regional Council usually meets once a month, roughly two weeks after the Management Committee meets.)

12. Action at the statewide Water Quality Management Working Group in Phoenix (meets every other month).

13. ADEQ approval. Amendment is certified by ADEQ director.

14. EPA approval. (EPA has 120 days to review; if no comments are received, the amendment is considered to be approved.

When is a 208 Plan Amendment Required?
Generally, any change in wastewater service which was not included in the original 208 Plan or its amendments will require either an analysis for consistency with the plan, or a new Plan Amendment. A 208 Plan Amendment will also be required in the event of any change in a policy established by the original 208 Plan or adopted in subsequent 208 Plan Amendments. A Plan Amendment is generally not necessary for a facility modification that will not change the facility’s capacity.

The Arizona Department of Environmental Quality Continuing Planning Process (April, 1993) identifies the following instances in which a 208 Plan Amendment is required:

  • When new Water Quality Management Planning Agency or Wastewater Management Agency designations are made;
  • When significant changes occur in the service area and/or population figures projected in current wastewater treatment facility plans or areawide water quality management plans;
  • Prior to construction of facilities (regardless of funding source) or implementation of management practices which are inconsistent with the areawide or State plan;
  • When changes in site-specific water quality standards associated with wastewater treatment facilities and/or management practices are made;
  • When significant growth occurs in areas where water quality is threatened by particular activities such as heavy reliance on septic tanks;
  • When changes to the State plan necessitate an amendment to the regional or areawide plan in order for the changes to be implemented.

For more information, contact PAG at (520) 792-1093 or the Arizona Department of Environmental Quality at 1-800-234-5677.  

PAG's 208 Plan

Planning for the treatment of municipal wastewater is a key part of 208 Planning. PAG's Section 208 Areawide Water Quality Management Plan (208 Plan) identifies all of the existing wastewater treatment facilities in Pima County, as well as any facilities that have been proposed, and  provides policy and management direction for control and use of wastewater in Pima County. The current 208 Plan consists of a document written in 1978 and all of its amendments through 2006, and was approved by the Regional Council on March 23, 2006.

The 208 Plan Update is provided below, both as an entire document and divided into parts, or you may review a copy at Pima Association of Governments offices in Tucson, Arizona.

PAG's Section 208 Areawide Water Quality Management Plan Update as approved by the Regional Council on March 23, 2006, is provided below, both as an entire document and divided into parts.

Entire Plan (8.3 Mb PDF) 

  • Cover Page (900 Kb PDF)
  • Table of Contents (33 Kb PDF)
  • Executive Summary (14 Kb PDF)
  • Chapter 1: Introduction (183 Kb PDF)
  • Chapter 2: Summary of Original 208 Plan, Amendments and Policies (165 Kb PDF)
  • Chapter 3: Planning Area Description (917 Kb PDF)
  • Chapter 4: Agency and Area Designations (1.3 Mb PDF)
  • Chapter 5: Existing Wastewater Treatment Facilities and Other Point Source NPDES Discharges (1.3 Mb PDF)
  • Chapter 6: Existing Solid Waste Management (79 Kb PDF)
  • Chapter 7: Future Conditions (1.2 Mb PDF)
  • Chapter 8: Watershed Approach to Water Quality Management Planning (1 Mb PDF)
  • Chapter 9: Plan Description and Policies (132 Kb PDF)
  • Chapter 10: Plan Implementation and Procedures (141 Kb PDF)
  • References (32 Kb PDF)
  • Appendix A: 40 CFR 130.6 (20 Kb PDF)
  • Appendix B: PAG Regional Council Approval of Resolution 78-12-07 (188 Kb PDF)
  • Appendix C: ADEQ Checklist for 208 Plan Amendments (25 Kb PDF)
  • Appendix D: Sampling Results from ADEQ's 2004 Draft 305b Report (468 Kb PDF)
  • Appendix E: State of Arizona Executive Order 70-2 and Governor Williams' Designation Letter (235 Kb PDF)
  • Appendix F: Town of Sahuarita 1999 DMA Description (99 Kb PDF)
  • Appendix G: PAG Outline for 208 Plan Amendments (24 Kb PDF) 

PAG 208 Plan Amendments and Consistency Reviews

A 208 Plan Amendment is any approved change to the Areawide Water Quality Management Plan. In the PAG region, most 208 Plan Amendments since 1990 have related to proposals to construct wastewater treatment facilities that were not included in the original 208 Plan adopted in 1978. Many 208 Plan Amendments adopted in the 1980s addressed policy changes, pollution source assessments, groundwater quality investigations, and long-range plans for meeting regional wastewater treatment needs.

Recent 208 Amendments

Recent Consistency Reviews

A Consistency Review by DPA is required for new wastewater reclamation facilities, existing domestic facilities adding an AZPDES discharge outfall, major increased in design flow, and changes of ownership of facilities. A Consistency Review determines if a project was described in the PAG 208 Plan, or if not, if an Amendment to the PAG 208 Plan is necessary. ADEQ relies on PAG as the DPA to notify ADEQ if regional coordination has occurred and if cooperative support is present.

Tucson Water- Santa Cruz River Heritage Project

PAG online document library


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