FINDINGS FOR THE
  AMERICAN SAMOA COASTAL NONPOINT PROGRAM
                      

FOREWORD

     This document contains the findings for the coastal
nonpoint pollution control program submitted by the Territory of
American Samoa pursuant to Section 6217(a) of the Coastal Zone
Act Reauthorization Amendments of 1990 (CZARA).  The
findings are based on a review of the American Samoa Coastal
Nonpoint Pollution Control Program, July 1995.  The National
Oceanic and Atmospheric Administration (NOAA) and the U.S.
Environmental Protection Agency (EPA) reviewed this
information and evaluated the extent to which it conforms with
the requirements of CZARA.

     NOAA and EPA commend American Samoa on the
substantial amount of time and effort put into developing your
program and we appreciate the commitment you have shown to
complete an ambitious task with limited resources.  We will
continue to work with coastal states and territories to ensure that
these findings represent an accurate assessment of current state
and territory abilities and efforts to address coastal nonpoint
source pollution.  We recognize that there may be further
administrative changes to the coastal nonpoint program that will
impact these findings and we assure you that, once such changes
are finalized, we will review these findings in light of the changes
and make any necessary adjustments. 


APPROVAL DECISION

     NOAA and EPA approve the coastal nonpoint pollution
control program submitted by the Territory of American Samoa
pursuant to Section 6217(a) of the Coastal Zone Act
Reauthorization Amendments of 1990, subject to certain
conditions.  

     This document provides the specific findings used by
NOAA and EPA as the basis for the decision to approve
American Samoa's program.  It also provides the rationale for the
findings and includes conditions that will need to be met for
American Samoa to receive final approval of its program.  The
timeframes associated with conditions become effective on the
date of the approval letter for these findings.
INTRODUCTION

      This document is organized by the major nonpoint source
categories and subcategories identified in the section 6217(g)
guidance and the administrative elements identified in the
program guidance (including the boundary for the 6217
management area).  Where appropriate, NOAA and EPA have
grouped categories and subcategories of management measures
into a single finding.  The structure of each finding follows a
standard format.  Generally, the finding is that the Territory's
program includes or does not include management measures in
conformity with the (g) guidance and includes or does not include
enforceable policies and mechanisms to ensure implementation. 
In some cases, the finding reflects that the Territory has identified
a back-up enforceable policy, but has not yet demonstrated the
ability of the authority to ensure implementation.  For further
understanding of terms in this document, the reader is referred to
the following:

Guidance Specifying Management Measures for Sources of
Nonpoint Pollution in Coastal Waters (EPA, January 1993)
Coastal Nonpoint Pollution Control Program:  Program
Development and Approval Guidance (NOAA and EPA, January
1993)
Flexibility for State Coastal Nonpoint Programs (NOAA and
EPA, March 1995)

     The references in this document refer to the American
Samoa Coastal Nonpoint Pollution Control Program, July 1995
("program submittal").  NOAA and EPA have written this
document as succinctly as possible.  We have relied upon, but do
not repeat here, the extensive information that the Territory has
included in its program submittal.  Further information and
analysis is contained in the administrative record for this approval
decision and may be reviewed by interested parties at the
following locations:

USEPA/Office of Wetlands, Oceans, and Watersheds
Assessment & Watershed Protection Division
Nonpoint Source Control Branch
401 M Street, SW (4503-F)
Washington, DC  20460
Contact:  Robert Goo (202-260-7025)

NOAA/Office of Ocean and Coastal Resource Management
Coastal Programs Division
SSMC-4, N/ORM3
1305 East-West Highway
Silver Spring, MD  20910
Contact:  Masi Okasaki (301-713-3121, x185)

USEPA Region 9
Office of Pacific Island Programs
75 Hawthorne Street
San Francisco, CA  94105
Contact:  Pat Young (415-744-1594)

I.   BOUNDARY

FINDING:  American Samoa has included the entire Territory as
the management area within which it will implement the 6217
coastal nonpoint program.  Therefore, American Samoa's
boundary is sufficient to control the land and water uses that
have, or are reasonably expected to have, a significant impact on
the coastal waters of American Samoa.

II.  AGRICULTURE

FINDING:  American Samoa's program includes management
measures in conformity with the 6217(g) guidance for erosion and
sediment control and for confined animal facilities, except that it
does not provide for appropriate waste utilization systems for
animal waste.  American Samoa's program does not include
management measures in conformity with the 6217(g) guidance
for pesticide management.  The Territory has identified a back-up
authority for the erosion and sediment control and confined
animal facilities measures, but has not yet demonstrated the
ability of the authority to ensure implementation of the
management measures throughout the 6217 management area. 
The program does not include enforceable policies and
mechanisms to ensure implementation of the pesticide
management measure throughout the 6217 management area. 
American Samoa has provided sufficient justification to support
an exclusion of the grazing and irrigation water management
measures, but not for exclusion of the nutrient management
measure as it applies to animal waste. 

CONDITION:  Within one year, American Samoa will (1)
include in its program management measures in conformity with
the 6217(g) guidance for confined animal facilities, nutrient
management as it applies to animal waste, and pesticides; (2)
include in its program enforceable policies and mechanisms to
implement the pesticide management measure; and (3) provide a
strategy (in accordance with section XIII, page 12) for use of the
American Samoa Environmental Quality Act (EQA) as a back-up
enforceable policy and mechanism to ensure implementation of
the management measures for erosion and sediment control,
confined animal facilities, and nutrient management as it applies
to animal waste. 

RATIONALE:  American Samoa expresses its commitment to
implement the management measures for erosion and sediment
control and confined animal facilities, lists some of the practices
that it currently uses to implement the measures, and sets forth a
process and schedule that will guide the Territory's
implementation activities.  However, the Territory does not
address waste utilization systems for animal waste management,
and needs to add this component to its confined animal facility
program to assure that animal waste is not over-applied to land
and, thereby, reaches coastal waters through leaching or runoff.

     The EQA, codified as ASCA, Title 24, Chapter 01, and
the American Samoa Water Quality Standards (ASWQS),
codified as ASAC, Title 24, Chapter 02, provide the
Environmental Quality Commission (EQC) with the authority to
require best management practices to prevent soil erosion and
prohibit other water pollution resulting from agricultural practices
(see ASCA 24.0107 and ASAC 24.0205 and 24.0207(a)
(10)).  The American Samoa Environmental Protection Agency
(ASEPA) is currently revising the ASWQS and developing
erosion and sediment control regulations and guidance documents
on agricultural practices.  These documents, to be adopted by the
Natural Resources Conservation Service (NRCS), the American
Samoa Community College (ASCC), and the American Samoa
Coastal Management Program (ASCMP) and implemented under
the authority of the EQA, could include the management
measures for erosion control and confined animal facilities.

     Crop agriculture in American Samoa is largely of a
subsistence nature, and confined animal facilities in the Territory
similarly consist of a relatively large number of family-operated
piggeries, which, although individually small in size, can have a
significant cumulative effect on water quality.  The Territory
proposes to implement these measures through a program based
on voluntary implementation, technical assistance, and outreach
from the NRCS, the American Samoa Department of Agriculture
(DOA), the ASCC, and the American Samoa Soil and Water
Conservation District (ASSWCD).  In addition, an assessment of
management practices will be conducted to determine those most
suitable for the Territory's steep terrain and intense rainfall.  The
Territory needs to demonstrate that its identified enforceable
policies and mechanisms can ensure implementation if voluntary
efforts fail to achieve compliance with the management measures.

     In reviewing the American Samoa program submittal,
NOAA and EPA note that, pursuant to ASAC 24.0209, the
EQC has the authority to review and permit all point and
nonpoint sources of pollution within the Territory.  ASEPA and
ASCMP program coordinators, however, have indicated to
NOAA and EPA that the Territory plans to use the voluntary
approach described above, coupled with existing backup authority
under ASAC 24.0205 and 24.0207, rather than the permitting
authority.

     The DOA has the authority, under 24.1205 of the
American Samoa Pesticide Act, ASCA, Title 24, Chapter 12, to
adopt rules regarding the application of pesticides.  DOA has
delegated this authority to the executive secretary of the EQC,
which has promulgated rules at ASAC, Title 24, Chapter 06. 
The Pesticide Act, however, pertains exclusively to the use of
regulated pesticides and does not include the use of techniques
such as integrated pest management.

     American Samoa has requested an exclusion from the
nutrient management measure, based on relatively low rates of
application of commercial fertilizer.  The nutrient management
measure, however, addresses land application of manure as well
as of commercial fertilizer.  Because the many small confined
animal facilities in the Territory have the potential to generate
animal waste as a pollutant to surface and groundwater, the
Territory needs to implement the nutrient management measure as
it applies to animal waste from these sources.  

     There are no domestic livestock that utilize range, pasture,
or grazing lands in American Samoa, and, because of the 125 to
200 inch per year rainfall in the Territory, the use of irrigation is
not needed.  Therefore, the Territory has demonstrated that
grazing and irrigation are not, and not anticipated to be,
significant contributors of pollutants to American Samoa's coastal
waters, and should be excluded from the program.



II.  FORESTRY

FINDING:  American Samoa has provided sufficient justification
to support a categorical exclusion of forestry from its coastal
nonpoint program.

RATIONALE:  Forestry is not practiced commercially in
American Samoa, and although some wood is harvested for fuel
and handicrafts, such activity is minimal and at the subsistence
level.  Therefore, forestry activities do not and are not reasonably
anticipated to present significant adverse impacts to coastal
waters.

IV.  URBAN

     A.   NEW DEVELOPMENT, SITE DEVELOPMENT,
     CONSTRUCTION SITE EROSION AND SEDIMENT
     CONTROL and CONSTRUCTION SITE CHEMICAL
     CONTROL

FINDING:  American Samoa's program does not include
management measures in conformity with the 6217(g) guidance
but does include enforceable policies and mechanisms to ensure
implementation throughout the 6217 management area.

CONDITION:  Within one year, American Samoa will include
in its program management measures in conformity with the
6217(g) guidance for new development, site development, and
construction site erosion and sediment and chemical control.  

RATIONALE:   The American Samoa Coastal Management
Program implements the Territorial land use permit (LUP)
program, under which permits are required for all activities that
may cause or threaten to cause adverse impacts to coastal
resources, except where specifically exempted by law.  ASCMP
permits must be consistent with the ASCMP implementing
regulations, ASAC Title 26, Chapter 02, and are reviewed 
through an interagency process know as the Project Notification
and Review System (PNRS).  The Development Planning Office
(DPO) and other PNRS member agencies can condition permits
for compliance with their authorizing legislation. 

     Both DPO and ASEPA have the authority to issue permit
conditions related to erosion control under the American Samoa
Coastal Management Act (ASCMA) and the EQA, respectively. 
These acts and their implementing rules do not, however,
completely implement the management measures.  For instance,
they do not require the post-development loadings of total
suspended solids or peak runoff rates specified in the management
measure for new development, nor do they fully implement the
requirements for protection of natural drainage features and
vegetation in the site development management measure.

     The ASEPA is currently revising its erosion control
regulations for implementation under the EQA through the
PNRS.  The ASEPA nonpoint source coordinator indicated in a
personal communication that ASEPA intends to incorporate all of
these measures into the revised regulations.  The Territory is also
currently undertaking studies to determine the management
practices most feasible for the climate and geography of
American Samoa.  NOAA and EPA recognize the unique
characteristics of American Samoa and anticipate that completion
of these activities will provide for full implementation of the new
development, site development, and construction site erosion and
sediment and chemical control management measures.

     The Territory has cited its pesticide and storage tank
regulations as implementing authorities for the construction site
chemical control management measure; however, these
authorities do not address nonregulated pesticides, nutrients, and
other toxic substances, such as oil, grease, and gasoline,
generated on construction sites.  The Territory needs to develop
management measures for such chemicals and clearly demonstrate
that permits, including appropriate conditions, can be used to
implement the management measure. 

B.   WATERSHED PROTECTION and EXISTING
DEVELOPMENT

FINDING:  American Samoa's program does not include
management measures in conformity with the 6217(g) guidance
for watershed protection and existing development but does
include enforceable policies and mechanisms to ensure
implementation throughout the 6217 management area.

CONDITION:  Within three years, American Samoa will include
in its program management measures in conformity with 6217(g)
guidance for watershed protection and existing development. 

RATIONALE:  Several agencies in American Samoa, including
ASEPA, DPO, and the Department of Marine and Wildlife
Resources (DMWR), have authorities and carry out activities
related to watershed protection.  For example, ASEPA has begun
watershed assessment, planning, and remediation in the Malaeimi
Valley and Lauli'i Village and will begin similar efforts in the
Pala Lagoon area.  The ASCMA contains provisions to protect
unique areas and resources from destruction and inappropriate
development and directs DPO to develop strategies to cope with
cumulative impacts on land and water resources.  These
activities, however, are not coordinated in a meaningful fashion
at present.

     In its program submittal, the Territory describes a
schedule of activities that it will undertake to implement the
watershed protection measure, including development of a
memorandum of understanding among ASEPA, DPO, and
DMWR, a resource inventory and information analysis, and
development and implementation of a watershed protection plan. 
When implemented, these efforts should provide an effective
means of watershed protection.

          For the existing development management measure, the
Territory proposes to assess opportunities to reduce pollutant
loadings.  Implementation will be dependent both on type of
solution proposed and on cost.  NOAA and EPA suggest that the
Territory integrate the existing development measures into the
watershed planning process discussed above.




C.   NEW and OPERATING ON-SITE DISPOSAL
SYSTEMS (OSDS)

FINDING:  American Samoa's program includes management
measures in conformity with the 6217(g) guidance and
enforceable policies and mechanisms to ensure implementation
throughout the 6217 management area, except that it lacks (1)
provisions for protective setbacks from surface waters and
wetlands and to direct placement of on-site disposal systems
(OSDS) away from unsuitable areas; (2) a program for inspection
of new and operating OSDS; and (3) a program to require
denitrifying systems where nitrogen-limited surface waters may
be adversely affected by nitrogen loadings from OSDS. 

CONDITION:  Within two years, American Samoa will finalize
its proposed OSDS regulations, and include management
measures in conformity with the 6217(g) guidance on setbacks
and avoidance of unsuitable areas; inspection of new and
operating systems; and requirements for denitrifying systems
where nitrogen-limited surface waters may be adversely affected
by nitrogen loadings from OSDS. 

RATIONALE:  Regulation of OSDS is currently fragmented
among several Territorial agencies. An LUP must be obtained
from the PNRS for any new construction or renovation.  OSDS
permit conditions are included in this permit for any structure
requiring an OSDS.  The American Samoa Power Authority
(ASPA), a PNRS member agency, requires hook up to the sewer
system or proper septic tank installation and conducts a final
inspection prior to connecting water or power lines to new or
modified structures.  The building inspections branch of the
Department of Public Works (DPW), however, is responsible for
inspecting OSDS systems during installation.  ASEPA and ASPA
currently are implementing an OSDS project, which involves
training, development of new regulations, and public education.

     The existing and proposed Territorial regulations do not
contain adequate provisions for inspection during installation of
new systems, and for operation, maintenance, and inspection of
existing systems.  The ASEPA regulations also need to address
the need for denitrifying systems where nitrogen-limited surface
waters may be adversely affected by nitrogen loadings from
OSDS and other aspects of the 6217(g) guidance as noted in the
Finding above. 

D.   POLLUTION PREVENTION
          
FINDING:  American Samoa's program includes management
measures in conformity with the 6217(g) guidance.
          
RATIONALE:  In its program submittal, American Samoa
describes a number of programs and activities that address the
components of this management measure.  These programs and 
activities include a household hazardous waste education and
collection program, the establishment of used oil collection
centers, an anti-litter campaign, stream and beach clean ups, and
an industrial and government facility pollution prevention
program.




E.   ROADS, HIGHWAYS, AND BRIDGES

FINDING:  American Samoa's program includes management
measures in conformity with the 6217(g) guidance for planning,
siting, and developing roads and highways and bridges and
includes enforceable policies and mechanisms to ensure
implementation of the planning, siting, and development measure,
the measure for bridges, and the construction project erosion and
sediment control and chemical control measures.  The program
does not include management measures in conformity with the
6217(g) guidance for construction project erosion and sediment
control, construction site chemical control, operation and
maintenance, and runoff systems and does not include enforceable
policies and mechanisms to ensure implementation of the
operation and maintenance and runoff measures throughout the
6217 management area. 

CONDITION:  Within three years, American Samoa will include
in its program management measures in conformity with the 6217
(g) guidance for construction project erosion and sediment
control, construction site chemical control, operation and
maintenance, and runoff systems.  Within three years, the
Territory will also include in its program enforceable policies and
mechanisms to ensure implementation of the operation and
maintenance and runoff measures throughout the 6217
management area.

RATIONALE:  The PNRS permitting process and ASCMP
administrative rules include provisions to implement the planning,
siting, and development and bridges management measures. 
Existing rules for the ASCMA and EQA do not contain specific
elements to ensure implementation of the construction project
erosion and sediment control and construction site chemical
control measures, but the ASEPA erosion and sediment control
regulations currently being revised have the potential to
implement these measures.  The Territory's program submittal
identifies the EQA as an enforceable authority for the operation
and maintenance and runoff measures, but the Territory needs to
provide further description and detail on how it intends to use this
authority to ensure that the DPW, which constructs all public
roads in American Samoa, complies with the measures.  If the
Territory decides to use the EQA as a back-up authority, it will
need to develop a strategy in accordance with section XIII, page
12.

V.   MARINAS AND RECREATIONAL BOATING
    
     A.   MARINA FLUSHING, WATER QUALITY
     ASSESSMENT, HABITAT ASSESSMENT,
     SHORELINE STABILIZATION, FUELING
     STATION DESIGN, AND SEWAGE FACILITY
     MANAGEMENT      

FINDING:  American Samoa's program does not include
management measures in conformity with the 6217(g) guidance
but does include enforceable policies and mechanisms to ensure
implementation throughout the 6217 management area.
          
CONDITION:  Within three years, American Samoa will include
in its program management measures in conformity with the
6217(g) guidance for marina flushing, water quality assessment,
habitat assessment, shoreline stabilization, fueling station design,
and sewage facility management.

RATIONALE:  Authority to regulate new and expanding
marinas in American Samoa exists under the ASCMP land use
permitting program, but existing regulations and guidance do not
fully implement the management measures.  The Territory has
proposed to develop a marina guidance document, based upon the
6217(g) guidance, which would address marina siting and design. 
Implementation of the guidance document would be ensured
through LUP conditions. 

     B.   STORMWATER MANAGEMENT, SOLID WASTE
     MANAGEMENT, FISH WASTE MANAGEMENT,
     LIQUID MATERIAL MANAGEMENT,
     PETROLEUM CONTROL, BOAT CLEANING,
     PUBLIC EDUCATION, SEWAGE FACILITY
     MAINTENANCE, and BOAT OPERATION

FINDING:  American Samoa's program does not include
management measures in conformity with the 6217(g) guidance. 
The Territory has identified a back-up enforceable policy and
mechanism for these measures, but it has not yet demonstrated
the ability of this authority to ensure implementation of the
management measures throughout the 6217 management area.

CONDITION:  Within three years, American Samoa will include
in its program management measures in conformity with the
6217(g) guidance and develop a strategy (in accordance with
section XIII, page 12)  for use of the EQA as a back-up
enforceable policy and mechanism to ensure implementation of
these management measures throughout the 6217 management
area.

RATIONALE: American Samoa proposes to implement these
measures on a voluntary basis, primarily through the use of a
marina guidance document, using provisions of the EQA as a
back-up authority (see especially ASCA 24.0107 and ASAC
24.0207).  The Territory does not at present, however, have
regulations or guidance to provide a means of implementing the
voluntary program.  In addition, the Territory needs to develop a
strategy for use of the EQA as a back-up authority. 

VI.  HYDROMODIFICATION

FINDINGS:  American Samoa's program does not include
management measures in conformity with the 6217(g) guidance
but does include enforceable policies and mechanisms to ensure
implementation throughout the 6217 management area for the
channelization and channel modification and eroding streambank
and shoreline management measures, except that the program
does not include (1) a process to improve surface water quality
and restore in-stream and riparian habitat through the operation
and maintenance of existing modified channels and (2) a process
to identify and develop strategies to solve existing nonpoint
source pollution problems caused by eroding streambanks and
shorelines that do not come up for review under existing permit
authorities. American Samoa has provided sufficient justification
to support an exclusion of the dams management measures from
the coastal nonpoint program.

CONDITION:  Within three years, American Samoa will include
in its program (1) management measures in conformity with the
6217(g) guidance for channelization and channel modification,
and eroding streambanks and shorelines; (2) a process to improve
the physical and chemical characteristics of surface waters and
restore instream and riparian habitat in existing modified
channels; and (3) a process to stabilize eroding streambanks and
shorelines causing nonpoint problems that are not reviewed under
existing authorities.

RATIONALE:  LUPs issued through the PNRS under the
authority of the ASCMA and EQA are required for new
channelization activities.  While permit applications are reviewed
for impacts on water quality and habitat, existing regulations do
not completely implement the measures.  The Territory may
choose to consider revisions to the water quality standards,
erosion and sediment control regulations, or ASCMP regulations
as a mechanism to achieve full implementation of the measures. 
For existing channels, the program submittal identifies the need
for an assessment of existing channels and prioritization of areas
to be restored; however, authorities to ensure implementation of
the measure are not identified, nor are management measures
adopted in the form of regulations or guidance manuals. 

     To implement the management measure for eroding
streambanks and shorelines that are causing nonpoint problems,
American Samoa plans to assess and prioritize shoreline and
streambank needs for stabilization and then begin a stabilization
program. This proposal, however, does not include management
measures and clear processes to ensure implementation of the
measure throughout the 6217 management area.

     Since the program submittal points out that there are no
dams in American Samoa meeting the definition in the (g)
guidance, and that none are expected to be constructed in the
future, the management measures for dams are excluded from the
program. 

     VII. WETLANDS, RIPARIAN AREAS, AND
     VEGETATED TREATMENT
     SYSTEMS
          
FINDINGS:  American Samoa's program includes management
measures in conformity with the 6217(g) guidance and includes
enforceable policies and mechanisms to ensure implementation of
the management measures.
          
RATIONALE:  Land use permits are required from the PNRS
for dredging or filling activities in wetlands.  The ASCMA
regulations include provisions that implement the management
measures.  Proposals for new work in or near wetlands and
streams are reviewed for their impacts on water quality and
habitat.  The ASCMP also has an aggressive wetland restoration
program underway. Pretreatment practices for runoff from upland
areas are being introduced as part of the implementation of the
urban management measures. 

          VIII.     ADMINISTRATIVE COORDINATION

FINDING: American Samoa's program includes mechanisms to
improve coordination among Territorial agencies and between
Territorial and local officials in implementing the coastal
nonpoint program.

RATIONALE:  The program submittal describes existing
mechanisms to coordinate Territorial efforts to address nonpoint
pollution of coastal waters.  Existing mechanisms include the
EQC, PNRS, and the ASSWCD.  The ASEPA will act as the lead
agency on all nonpoint pollution program coordination, working
closely with the ASCMP.  

     The program submittal also describes new coordination
mechanisms the Territory intends to create.  A coordination
committee will be convened under ASEPA leadership to develop
and implement management measures not currently in place. 
Memoranda of understanding will be entered into with agencies
implementing applicable management measures. 

     Special attention should be given to coordinating the
implementation of the OSDS management measures by the
Territorial agencies with responsibility in this area.

     IX.  PUBLIC PARTICIPATION

FINDING:  American Samoa's program provides opportunities
for public participation in the development and implementation of
the coastal nonpoint program.

RATIONALE:  The Territory's program submittal describes
activities that provide ongoing opportunities for public
participation in the coastal nonpoint program. These include
workshops on nonpoint source pollution and on the section 319
and 6217 programs for government, the private sector, and the
general public; public comments on the draft Coastal Nonpoint
Pollution Control Program document; and public education on
management measures and practices as they are implemented.  A
number of workshops and demonstration projects have already
occurred.

     X.   TECHNICAL ASSISTANCE

FINDING: American Samoa's program includes technical
assistance to village governments and the general public for
implementing the nonpoint program.

RATIONALE:  The section 319 program in American Samoa
includes several projects in which financial and technical
assistance are provided to demonstrate nonpoint source best
management practices.  Other types of technical assistance will
include brochures, training sessions, and other hands-on
assistance. 

     XI.  CRITICAL COASTAL AREAS and ADDITIONAL
     MANAGEMENT MEASURES

FINDING:  American Samoa's program identifies and includes a
continuing process for identification of critical coastal areas and
provides for the development and continuing revision of
management measures applicable to critical coastal areas and
cases where the 6217(g) measures are fully implemented but
water quality threats or impairments persist. 

RATIONALE:  In its program submittal, the Territory has
identified currently designated special management areas under
the ASCMP as critical coastal areas under its coastal nonpoint
program.  These areas are Pago Pago Harbor, Pala Lagoon, and
Leone Pala.  The beneficial uses of these water bodies are either
not being met or are threatened.  Land uses and other activities
prohibited by the ASWQS are also present.  The program
identifies additional management measures for small piggeries,
shoreline land filling, and solid waste management as preliminary
needs.  The program includes a process for continually
developing and revising these and other measures for application
in critical coastal areas and other relevant areas. 

XII. MONITORING
          
FINDING:  American Samoa's program does not include a plan
to assess over time the success of the management measures in
reducing pollution loads and improving water quality.
          
CONDITION:  Within one year, American Samoa will include
in its program a monitoring plan that enables the Territory to
assess over time the extent to which implementation of
management measures is reducing pollution loads and improving
water quality.  
          
RATIONALE:  American Samoa outlines its monitoring
program, stating that it will consist of routine water quality
testing, on-site inspections of management practices,
self-reporting by land owners or permittees, a tracking system for
BMPs, an annual report, and possibly a volunteer monitoring
program.  While these activities address the major elements of a
successful monitoring program, the Territory has not clearly
specified what it will do to assess over time whether the
management measures are reducing pollution loads and improving
water quality.  For example, there is no discussion of the specific
monitoring and analyses that will be performed to demonstrate
and associate water quality trends with management measure
implementation at the major bays of Tutuila Island (p. 138).  The
sedimentation study described on page 138 provides an
opportunity to establish a baseline for relating water quality to
management measure implementation, but the Territory plans to
complete the study in fiscal year 1996 rather than continue or
expand the effort over time as management measures are
implemented. Thus, none of the current or planned monitoring
efforts are described in adequate detail to determine if they might
be useful to evaluate the effectiveness of the Territory's coastal
nonpoint program.
          
          American Samoa needs to continue development of its
proposed monitoring program.  The Territory should include in
its plan information regarding the number and location of
monitoring stations, the types and frequency of water quality data
being collected, and the analytic approaches that will be
employed in conjunction with existing monitoring efforts to
assess the success of management measures in achieving water
quality objectives.  The Territory should include some
inexpensive tracking of management measure implementation in
conjunction with water quality monitoring, as such information is
needed to assess the success of management measures in
achieving water quality objectives.  NOAA and EPA are willing
to assist the Territory in these efforts.

XIII.     STRATEGY AND EVALUATION OF BACKUP
AUTHORITIES

     Within one year, American Samoa will develop a strategy
to implement the management measures for agricultural erosion
and sediment control, confined animal facilities, nutrient
management as it applies to animal waste, marina and boat
operation and maintenance, and marina stormwater management
throughout the 6217 management area.  This strategy will include
a description and schedule for the specific steps the Territory will
take to ensure implementation of the management measures;
describe how existing or new authorities can be used to ensure
implementation where voluntary efforts are unsuccessful; and
identify measurable results which, if achieved, will demonstrate
the Territory's ability to achieve implementation of the
management measures using the described approach.

     In order to evaluate the adequacy of this strategy,
American Samoa will also develop and apply credible survey
tools to demonstrate the ability of the Territory's approach to
achieve implementation for these management measures.  The use
of credible assessment techniques is necessary in order for
NOAA and EPA to evaluate, at the end of the three year period
described in the March 16, 1995 guidance issued by NOAA and
EPA entitled Flexibility for State Coastal Nonpoint Programs,
whether the Territory's approach has been successful or whether
new, more specific authorities will be needed.