"This paper examines Section 208, the areawide water quality planning and implementation program, to determine its use as a model for the air quality program. Section 208 was incorporated into the Federal Water Pollution Control Act as an amendment in 1972 to structure and help fund a mechanism by which local governments comprehensively plan and direct management of water quality. While 208's implementation is just beginning, it has already shown effects that can help design a planning/management mechanism to be incorporated into the Clean Air Act. Many members of Congress are considering including 208 language into the Clean Air Act, and this paper intends to show which provisions could be carried over usefully to the air program and what language needs to be adjusted to better fit the clean air effort. It is assumed here that comprehensive, areawide planning is needed for improved air quality management, just as it is essential to water quality management. The paper compares the water and air quality programs -- their functions, the types of organizations involved, the environmental problems they address and the level of expertise and data for planning. Key legislative and administrative issues are identified for 208, and then applied to the air program."