FINAL
ENVIRONMENTAL IMPACT STATEMENT
REDWOOD SERVICE DISTRICT
JOSEPHINE COUNTY, OREGON
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
SEATTLE, WASHINGTON 98101
APPROVED BY:
REGIONAL ADMINISTRATOR (D#fE)
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PREFACE
On June 13, 1975 the U.S. Environmental Protection Agency (EPA)
released for public review a draft Environmental Impact Statement (EIS)
on a proposed action for the Redwood Sanitary Service District, located
in Josephine County, Oregon. The decision to write a draft and final
EIS by EPA was based on an expected grant application from the Redwood
Sanitary Service District for Step 3 construction grant funding in which
EPA would provide 75% of the funds required to construct a sewerage system.
This grant award would also provide reimbursement funds for Step 1 planning
and Step 2 design work which has already been expended by the Redwood
District. To complete the environmental impact evaluation, EPA has prepared
this final EIS which is the result of EPA's consideration of the comments
received on the draft EIS, public hearing testimony, additional evaluation
of the alternatives, and a review of legal interpretations involving
Federal policy and regulations related to local land use plans.
A new addition to the text of this final EIS is the inclusion of a
chapter entitled "Comments and Responses to the Draft EIS". In this chapter,
EPA has reprinted letters commenting specifically on the draft statement
and has attempted to respond to all questions and requests for explanation,
correction or revision where additional evaluation proved the draft statement
to be in error.
Letters voicing opinions on the proposed project but not commenting
on the EIS were also received by EPA. While these letters are not reproduced
in this final statement, a summary of them is included illustrating the
major concerns raised. All letters along with the Public Hearing Record have
been.considered in EPA's decision-making process.
A significant action occurred during the EIS review process involving
an examination of EPA's construction grant requirements and their relationship
to State and local land use regulations. Throughout the draft statement EPA
noted that the proposed project as submitted by Josephine County raised
serious questions as to conformance with the County's Comprehensive Land Use
Plan. EPA's regulations require that the Regional Administrator of EPA,
prior to grant award, must determine:
"That the treatment works will comply with all pertinent
requirements of the Clean Air Act and other applicable Federal,
State and local environmental laws and regulations."(40 CFR 35.925-14)
Additionally, 40 CFR 35.935-4 subjects all treatment works grants to the
following conditions:
"The construction of the project, including the letting of
contracts in connection therewith, shall conform to the applicable
requirements of State, territorial, and local laws and ordinances
to the extent that such requirements do not conflict with Federal
laws and this subchapter."
In ascertaining whether or not a Comprehensive Land Use Plan constitutes
an applicable law, regulation or ordinance within the meaning of 40 CFR 35.925-14
and 40 CFR 35.935-4, EPA reviewed recent decisions of the Supreme Court of
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Oregon (Fasano v. Board of County Commissioners of Washington County,
507 P. 2d23 (1973); Baker y. City of Milwaukie, 533 P. 2d772 (1975)) which
assert that the Comprehensive Plans are the controlling land use instruments
within Oregon and that such plans are legislative in nature. Because of
the decisions of the Supreme Court of Oregon as to the legal status of
adopted comprehensive plans, EPA's Regional Counsel concluded that such
plans should, when duly adopted in the State of Oregon, be considered laws,
regulations, or ordinances with which EPA-funded construction grant projects
must comply as stated in the above-cited EPA regulations.
Based on the foregoing, EPA considers itself bound to respect the
policies and decisions expressed in comprehensive plans when awarding
construction grants in the State of Oregon. EPA has concluded that the
alternative designated as the "Proposed Project" in the draft EIS contra-
dicts the comprehensive plan adopted by the Josephine County Planning
Commission in 1971 and existing zoning requirements which implement that
Plan. At this time, funding that alternative would violate EPA's regula-
tions as well as both the State and EPA policies.
The draft EIS examined the environmental impacts associated with
each alternative. While these impacts were analyzed in the draft, they
have been given further consideration and will continue to be examined
throughout the remainder of the EIS process. Major adverse impacts must
be studied in terms of mitigating techniques which can be incorporated into
project construction and which may affect the degree of future secondary
impacts. This examination of adverse impacts is an essential facet of
EPA's decision-making process.
During preparation of the draft EIS a number of population projections
for Josephine County were examined by EPA (these are shown in the response
to the comment letter from the Josephine County Road Department). Based
on the projections it appeared that the estimate utilized in the District's
grant application for project design purposes was high. Due to the sub-
stantial differences between the projections, EPA will require, through
a condition to any grant award, a new population estimate for the Redwood
area, (see page 80)
The grant condition will specify that:
The grantee shall, prior to preparation of plans and specifi-
cations, have prepared a new population projection for the Redwood Service
District. To the extent that changes from the original population projection
occur, the treatment plant and collection system design flows will be revised
accordingly. The projection shall not be based upon a presumed saturation
of the area to an arbitrary density, but must rely upon accepted modern
demographic techniques including historical trends, employment projections,
current zoning and land use planning goals, and local immigration and birth
rates. This projection shall be submitted to the Oregon State Clearinghouse
for review and to EPA for approval prior to commencement of further design
work.
The two remaining alternatives that were explored in the draft EIS
are Alternative "A", a project of reduced scope, and Alternative "B", the
no-action alternative. Alternative "A" proposes construction of a sewage
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treatment plant in the vicinity of Darnielle Lane and South River Road.
This project would provide sewerage service to the eastern sector of the
Redwood S.D. but presently would not serve tk- western sector. Phase II
of this alternative would allow provision of sewer service to the western
sector when, and if, growth pressures dictate and the Comprehensive Plan
has been changed to permit such development. Alternative "A" will, however,
provide service to the Redwood School, Rogue Community College, River Haven
Mobile Estates and the Dun Rovin Trailer Park. These four sites were
identified in the draft EIS as having serious wastewater problems and as
being in need of a sewer system. This alternative would be in compliance
with the Comprehensive Plan and is EPA's recommended alternative in
solving the wastewater problems within the Redwood Sanitary District. The
"no-action" alternative would not provide a sewerage system for the Redwood
S.D. The "Alternative Section" of the final EIS investigates these alter-
natives in more detail.
The Environmental Protection Agency submits this final EIS for a
public review period of 30 days. Following this review period the
Regional Administrator of EPA will make his final determination concerning
a grant for the Redwood Service District.
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U.S. Environmental Protection Agency
Region X
Seattle, Washington
SUMMARY SHEET
( ) Draft Environmental Impact Statement
(X) Final Environmental Impact Statement
1. Background of the Redwood Environmental Impact Statement.
On July 31, 1974, the Redwood Sanitary Sewer Service District (located
southwest of Grants Pass, Oregon) submitted an application to EPA for grant
assistance in the construction of a waste treatment plant and sewerage system.
Because of the surrounding public controversy and the potential for significant
environmental impact, EPA has prepared this EIS.
2. Alternatives Considered.
EPA considered three alternatives:
a. The project as originally proposed by the Service District would
involve construction of a sewerage system to initially serve the eastern half
of the Service District which a portion has been declared an emergency health
hazard area by the Josephine County Health Department. An interceptor (the
Redwood Interceptor) would be constructed westerly along the Rogue River (the
northern boundary at the District) to a secondary treatment plant at the west
end of the Service District. Effluent would be discharged to the Rogue River.
(See Preface)
b. Alternative "A" would also sewer the eastern half of the Service
District, but the treatment plant would be located in the vicinity of the
intersection of Darnielle Lane and South River Road (approximately 1.7 miles
east of the proposed project plant site). The western half of the District
would only be sewered if the planned growth potential of the eastern sector was
near realization and the Comprehensive Land Use Plan was amended to permit
residential development of the western sector. If the western sector was going
to be sewered, a new treatment plant could be built (and the old one abandoned)
at the "proposed project" plant site.
c. Alternative "B" involves no construction of an areawide
sewerage system or treatment plant. The predominant form of waste disposal
would continue to be septic tanks and drainfields.
3. Environmental Impacts and Adverse Environmental Effects.
Though the "no-action" alternative (Alternative "B") involves the least
cost and impacts, there would be a certainty for continued health hazards
associated with malfunctioning septic tanks in the eastern portion of the
Service District, due to physical conditions such as high groundwater table,
shallow bedrock depth, non-porous soils, etc. It is our conclusion that in
the no-action "future" certain serious health hazards would not be corrected.
There is also the significant possibility that raw wastes would continue to
be discharged to the Rogue River thereby degrading its water quality.
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Thus, the "no-action" alternative (in the eastern portion where land use
controls have been lacking) would not meet national and state water quality
goals and requirements and, thus, not be a solution to the Service District's
waste disposal problems.
The proposed project does alleviate the health hazard within the
initial service area and by doing so it permits planned development of
the eastern sector as recommended by the Comprehensive Plan.
However, the proposed project has the potential to induce growth within
the western sector that is inconsistent with existing land use patterns and
the goals of the Comprehensive Plan. The project is designed to serve such
growth should it occur.
The proposed project is as expensive as other alternatives and may
result in significantly higher short-term energy consumption levels.
Alternative "A" (Phase One) also alleviates the existing health hazard
and provides for future planned growth in the eastern sector pursuant to
the Comprehensive Plan. No sewers are constructed in the western half of
the Service District, so Alternative "A"'s growth inducement potential for
the western sector is minimal. This would help maintain the rural character
of that area while permitting growth in areas for which it has been planned.
Phase Two of this alternative would allow provision of sewer service
to the western half of the Service District when, and if, growth pressures
dictate and the Comprehensive Plan has been changed to permit such develop-
ment. It is also possible that all projected growth for the Service District
(over 50 years) could be confined to the easter sector utilizing the zoning
densities recommended by the Comprehensive Plan, and thus, the plant would
never have to be moved.
4. The following State, Federal and local agencies and interested groups
were invited to comment on the Environmental Impact Statement.
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FEDERAL AGENCIES
COUNC L ON ENVIRONMENTAL Qi
U,S, DEPARTMENT OF AGRICUL
U,S, DEPARTMENT OF DEFENSE
0,S, DEPARTMENT OF INTERIOR
U,S, DEPARTMENT OF HEALTH., I
U,S, DEPARTMENT OF HOUSING ..
U,S, DEPARTMENT OF TRANSPORT
ADVISORY COUNCIL ON HISTORIC
-EDERAL ENERGY ADMINISTRATION
U,S, FOREST SERVICE
K 0, HATFIELD
,S, SENATE
ROBERT W. PACKWOOD
U,S, SENATE
ITY
IE
ICATION AND WELFARE
i URBAN DEVELOPMENT
ION
ESERVATION
OF CONGRESS
- , JAMES WEAVER
U,S, HOUSE OF REPRESENTATIVES
STATE
GOVERNOR OF OREGON
OREGON STATE CLEARINGHOUSE
DEPARTMENT OF ENVIRONMENTAL QUALITY
OREGON STATE WILDLIFE COMMISSION
JOSEPHINE COUNTY BOARD OF COMMI
JOSEPHINE COUNTY PLANNING OFFIC
JACKSON-JOSEPHINE COMPREHENSIVE
DISTRICT #8
JOSEPHINE COUNTY
JOSEPHINE COUNTY
JOSEPHINE COUNTY
:XTENSION SERV
.IBRARY
HEALTH DEPARTM
ML AfID LOCAL
SIGNERS
HEALTH PLANNING COUNCIL, INC,
CE
NT
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KJTERESTEB GROUPS
CM/!:
REDWOC
r
REDWOOD AREA CITIZENS ASSOCIATION
ROGUE VALLEY COUNCIL OF GOVERNMENTS
OREGON ENVIRONMENTAL COUNCIL
ROGUE RIVER GUIDES ASSOCIATION
JOSEPHINE COUNTY CONSERVATION COALITION
iJORTWEST ENVIRONMENTAL DEFENSE CENTER
RIENDS OF OREGON
IOGUE RIVER COORDINATION I-OARD
IZAAK k?ALTON LEAGUE OF AMERICA, IlC,
NORTHWEST CTEELHEADERS COUNCIL OF TROUT UNLIMITED
tocuE ECOLOGY CENTER
_EAGUE OF hOMEN VOTERS OF OREGON
f'lAZAMAS
OREGON ','ILDLIFE FEDERATION
SIERRA CLUE
THE DRAFT ENVIRONMENTAL IMPACT STATEMBIT WAS MADE AVAILABLE TO THE
COUNCIL ON FNVIRONMENTAL QUALITY (CEQ) ATO THE PUBLIC ON JUNE 13, 1975,
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TABLE OF CONTENTS
Page No.
Chapter One—BACKGROUND AND DESCRIPTION OF THE "T-TI
PROPOSED PROJECT
Introduction 1-2
The Problem" 2-3
The Proposed Project 3-8
A. Location3
B. Facility Components 3
C. Design Capacities 8
D. Financing and Costs 8
Description of the Design Criteria Used to Plan the Project 9-11
A\Population Projection10
B. Per Capita Waste Discharge 10
C. Excess Capacity 11
Chapter Two—ENVIRONMENTAL IMPACT OF THE PROPOSED PROJECT 12-28
Introduction 12-13
Current Environmental Quality Conditions to be Affected 13-16
by the Project
A. Water Quality 13
B. Environmental Standards 13
C. Fish and Wildlife 14
D. Soils 14
E. Land Use Patterns 14
F. Population and Growth Trends 15
G. Economic Conditions 16
Primary Environmental Impacts of the Proposed Project 16-22
ft.Impacts on the Ecology18
B. Impacts on Physical/Chemical 19
C. Impacts on Aesthetics 20
D. Social and Economic Impacts 21
Secondary Environmental Impacts of the Proposed Project 22-28
A. Impacts on the Ecology23
B. Impacts on Physical/Chemical 23
C. Impacts on Aesthetics 27
D. Energy Consumption 27
Chapter Three—ADVERSE IMPACTS WHICH CANNOT BE AVOIDED 29-30
SHOULD THE PROPOSAL BE IMPLEMENTED"
Chapter Four—RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF 31
THE ENVIRONMENT AND THE MAINTENANCE AND ENHANCEMENT
OF LONG-TERM PRODUCTIVITY
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Page No,
Chapter Five—IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF 32
RESOURCES WHICH WOULD BE INVOLVED IN THE PROPOSED
ACTION SHOULD IT BE IMPLEMENTED
Chapter Six—ALTERNATIVES TO THE PROPOSED PROJECT 33-40
Alternative "A" 33-38
Alternative"^ 38-40
Chapter Seven—COMMENTS AND RESPONSES TO THE DRAFT EIS 41-133
LIST OF TABLES AND FIGURES
Figures
1. Redwood Service District Boundaries 4
(Initial Service Area)
2. Alternative Service Area Boundaries 5
3. Proposed Sewer System Layout 6
4. Ultimate Drainage Area 7
Tables
1. Summary of Eligible Project Costs 9
2. Existing and Design Population for the Proposed Project 11
3. Environmental Assessment of the Proposed Project 17
4. Annual Energy Consumption 28
5. Design Criteria for Alternative "A" 34
6. Environmental Assessment of Alternatives 35
7. Summary of Energy Consumption 38
8. Comments Received on Draft EIS 42
9. Letters Received in Support of a Sewerage System 121
10. Letters Received in Opposition 125
11. Speakers at EPA's Public Hearing 131
APPENDIX
Exhibit No.
1. Patterson, Langford, and Stewart Methodology
2. Current Environmental Quality Conditions
3. Telephone Memo of Call to Mr. William Haight 11/08/74
4. Josephine County Resolution
5. Oregon State Water Quality Standards
6. Explanation of Battelle-Columbus Methodology
7. Procedural Steps Required to Attain Sewer Service From the
Redwood Sanitary Sewer Service District
8. Bibliography
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CHAPTER ONE
BACKGROUND AND DESCRIPTION OF THE PROPOSED ACTION
Introduction
The Redwood Sanitary Sewer Service District (under the directorship
of the Josephine County Board of Commissioners) submitted an application
on July 31, 1974, to the Environmental Protection Agency (EPA) for grant
assistance under P.L. 92-500 in the construction of a waste treatment plant
and sewerage system. This followed a public hearing on May 7, 1974, where
the testimony indicated that there was some public controversy surrounding
the proposed project. Based on the potential for significant environmental
impact, the public controversy, and pursuant to the National Environmental
Policy Act of 1969 (NEPA), EPA determined that an Environmental Impact
Statement (EIS) should be prepared for the proposed Redwood Sewer Project.
A Notice of Intent to prepare the statement was sent to all interested
parties on October 4, 1974.
This EIS has been prepared on the proposed project as it was submitted
to EPA by the applicant, and is based on currently available data and
information. Thus, reference to the "proposed project" means the one
presented by the applicant not EPA. In addition to the proposed project
the EIS considers two other alternatives, a "do-nothing" project (maintaining
status quo) and a two-phase project that initially serves the eastern portion
of the District, (see p. 33) Figures 1 and 2 depict the boundaries of the
Redwood Service District, and also outline the "sub-areas" of each alter-
native that are referenced throughout the EISS e.g. the "Initial Service
Area" of the proposed project (Fig. 1) and the "Alternative Service Area"
of Alternative "A", (Fig. 2). The reader should become somewhat familiar
with the maps and area designations to avoid confusion.
In accordance with the Council on Environmental Quality (CEQ) guidelines
(40 CFR-Part 6), this EIS examines the relationship of the proposed action to
land use plans, policies and controls of the affected area. This report also
presents the population and growth assumptions used to support the project
and to determine secondary population and growth impacts resulting from the
proposed action and its alternatives. The EIS also addresses issues of how
the proposed project and alternatives will conform or conflict with the
objectives of other approved or proposed projects, plans, policies and controls,
The positive and negative impacts of the project on the environment are
evaluated including the primary and direct consequences as well as the
secondary or indirect consequences. These latter include, in the case of
construction of sewer systems, the stimulation or inducement of secondary
effects in the form of associated investments and changed patterns of social
and economic activities as well as impacts on growth and population. This
EIS assesses the effects of these possible changes in population patterns
or growth upon the resource base, including land use, water, air, public
services and facilities, and energy consumption.
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Despite the fact that some alternatives for wastewater treatment and
various identifiable environmental impacts (primary and secondary) may fall
outside the explicit regulatory and enforcement authority of EPA, NEPA mandates
a full public disclosure of all reasonable alternatives and possible environ-
mental impacts. This disclosure and discussion is the intent of this EIS,
To insure that the public is kept fully informed regarding this action,
and that it participates to the fullest extent possible in EPA's decision-
making process, the draft EIS was circulated for a 45-day review as required
by CEQ's August 1, 1973 guidelines. This final EIS is resubmitted for a 30-
day review period.
The Problem
The proposed project has evolved as a result of the Josephine County
Board of Health and the County Health Department's survey of the
individual disposal systems in the District during the last decade.
The entire Service District is presently unsewered, relying primarily on
individual disposal systems. In 1965, a portion of the eastern sector of
the Service District was declared an "emergency area" by the Josephine County
Health Department, because of numerous subsurface sewage disposal failures
and malfunctioning systems caused by a high water table, soil limitations,
and poor drainage.
An environmental health survey was conducted in 1970 by the County
Health Department. It was performed house to house and constituted a
50 percent sampling of homes in the entire Service District. There are
no more recent comprehensive surveys for the area, but results of EPA
site inspections appear to support the findings of the Health Department
survey.
SURVEY RESULTS--A11 sewage disposal systems were subsurface, due
to use of septic tanks. Five privies were also in use.
Effluent Disposal Condition:
Satisfactory 208 (55%)
Questionable - 74 (19%)
Malfunctioning 99 (26%)
Total systems 381
Effluent Disposition of Malfunctioning:
Surfacing -— 72 (73%)
Direct outfalls - 27 (27%)
Forty-five percent of the systems surveyed were experiencing problems
and 26 percent were malfunctioning. The wastes from these failing septic
tanks were found to be surfacing (73 percent) and also being discharged
directly through outfalls (27 percent). It is estimated that approximately
10 to 15 percent of the systems having problems were located in the western
portion of the Service District. Because of the number of malfunctioning
septic tanks, poor soil drainage, animal waste disposal, and improper well
construction, the domestic water supplies of the Service District were also
surveyed. Out of the total water samples (87 wells) taken in the area, 24
percent were found to be contaminated.
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The incidence of inadequately treated sewage surfacing is evident
throughout the eastern portion of the Service District. Such conditions
can subject the local citizenry to infectious hepatitis and other diseases.
Such waste discharges can be transported directly to the Rogue River where
people swim, boat, and other water-oriented sports. They also add
to the overall waste load to the river, which the river must try to assimilate.
In addition to the numerous failing residential septic tanks and drain-
fields, the Redwood School has a seasonal problem with sewage surfacing on
the west end of the track and play area. One mobile court (Dun Rovin) also
has a major sewage disposal problem with sewage surfacing in an open field
behind a residential development.
Thus, the purpose of the project is to eliminate the pollution of surface
and groundwaters in the area, protect individual domestic water supplies from
contamination, eliminate the present public health hazards resulting from
surfacing sewage and to enhance water quality of the Rogue River through the
elimination of raw discharge of sewage to the river and its adjacent drainage
areas.
The Proposed Project,
A. Location
The Redwood Sanitary Sewer Service District, located southwest of the
City of Grants Pass in Josephine County, encompasses 3,480 acres (about 5.4
square miles). The boundaries of the Service District, as shown in Figure 1,
are generally defined as that area lying south of the Rogue River, westerly
of Allen Creek, northerly of the South Highline Canal of the Grants Pass
Irrigation District, and easterly of Rounds Avenue. An additional 3,014
acres (about 4.7 square miles) drains into the service area from the south
and west. The summation of these areas (6,500 acres or 10.1 square miles)
represents the ultimate limits of the general drainage area, as shown in
Figure 3. Eventually, this ultimate drainage area may be incorporated into
the Service District as the District develops and extends its boundaries.
B. Facility Components
The proposed project to be contructed consists of an activated sludge
plant, a major interceptor 22,000 feet (about 4.2 miles ranging in size
from 12" to 27"), plus 67,000 feet of additional lines (two smaller inter-
ceptors, mains, and laterals). The entire sewerage system, at later develop-
ment, as shown in Figure 4, totals 157,000 feet (over 29.7 miles) of sewer
lines.
The treatment plant is sized to handle projected population increases
over its 20-year service life; it has a design capacity of just under
500,000 gallons per day and will produce an effluent concentration of
20 mg/1 of BOD and supsended solids. The effluent will be discharged to
the Rogue River. The general layout of the wastewater treatment facility
will consist of a control building, a blower building, and aeration basin,
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REDWOOD SANITARY SERVICE SEWER DISTRICT
INITIAL SERVICE AREA (Shaded)
PROPOSED SEWAGE
TREATMENT PLANT SITE
1 mile
SERVICE DISTRICT BOUNDARY
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ALTERNATIVE "A" SEWAGE
TREATMENT PLANT SITE
VICINITY
REDWOOD SANITARY SERVICE SEWER DISTRICT
ALTERNATIVE SERVICE AREA (Shaded)
1 mile
SERVICE DISTRICT BOUNDARY
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-Redwood Interceptor
REDWOOD SANITARY SERVICE SEWER DISTRICT
PROPOSED SANITARY SEWER SYSTEM
1 mile
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N
SCALE or mills
_.___JBaBHHaSHH
o 'A 1
LIMIT OF STUDY AREA
DRAINAGE BASIN
PASS f
'rrn
LOCATION MAP
REDWOOD SANITARY SERVICE
SEWER DISTRICT
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a secondary clarifier and chlorine contact chamber, an aerobic digester,
and two sludge disposal ponds. The proposed plant will be located on
the river approximately a quarter-mile west of the intersection of Rounds
Avenue and Leonard Road—about 4.5 miles downstream from the City of
Grants Pass.
Three interceptor sewers are proposed: a major one—the Redwood
Interceptor—running along the south bank of the Rogue River from Daisy
Lane west to the proposed treatment plant; a 12" line—the Darnielle
Interceptor—9,600 feet long in Darnielle and Hubbard Lanes; and the
Willow Interceptor in Willow Lane, 6,300 feet long, ranging from 10" to
12" in size.
The proposed sewage collection and treatment facilities will initially
serve about 1,650 people and 1,560 acres—that portion of the Redwood
Sanitary Sewer Service District, as shown in Figure 1, (designated as
Initial Service Area), located north of the Redwood Highway, east of
Darnielle and Hubbard Lanes, roughly north of South River Road and Leonard
Road extending to Rounds Avenue, and a portion of the District south of
the Redwood Highway which borders Allen Creek Road.
C. Design Capacities
The treatment plant is designed to handle the flow from 4,800 people.
The Redwood Interceptor, with a service life of 50 years (2025) is designed
to serve between 20,000 and 23,000 people, and 3,400 acres.
D. Financing and Costs
The estimated federally eligible cost of the project is $2,355,900.
The basic cost elements of the sewerage system are summarized in Table 1
for a 20-year planning period which is in accord with EPA's Cost-
Effecitiveness Guidelines.
The financing program proposed will include grant funds from EPA and
Josephine County, a county loan, and general obligation bond sales. EPA's
grant amount is expected to be $1,766,925, which is 75 percent of eligible
capital project costs. The voters of the Service District approved on
November 6, 1973 a $745,000 general obligation bond issue. With the addition
of Josephine County grant and loan monies the bond sale revenue will provide
all of the local financing for the collection system and that portion of the
interceptor and treatment plant costs not funded by the Federal grant (25%
of federally eligible costs).
The bonds ($745,000) would be repaid by property owners in the Service
District through assessments and connection charges. The county loan would
be repaid by revenue from future expansion within the presently unserved
portion of the District. A sewer service charge would provide the funds
necessary for operating the sewerage system. If the proposed project is
not approved for Federal funding, and an alternative is selected, a new
bond election would have to be held. In such a case, there is a risk that
the voters would not approve another bond issue, and based on public objection
to the proposed project, the risk could be substantial.
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TABLE 1
SUMMARY OF ELIGIBLE PROJECT COSTS .
20 Year Planning
1. CAPITAL COSTS Period Stage II2- Present Worth
Secondary Treatment Plant 807,OOO1• 807,000
473,000 122,000
Redwood Interceptor 1,043,100 1,043,100
Willow Interceptor 198,600 198,600
Darnielle Interceptor 307.200 307,200
Total $2,355,900 473,000 2,477,900
2. OPERATION & MAINTENANCE COSTS
Treatment Plant & Interceptors
(per year) 62,800 665,300
77,300 818,900
Total Present Worth
Capital, Operating &
Maintenance Costs 3,962,100
1. Serves 4,800 P.E.
2. Stage two provides for expansion of the treatment plant after 20 years.
This is done for comparison with Alternative "A" which is a two-phase
project. (Provided that growth pressures fill the eastern sector and
require that the plant be moved so as to serve the western sector).
Description of the Design Criteria Used to Plan the Project
The design criteria by which interceptors are sized and treatment plant
capacity is determined, are of particular importance in any waste treatment
project. Excess or inadequate capacity can lower treatment efficiencies or
result in higher long-run costs. A treatment plant that is oversized may
suffer from'just as much treatment inefficiency as an overloaded plant.
Likewise, interceptors that are excessively sized require an unjustified
capital expenditure in that the public is paying for more line than is
necessary to transport sewage.
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10
There are two criterion which are used as the basis for designing
sewage treatment systems—a population projection and average per capita
wastewater discharge. The product of these two numbers plus an infiltration/
inflow allowance, multiplied by a peak to average flow ration will yield the
maximum expected gallons per day to be carried and treated by the system.
Both factors are discussed below.
A. Population Projection
The proposed sewerage system was presented to EPA with a design capacity
of 20,000 people. This figure was calculated by the District's engineering
firm Cornell, Howland, Hayes, Merryfield, and Hill (CHp M) in the preliminary
engineering study for the District, (completed in 196b).
After receipt of the Service District's construction grant application
in 1974, EPA requested an independent population projection because of the
age of the prior estimate by CH2 M. The County was provided with a new
population projection by Patterson, Langford, and Stewart (PL&S) which
supported the CH2 M ultimate population projection (it was somewhat higher
at 23,000) but indicated a greater rate of growth for the Redwood area
than CH2 M had projected.
Exhibit 1 in the Appendix is the complete explanation of PL&S's
methodology. But briefly, PL&S based the county growth on historical
trends, and by assuming District saturation (3 people per unit--3 units
per developable acre) in 2025.
For the purposes of this EIS, the CH2 M projection will be used for
all alternatives, but a caveat should be added. During its research EPA
examined numerous population projections for Josephine County and it appears
that the CH2 M and PL&S estimates are high. Rather than provide its own
projection, or evaluate an alternative utilizing a lower design population
(which would be like comparing apples and oranges), EPA utilizes the CH2 M
projection. When a project is finally selected, EPA will require the
District to provide a new projection to support present sewer line
sizing. (See Preface) The major effect of a design population of a project
is on cost. EPA's use of the CH2 M projection in the EIS is valid because
it will permit an evaluation of the relative environmental impacts and
costs.
B. Per Capita Waste Discharge
To arrive at an estimate of expected waste flows and design treatment
facilities accordingly, engineers utilize an average gallons per capita
per day flow figure multiplied by the expected population. The most
common figure used is 100 gpcd, and it is based on average consumer waste
discharges. The total average flow obtained by these calculations is
multiplied by the peak to average flow ratio which is obtained from accepted
engineering manuals (e.g., Manual of Engineering Practice on the Design and
Construction of Sanitary and Storm Sewers).
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11
Such a methodology was used in the design of the Redwood treatment
facilities and yielded a sewer sized to carry approximately 5.3 MGD, the
ultimate design flow. This figure is adequate to facilitate the effective
transport of extra flows due to infiltration which .is an inevitable
occurrence, even with modern construction materials and practices.
C. Reserve Capacity
Reserve capacity is usually defined as that capacity of a treatment
plant or sewer line that serves future growth. In other words, treatment
facilities are usually sized to serve the existing population plus the
expected increase in population over the design life of the project. The
capacity included to serve this increase in population is called "reserve"
capacity.
In determining how much reserve capacity is to be built into a treatment
plant or interceptors, the selection of a planning period is very important.
Generally, the longer the period, the greater the amount of reserve capacity
designed into the system. EPA requires that the planning period be 20 years
for the cost-effectiveness analysis of waste treatment facilities. However,
it should be noted that the service life of a treatment plant is normally in
the range of 20 years while that of an interceptor is 30 to 50 years, (see
Cost-Effective Guidelines 40 CFR-Part 35).
The proposed treatment plant for the District has been sized to serve
the growth of the Initial Service Area (see Figure 1). The interceptors
have been sized to serve the ultimate (50 year) growth of the entire sewer
Service District. Table 2 shows the existing population for each area and
the design population for each component of the proposed project.
TABLE 2 EXISTING AND DESIGN POPULATION FOR THE PROPOSED PROJECT
Plan Component Existing Pop. Design Pop. Excess in Flow Capacity!
Treatment Plant 1650^4T8000.315 MGD
Interceptor 30003 20,000 1.7 MGD
- 1. Difference between existing population and design population
multiplied by 100 gpcd.
2. Population of Initial Service District.
3. Population of entire Service District.
The table indicates the extent to which the capacity is designed for
future flow requirements beyond existing service needs. The system capacity
is primarily designed to serve future growth and, in reality, its ultimate
effect is to permit and accommodate such growth. However, in terms of cost,
the cost of excess capacity is a small percentage of the total project cost.
For example, the additional cost of a 27" line would be 24 percent more than
the cost of 21" line, but a 27" line would provide for an increase in
capacity of 60 percent.
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12
CHAPTER TWO
ENVIRONMENTAL IMPACT OF THE PROPOSED PROJECT
Introduction
In describing the impact of the Redwood treatment facilities EPA
has divided its evaluation into three components: a description of exist-
ing environmental quality, an evaluation of primary impacts, and a dis-
cussion of secondary impacts. These are explained more fully within
each section.
The discussion in this chapter will center on the environmental
impacts of the proposed project, and Chapter 6 will contain the dis-
cussion of alternatives. However, to facilitate comparisons between the
proposed project and the alternatives, the text will contain footnotes
describing the relative environmental impact of an alternative and the
proposed project in terms of a specific environmental parameter. Not
all environmental impacts will be compared, but every area where there
is a major difference in relative impact between the proposed project
and an alternative will be discussed in a footnote.!/
The analysis of environmental impacts utilizes the Environmental
Evaluation System (EES) which was developed by Battelle-Columbus with
the aid of two field tests designed to make the system reflect the responses
of the real environment. The EES provides for environmental impact eval-
uations in 4 major categories: ecology, physical/chemical, aesthetics, and
social. These categories are further broken down into 19 components and
64 parameters. See Exhibit 2 in the Appendix for a full explanation of
the method.
The system is designed to produce environmental impact values in
numerical units, with the larger positive numbers indicating the least
adverse impacts. The important consideration in comparing the impact
values for each alternative is to consider the relative differences
between the existing value and the values produced by each alternative.
The larger the negative value, the greater the adverse impact of the
alternative. A positive value would indicate a beneficial effect.
Another important feature is the "red flags" that are produced.
These indicate that there are specific areas that are adversely impacted
and should be considered carefully.
]_/ Alternative "A" involves a two-phase project with a treatment plant
located at an interim site (intersection of Darnielle Lane and South
River Road) that initially serves only the eastern half of the Service
District.
Alternative "B" is a "do-nothing" proposal that would maintain the
status quo.
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13
The EES, as used in this impact statement, is intended to be a tool,
not the decision-maker. It has been used to systematically explore the
effects of each possibility from an environmental standpoint and point
up problem areas that should be considered in the overall evaluation.
Current Environmental Quality Conditions to be Affected by the Projectl/.
A. Water Quality
The water quality of the Rogue River, in the vicinity of the Service
District is generally good. Violations of water quality standards, when
they do occur, are naturally caused, usually by temperature and flow
changes.
There has been some evidence of the discharge of inadequately treated
sewage from failing subsurface disposal systems in the Service District.
To date, this has had no observable effect on the river, but continued
development on septic tanks and drainfields with subsequent failures in
the Initial Service Area could adversely affect Rogue River water quality.
B. Environmental Standards
Water quality and control standards in the State of Oregon have been
established by the Department of Environmental Quality. The general water
quality standards that apply to all waters of the state, the special water
quality standards adopted for all waters within the Rogue River Basin, and
the waste discharge permit requirements are summarized in Exhibit 4 in the
Appendix.I/ The proposed project is designed to meet these water quality
standards by providing "secondary treatment", which removes not less than
85% of all pollutants from the wastewater flow before discharging it into
the river. The effluent will also meet the basin requirements of 20 mg/1
of suspended solids.
2/ For a fuller description of existing environmental conditions see
Exhibit 3 in the Appendix.
3_/ The most important standards are as follows:
No wastes shall be discharged which will cause in the waters of
the Rogue River Basin:
1. Average concentrations of fecal coliform to exceed 1000
per 100 milliliters, except during periods of high surface
runoff.
2. Dissolved oxygen concentrations to be less than 90 percent
of saturation in spawning areas during spawning, incubation,
hatching, and fry stages of salmonid fishes.
3. pH values to fall outside the range of 7.0 to 8.5.
4. Any measurable increases in natural stream turbidities
when natural turbidities are less than 30 JTU, or more
than a 10 percent cumulative increase in natural stream
turbidities when stream turbidities are more than 30 JTU.
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14
Standards and rules for subsurface sewage disposal adopted pursuant to
the provisions of Chapter 835, Oregon Laws 1973 prescribe the requirements
for the construction, operation and maintenance of subsurface sewage dis-
posal systems and nonwater-carried waste disposal facilities and establish
procedures for regulation of such activities. They are for the purpose of
restoring and maintaining the quality of the public waters and of protecting
the public health and general welfare of the people. A copy of the new rules
may be obtained from DEQ.
In essence, they require written approval or a permit specifically
authorizing subsurface sewage disposal on the individual lot or land
parcel. The approval must be granted by an authorized agent of the county
or state and be in comformity with whatever rules were in effect when it
was issued. Since January, 1974, responsibility for the statewide septic
tank permit system has belonged to the Department of Environmental Quality.
C. Fish and Wildlife
The Rogue River supports an excellent fishery resource which includes
steelhead, sea-run cutthroat, Chinook and coho salmon, trout, and several
species of warm water game fish. Summer steelhead utilize Sand and Allen
Creeks within the District for spawning, and the main stem Rogue in the
area is used by winter steelhead, fall Chinook and coho salmon for spawning.
There is no evidence that the fishery resource has been affected by septic
tank and drainfield discharges, but the steelhead usage of Sand and Allen
Creeks has declined due to urbanization in the area, (see telephone memo,
Exhibit 5 in the Appendix).
The District and ultimate drainage area contain a wide range of wildlife
including the ring-tailed cat which is on Oregon's list of rare and endangered
mammaIs. ^
The American Osprey utilizes the shoreline of the Rogue adjacent to the
District as a feeding and resting area. The Osprey is on Oregon's list of
rare and endangered birds.
D. Soils
The predominant soil group within the District is Barren course sandy
loam which is primarily used for irrigated hay and pasture land. The soil
is not well suited to community development since it is easily saturated
and when combined with a shallow groundwater table as in the District,
precludes successful operation of septic tanks and drainfields.
E. Land Use Patterns
On April 27, 1971 the Josephine County Planning Commission adopted
the Comprehensive Plan for Josephine County 1970-1990. and in 1973 zoning
regulations were adopted. The Comprehensive Plan Map designated most of
the Service District as Farm Residential, which is described as follows:
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15
"Farm Residential areas (5 to 10 acres per dwelling unit) are intended
to encourage rural residential living in an agricultural or open
environmental through large lot size development that will minimize
conflict between residential and farm use and establish densities
consistent with soil suitability and physical characteristics.
Availability of community water and sewer services is very unlikely
in these areas." (Page 8 of Comprehensive Plan)
The next largest classification was Rural Residential which is described
as follows:
"Rural Residential areas (2% to 5 acre lots) are also intended to
encourage low density development in agricultural or open areas. The
smaller lot size reflects existing development patterns and soil
which is classified as fair in septic tank suitability. Community
services are not likely within the current planning period." (Page 8
of Comprehensive Plan)
The zoning regulations that were adopted in 1973 reflect the goals
and guidance of the Comprehensive Plan by zoning the Service District in
conformance with the Plan Map. The predominant zoning classification for
the Service District permits development on minimum five acre tracts of
land. However, the existing land use pattern is not entirely consistent
with the adopted zoning regulations. For purposes of discussion, the Service
District may be divided into two sectors; an eastern portion (that area
east of Darnielle Lane) that is fairly well developed and experiencing
severe problems with disposal systems, and a western portion (west of Darnielle
Lane) that is less densely developed with large lots and fewer sewage disposal
problems. The eastern portion of the District is developed to a much greater
density. This development occurred before the adoption of zoning regulations
in 1973. Within the eastern portion of the District the five acre minimum
lot size serves the purpose of limiting septic tank development rather than
the preservation of rural areas.
Within the western portion of the District, development has occurred
on a scale consistent with present zoning regulation. In this sector,
the minimum lot size serves two purposes; it preserves the rural character
of the area and it permits development on septic tanks only where enough
land is available to allow proper operation of a drainfield.
Most of the development in the District is residential, with some
commercial areas in the eastern sector.
F. Population and Growth Trends
The population of the Redwood Service District (3,480 acres) is
presently about 3,000. The county has projected an ultimate population
for the District of 20,000 to 23,000 people.4/ The District is expected
to grow due to its proximity to Grants Pass, the continued influx of
retired persons, and the area's residential attractiveness.
4/ EPA will require another population projection. (See Preface)
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16
6. Economic Conditions
The primary industry in Josephine County is wood products manufacturing.
Tourism and agriculture follow the timber industry in importance. Because
of its dependence on the volatile timber industry, the county economy is
generally unstable and subject to the fluctuations of the wood products
market. Presently, unemployment is around 20 percent.
The county has been making efforts to diversify and there has been
some success, particularly in the tourist industry.
There are no industries in the District, and it is probable that most
District workers, are employed outside of the District.
Primary Environmental Impacts of the Proposed Project
Primary environmental impacts refer to those impacts that can be
attributed directly to a project. In the case of the proposed Redwood
Treatment Facilities, these impacts relate to construction activities and
the direct impacts, beneficial and adverse, of continued operation of
the facilities.
The importance of considering primary environmental impacts is
obvious; they are the first to occur, and generally, are the most notice-
able (as opposed to secondary impacts which occur over a long period of
time with effects much more difficult to relate to the construction of
a particular project).
The primary environmental impacts of the proposed project will be
discussed under the four environmental categories utilized throughout
this report (Ecology, Physical/Chemical, Aesthetics, and Social), with
particular note taken of the parameters "red-flagged" during our inves-
tigations.
Table 3 is a summary of the environmental impacts associated with
the proposed project, and it lists the environmental components that are
"red-flagged" because of a significant impact upon them. A "minor" red-
flag is different from a "major" red-flag only in degree. That is, a
minor red-flag signifies a small change in environmental quality (negative)
while a major red-flag indicates a large environmental change in the
particular parameter.^/
5/ The Battelle report Planning Methodology for Water Quality Management
is available for review at EPA's Oregon Operations Office.The report
explains the EES in detail. EPA's evaluation worksheets are also
available for review. Exhibit 2 contains an abbreviated explanation
of the EES.
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Category
Component
ECOLOGY
Terrestrial Species
Aquatic Species
Terrestrial Habitats
Aquatic Habitats
PHYSICAL/CHEMICAL
Biochemical Water Quality
Chemical Water Quality
Physical Water Environment
Air Quality
Land Use
Noise Pollution
SUB -TOTAL
AESTHETICS
Land
Air
Water
Biota
Man-Make Structures
i— Composition
SOCIAL
Environmental Interests
Health and Safety
Community Wei -Being
SUB-TOTAL
TOTAL
* These numbers reflect the tote
but they do not depict positiv
basis. The proposed project (
effects on water quality, the
on community health. These pc
net effect of all parameters c
positive effects do exist, but
of the table.
TAULC 3 ENVIRONMENTAL ASSESSMENT OF Tll£ PROPOSED PROJECT
Environmental
Assessment in
Environmental Impact Units
With
, 1.69
4.20
1.28
3.0
4.62*
6.0 *
4.62
3.52
3.06
1.0
32.99
2.43*
1.77*
1.98
1.20
2.92
0.07
3.95*
4.5 *
3.19
22.01
55.0
1 environmental t
e environmental e
as well as Altern
aesthetic quality
sitive numbers do
f a component may
are not depicted
Without
4.2
4.59
3.23
3.0
4.62
6.0
4.62
3.52
6.95
1.75
42.48
2.96
2.31
1.98
3.37
3.28
0.56
3.95
6.0
4.59
29.0
71.48
npact on each compor
;fects on a paramet«
Live "A") does have
of the land and air
not show up becaust
be negative or zen
because of the linr
Assessment
Difference
-2.51
-0.39
-1.95
-0-
-0-
-0-
-0-
-0-
-3.89
-0.75
-9.49
-0.53
-0.54
-0-
-2.17
-0.36
-0.49
-0-
-1.50
-1.40
-6.99
-16.48
ent,
r
positive
, and
the
. The
tations
Number of Red-Flags ' •
Primary Impacts
Minor
-0-
-0-
-0-
-0-
-0-
-0-
1
-0-
-0-
4
5
1
-0-
-0-
-0-
1
-0-
-0-
1
-0-
3
8
Major
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
0
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
4
4
4
Secondary Impacts
Minor
1
1
3
-0-
-0-
-0-
-0-
-0-
2
-0-
7
1
1
-0-
1
-0-
1
-0-
-0-
-0-
4
10
Major
5
-0-
-0-
-0-
-0-
-0-
-0-
-0-
3
-0-
8
-0-
1
-0-
2
-0-
1
-0-
-0-
-0-
4
12
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18
The table includes secondary as well as primary environmental impacts
expected to result from the proposed project. Primary environmental
impacts are discussed below.!/
A. Impacts on the Ecology
This section discusses the impact of the proposed project on Ecology
which is composed of two basic structural components: (1) the living
organisms and (2) the nonliving environment in which these organisms live.
Table 3 utilizes four components to assess ecological quality: they
are Terrestial Species and Populations, Terrestial Habitats and Communities,
Aquatic Species and Populations, and Aquatic Habitats and Communities.
As Table 3 indicates none of the red-flags under the Ecology category
are associated with primary environmental impacts. The construction activities
and operation of the proposed project will not adversely affect, to any
significant degree, the environmental quality of the Redwood Service District
ecology. However, some mention should be made of the temporary effects
associated with the construction of the proposed project. These effects are
not of such a level so as to be red-flagged, but they will result in some
temporary impacts and should be explained.
Construction activities will affect a small amount of vegetation
within the Service District. Most of the sewers and interceptors will be
constructed in roadway right-of-ways, so there will be little, if any,
effect on vegetation along these routes. A substantial portion of the
Redwood Interceptor will not be constructed within roadway right-of-ways,
but will traverse private property from the terminus of Mesman Drive to
the treatment plant (distance approximately 15,000 feet). This portion
of the interceptor will disturb and destroy some vegetation, but since
the land is largely in pasture, the effect will be minimal. The interceptor
route (that portion that destroys the natural ground cover) will be
reseeded, replanted and landscaped!/
Construction of the sewage treatment plant will not directly result
in any significant effect on the ecology. A small amount of vegetation,
possibly some trees, will be destroyed but the effect is minimal.
Activities associated with construction (moving equipment, materials
and people) may have a temporary effect on wildlife within the District.
Noise, heavy equipment movement, etc. may frighten wildlife into avoiding
certain areas of the District. However, this would only be a temporary
effect.
6/ It should be noted that most of the discussion of the proposed project
and comparisons to Alternative "A" will center on the differences in
each alternative's adverse environmental impact. This occurs because
both plans have similar beneficial effects, in that each remedies
serious health hazards in the eastern half of the Service District and
permits residential development of the eastern sector pursuant to the
Comprehensive Plan.
7/ Under Alternative "A" (Phase One), roughly 7,000-8,000 feet of the Redwood
Interceptor would be laid outside of roadway riqht-of-ways. Under
Alternative "B" no interceptors would be constructed.
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19
Operation of the proposed facilities will have no primary effect upon
the ecology of the District or the surrounding environment. The discharge
from the proposed facility will not significantly affect aquatic species
or their habitats.
B. Impacts on Physical/Chemical
The Physical/Chemical impacts include effects on water quality, air
quality, land use, and noise levels, which are traditionally the only classes
of impacts considered in evaluating the environmental consequences of water
quality projects. This was the case because the main purpose of such projects
is to improve the physical/chemical quality of the natural physical environ-
ment. However, the mandate of the National Environmental Policy Act of 1969
requires a much broader consideration of potential environmental impacts,
one of which is physical/chemical.
A number of parameters under this heading will be affected during
construction of the proposed facilities. The general noise level of the
District will be increased during construction when the heavy machinery is
operated. Once the project is completed, noise levels will return to
their pre-construction levels. This parameter has been red-flagged, as
it is expected that the frequency and intensity of disturbing noise will
be increased temporarily in the Service District.^./
Also red-flagged under the Physical/Chemical category was the "physical
water environment" component. The minor red-flag indicated a small negative
change in the turbidity level of the Rogue River. During construction a
great deal of excavation will take place, and this may, during a rainfall,
contribute to soil erosion and a subsequent turbidity increase in the Rogue
River. The effect of this turbidity will be minimal since other water
quality parameters will remain unaffected and fish and other aquatic life
will be unharmed. After construction, when all trenches are refilled and
ground cover replaced, erosion and subsequent turbidity levels will return
to normal.
Most construction will probably take place during the dry season
so dust may be a problem. This can become a nuisance to local homeowners
unless control measures are undertaken. As with many other construction
impacts, dust problems will be of a temporary duration, and will be controlled
by preventative measures required by contract specifications.
8/ Alternative "A" will initially affect the noise level of only the
eastern half of the Service District. If the need for sewerage
service increases in the western half of the Service District
and sewers are constructed there, noise level increases will occur
where there is sewer construction.
Alternative "B" will have no effect on noise levels.
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20
Effluent discharge to the Rogue River will not significantly affect
water quality parameters, such as dissolved oxygen, fecal coliform, pH,
inorganic phosphate, and inorganic nitrogen. The effluent concentration
of the discharge will not exceed 20 mg/1 of BOD or suspended solids, and
the effluent will be disinfected to meet the water quality standards for
this section of the Rogue River and the requirements of the draft Rogue
Basin Plan. The discharge will not adversely affect the Rogue River Wild
and Scenic River Recreation Area located immediately west of the Service
District.
The operation of the treatment plant and sewering of the Initial
Service Area will alleviate a serious health hazard in that portion of
the Service District. Presently, partially treated sewage surfaces at
the Redwood School and Dun Rovin Trailer Park and constitutes a health
hazard to the children at the school and to the residents of the trailer
park. These, as well as other malfunctioning disposal systems within
the Initial Service Area, will be eliminated by the proposed project to
the substantial benefit of the citizens of the area.
By eliminating the malfunctioning septic tanks the proposed project
will likely contribute to improved groundwater quality. The Health Department
survey indicted that 24 percent of sampled domestic wells were contaminated.
This was most likely due to the location of shallow wells in the area of
a high groundwater table and malfunctioning septic tanks and drainfields
which combined to contaminate the supplies of some wells.
C. Impacts on Aesthetics
The use of aesthetics criteria in comparing different project actions1
has become necessary as society has become increasingly conscious of the
value of the natural environment and of the degree to which people's
activities may destroy the unique and beautiful things in nature.
For the purposes of this report overall aesthetic composition has
been considered as an aggregation of five elements: land, water, air,
biota, and man-made structures.
As shown in Table 3 two of the Aesthetic components have been
red-flagged under primary impacts, "Land" and "Man-Made Structures".
The surface configuration of a small portion of the Service District,
regardless of treatment plant location, will undergo some change as a
direct result of the construction of the sewage treatment plant and
interceptors. Along the Redwood Interceptor route, a few trees will be
cut and some surface vegetation destroyed. The trenches that are excavated
for the interceptor will be filled and the surface reseeded or replanted
in an effort to restore it to its preconstruction condition. The excavation
necessary for treatment plant construction also is temporary, since the
area will be regraded in an attempt to return it to a near-natural state.
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21
The other red-flagged component was "Man-Made Structures", which
evaluates the aesthetic effect of new project structures. The treatment
plant represents a change in the plant site where no man-made structure
presently exists (a farm house is nearby). The aesthetic effect of this
structure can be minimized by the use of landscaping techniques, but
the immediate area will never be the same.
The operation of the proposed facility will have one other effect
on the aesthetics of the Service District which has not been red-flagged
because of its intermittent nature, but should be mentioned. At one
time or another, most treatment plants cause odors. Generally, with
proper care and careful monitoring there will be no odor problem. However,
treatment plants are rarely perfect so it must be assumed that once in a
while an odor problem will occur. The nearest existing group of residences
is a mobile home court located approximately 100 feet west of the plant
site. The next closest residence is 450 feet away. These people, at the
times of odor, may be subject to some nuisance if an east wind blows.I/
Operation of the treatment facility will improve the aesthetic quality of
the eastern sector where sewerage service will eliminate the surfacing and
ponding of partially treated sewage. This improves the visual and olfactory
quality of the area.
Sludge, a frequent source of odors when handled improperly, will be
disposed of by land application upon agricultural lands after drying.
D. Social and Economic Impacts
Basically, social and economic aspects describe the effect of a
project upon people. Since the purpose of a water quality management
project is too improve certain environmental areas for the benefit of
people, it is appropriate to examine the adverse impacts as well.
The only primary impact that construction activities will have upon
social aspects of the community is the disruption of local traffic that
will occur during the excavation for the interceptor in roadway right-
of-ways. The disruption will be confined to locales experiencing
construction, and it will be temporary with no lasting effects on the
community.
The two components that were "red-flagged" under social aspects, are
"Health and Safety" and "Community Well-Being" and both relate to the
planning of the proposed.
9/ Alternative "A" would have a more significant primary impact on
aesthetics because it would be located in an area proximate to
residential dwellings.
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22
The minor red-flag that appears under "Health and Safety" results
from a determination of the treatment plant's level of compatability with
the surrounding environment. The area surrounding the proposed plant
site (EPA looked at an area of one-half mile radius with the site at the
center) is generally rural-residential in character, which is a type of
area faily well suited to treatment plan location. However, immediately
west of the proposed plant site is a mobile home park. It is probable
that the residents of the park would be affected by odors the plant may
produce and, possibly, by the actual aesthetic or psychological impact
of living adjacent to a sewage treatment plant.
Major red-flags appear under "Community Well-Being" and they reflect
adverse impacts from the planning process; lack of community involvement
and the reserve capacity to be provided in the treatment system.
Ideally, community participation would occur at the very beginning
of the planning process and citizens would be given the opportunity to
offer input at various stages, e.g., defining the scope of the problem,
alternative solutions, and selection of the best alternative. In the
case of the Redwood Service District the main instance of meaningful
citizen input was the bond election and the remonstrance hearing on
March 12, 1974. This permitted the Service District residents to accept
or reject one project (twice), and did not allow a choice of alternatives.
On behalf of the Josephine County Commissioners it may be said that much
of the planning of the Redwood project occurred at a time when there was
less interest or pressure for citizen participation (the planning of the
project began as early as 1966 when CH2 M prepared the first engineering
study).
With respect to the population served, it is important that a project
serve those who need to be served, and provide for those who will need
service during the project's service life. The proposed Redwood project
adequately serves the segment of the population that needs sewers (those
with failing individual disposal systems), but it is sized to serve a
great amount of future growth in undeveloped areas. The secondary impacts
associated with such reserve capacity are significant, and they are dis-
cussed on p.11.
The proposed project (and Alternative "A") will also have beneficial
effects on the social aspects of the District. Community health will be
improved within the eastern sector where sewerage service will be provided,
and the use of individual disposal eliminated.
Secondary Environmental Impacts of the Propose Project
Secondary environmental impacts are indirect or induced impacts that
may result from the construction and operation of the proposed project.
These impacts usually take the form of changed patterns of social and
economic activities, usch as changes in population densities and local
land uses. When such changes are significant they can effect water quality
and quantity, air quality, and the provision of public services. They
may also cause conflicts with local, state, and Federal resource use
objectives.
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23
Again it should be noted that the discussion will focus on adverse
impacts. EPA recognizes the substantial benefit the proposed project (and
Alternative "A") provide by eliminating a public health hazard and permitting
planned development according to the Comprehensive Plan of the eastern half
of the Service District. These benefits fall within all of the environmental
categories, but because both plans yield these positive effects environmental
comparisons must revolve around relative adverse impacts.
Table 3 will again be used, with specific reference to environmental
components that have been red-flagged by the EES. Again, it should be
emphasized that the EES is a tool used to pinpoint environmental areas
of concern and that it gives only a relative assessment of impacts.
A. Impacts on the Ecology
The secondary effects of the proposed project will have a significant
impact on the ecology of the area, particularly with respect to those
components red-flagged in Table 3.
The major impact on the ecology will be on terrestrial species within
the Service District. As the Service District develops, small game, browsers,
and grazers will be forced out or eliminated. Vegetation will undergo a
significant change as pasture land and wooded areas are eliminated in favor
of lawns, etc. As indicated by the red-flagging of terrestrial habitats,
this will make the Service District unsuitable for most of the wildlife
that is presently found there. Besides the loss of habitat area, the
increased number of people and increased level of noise will scare off
all but the most "human-tolerant" wildlife. This would result in a
decrease in species diversity.
Most of this impact will be felt in the western half of the Service
District which has a great deal of open space. The eastern half is more
densely developed so it is likely that the effect will be slightly
smaller there.
There may be some effect upon waterfowl in the area as human activity
levels increase. As waterfront development and usage increases it is
possible that some species, such as the American Osprey, will seek a more
peaceful habitat further downstream.
B. Impact on Physical/Chemical
Under this category of environmental parameters only one component
(land use) was red-flagged as experiencing significant secondary environ-
mental impacts resulting from the proposed project. These impacts relate
to population growth and changes in land use patterns.
For ease of discussion, the land use impacts will be described for
their effect upon the Initial Service Area and the western half of the
Service District.
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24
Initial Service Area: The Initial Service Area (shown in Figure 1)
is that portion of the entire Redwood Service District that the proposed
project will initially serve.W With the exception of the "arm" that
extends west of Darnielle Lane to the proposed treatment plant site,
the Initial Service Area exhibits a largely suburban land use pattern
(homes on less than 1 acre tracts). There are some large tracts of land
but they tend to be the exception.
The Initial Service Area is zoned predominantly for 5-acre residential,
with industrial and commercial zoning also existing.
When the proposed sewer facilities are installed, the Board of County
Commissioners has indicated that it will rezone a large part of the Initial
Service Area to permit densities from 3 to 6 units per acre (see Exhibit 6
in the Appendix). This area lies east of Willow and Shroeder Lanes and
south of the Redwood Highway.
Such an action would be responsive to the growth pressures that
would probably develop upon completion of sewer construct!'on.H/ The
provision of sewer service may cause additional growth pressure in the
sewered area since it is common for development to "take advantage"
of this public service. This would be particularly likely in the Redwood
area where growth is restricted by minimum lot size requirements for
septic tank development.
IP/ Alternative "A" (Phase One) would only serve that portion of the
Initial Service Area that is east of Darnielle Lane. The area that
Alternative "A" would serve has been designated as the Alternative
Service Area in Figure 2 (on page 5). It includes a portion of land
(between Darnielle Lane and Willow and Shroeder Lanes) that is not
designated by the Comprehensive Plan to be urbanized. Because of the
need for sewer service in this area and the need to provide service
to Rogue Community College the Darnielle Interceptor will be
constructed and sized in conformance with existing zoning densities
and projected growth.
I!/ The Board of Commissioners has indicated that the Comprehensive Plan
recommends that within eastern portion of the Service District a)
"until sewers are available, the future development should progress
in recognition of the poor soil conditions for proper septic tanks
installation, i.e., large-lot zoning should be used; b) once sewers
become available the Plan recommends that the maximum allowable
density of development be increased to allow 3-6 dwelling units per
acre." (see Exhibit 6 in Appendix)
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Growth within the Initial Service Area will not constitute a signi-
ficant environmental impact on land use for several reasons: one, the area
(east of Darnielle Lane) has already experienced considerable small-lot
residential development, two, the Board of Commissioners and the Compre-
hensive Plan indicate a desire for planned growth in most of this area upon
installation of sewers, and three, when sewers are installed the county
will adopt zoning regulations to direct and control growth in the area. 12/JJ/
Western Half of Service District: The western half of the Service
District is that area west of Darnielle Lane including the "arm" of the
Initial Service Area, (see no. 12) Existing land use patterns in this
area reflect rural residential living in an agricultural and open environment.
Lands in this area have been classified predominantly as Farm Residential
and zoned to allow development on minimum 5-zcre tracts. A few Rural
Residential areas have also been classified and zoned to allow development
on minimum 2.5 acre tracts. This is an area of small farms, producing
beef, lamb, poultry, hay, fruits, vegetables, and other agricultural
products.
Ultimately, the proposed project would probably result in full
development of the Service District: approximately 3 units per acre with
an ultimate population from 20,000 to 23,000 people. 14/
12/ This discussion excludes the "arm" of the Initial Service Area which
lies west of Darnielle Lane because it contains almost entirely large-
lot development (at least 5-acre tracts), and is not included in the
Comprehensive Plan's recommendations for urbanization of the eastern
half of the entire Service District. The environmental impact on the
"arm" will be discussed below under impacts on the western half of
the Service District. The area of land between Darnielle Lane and
Willow and Schroeder Lanes is not designated for urbanization by the
Comprehensive Plan.
13/ Alternative "A" which initially serves only the eastern half of the
Service District, would have no significant environmental impact on
land use in the Alternative Service Area (that area east of Darnielle
Lane as shown on Figure 1), for the same reasons listed for the pro-
posed project.
Alternative "B" would have an effect on land use in the eastern sector
since minimum lot size restrictions would have to be maintained
contrary to Comprehensive Plan recommendations.
14/ This is the projection made by Ch^M and supported by the Patterson,
Langford, and Stewart estimates (see Exhibit 1 in Appendix). The
timing of this growth is open to question, but the county has relied
on its engineer's estimates which project Service District saturation
by 2025 and within the service life of the sewerage system. As noted
earlier EPA will require an updated population projection, (see Preface)
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26
The availability of sewers, particularly the Redwood Interceptor,
could provide an incentive for residential development within the western
half of the Service District before the eastern sector is fully developed.
It is likely that property values will increase as sewers become available
offering landowners increased incentive to attempt to subdivide and develop
their rural property for residential use. 15/ Whether this occurs is
dependent on individual landowner preference. Should the county begin to
levy sewer assessments in the western half of the Service District it is
possible that individual landowners would be financially forced to sell
or attempt subdivision of their property to pay the assessment. 16/
Residential development within the western sector will represent
a significant change in land use. Existing land use patterns establish
a rural character for the area which is the use and character that the
Comprehensive Plan designates for the western portion of the Service
District. The zoning of the area implements the goals of the Plan by
designating most of the sector for 5-acre minimum lot sizes.
Although the rate and type of development that occurs will be largely
determined by individual landowner preference and county land use policies,
the constructuon of sewers can play a substantial part in inducing
residential growth. The proposed project provides for residential
development of the entire Service District which would be inconsistent
with existing land use, zoning, and planning goals for the western
sector, llf The population inducement pressure of the sewer will also
depend on its financial impact on land-owners, particularly if the county
begins to levy assessments (when people begin connecting to the sewer)
that were deferred by way of a county loan, (see n. 16)
15/ Property taxes for individual land-owners may or may not increase
depending on the owner's use of the land. Pursuant to ORS 215.203
and 308.370(2) a piece of land may be taxed at its farm use value even
though surrounding land uses are residential, commercial, or industrial,
if the land is farmed for a profit. Thus, within the Service District,
land-owners who qualify and apply for this special assessment would
be unaffected by an increase in property value for residential use.
Non-qualifying, large-lot landowners may face property tax increases
that provide a substantial incentive for sale or subdivision of the
property.
16/ The county has indicated that it will make a loan to the Service
District to defer assessment payments by property-owners within the
"arm" of the Initial Service Area. Loans will be repaid only when
people connect to the sewer. Extensions of sewers and connection
thereto are governed by county regulations, (see Exhibit 7)
17J Alternative "A" would not provide for growth within the western sector
of the Service District until growth pressure dictated the need for
sewer extension and the county amended the Comprehensive Plan. No
financial impact would be expected on western sector residents, and,
hence, no growth pressure in that area would be expected to result
from construction of Alternative "A" (Phase One). (Cont. P. 27)
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27
C. Impact on Aesthetics
Secondary impacts associated with the proposed project will also affect
the aesthetic character of the Redwood Service District. Red-flags in Table
3 appear under the Land, Air, Biota, and Composition components.
The increased development permitted by the proposed project will
have an effect upon the appearance of the land. It is expected, with
the larger numbers of people, that the amount of roadside litter and
other trash will increase slightly to the detriment of the aesthetic
quality of the area. A diligent clean-up program, public or private, could
minimize the adverse environmental impact of litter and trash.
The aesthetic air quality (odor, visual, and sound) will be impacted
by the increased development of the Service District. The pleasant smells
associated with rural areas (such as freshly cut hay) will be replaced by
the more neutral smells of residential areas. Likewise, the types of sounds
associated wtih rural areas (wind in the trees and grassy fields, birds, etc.)
will be replaced by automobile noises and other sounds associated with
residential development.
The Biota component was also red-flagged because of the expected loss
of native vegetation and wildlife. As mentioned earlier it is anticipated
that the number of animals and animal species will decrease within the
Service District as it develops. Likewise, native vegetation will be
replaced by suburban-type ground-cover.
The composition component is a general "aesthetic quality" indicator
in that it measures the aesthetic quality of an area by looking at all
aesthetic parameters together. EPA has assumed that an area with open
space, pasture land, and a range of wildlife is more aesthetically pleasing
than a residential area (others may differ with that assumption). Thus,
the proposed project, and its consequent secondary impacts, lowers the
general aesthetic value of the western sector of the Service District, but
does not have as great an effect on the eastern sector because it currently
contains a large amount of residential development.
D. Energy Commission
Table 4 below summarizes the effects of developing the Redwood Service
District on energy consumption. Energy consumption levels have been
estimated on an annual basis.
It is estimated that the annual consumption of energy in the Service
District will increase from approximately 400 billion BTU's in 1974 to 1000
billion BTU's in 1995 to 3100 billion BTU's per year in 2025.
17/ Alternative "B" would only allow limited growth in the entire Service
District. Homebuilders would have to meet minimum lot size requirements,
and it is unlikely that existing zoning would change.
Sewer extension, connection thereto, and rezoning all will occur pursuant
to existing county procedures. These procedures may mitigate some of the
adverse land use impacts of the proposed project, (see Exhibit 7)
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TABLE 4
ANNUAL CONSUMPTION OF ENERGY IN THE REDWOOD SERVICE DISTRICT
1974 1995 2025
Usuage Billion BTU's Billion BTU's Billion BTU's
Home
Auto
Total Billion
BTU's per year
235.5
170.5
406.0
610
442
1,052
1844
1335
3179
The numbers on energy consumption that appear in Table 4 are based
on an increasing population occurring in an area of a low density residential
development pattern. The same population occurring in an area of planned
development utilizing high density multiple family units or cluster type
development would not consume so much energy. Differences in energy con-
sumption between patterns are accounted for by differences in automobile
miles driven (lower in high density development) and lower energy use in
multiple family units.
18/ Alternative "A" will result in lower energy consumption through the
first 20 years of its service life (Phase One) because it anticipates
a higher density development pattern within the eastern sector. If
both phases were constructed with the same densities as the proposed
project resulting, energy consumption would be approximately 3100
BTU's, the same as for the proposed project.
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CHAPTER THREE
ADVERSE IMPACTS WHICH CANNOT BE AVOIDED SHOULD THE PROPOSAL BE IMPLEMENTED^/
The normal construction-related impacts of increased noise levels, dust,
interruption of some street traffic, and disruption of existing plant, animal,
and soil communities are adverse and generally unavoidable. They are temporary
adverse impacts, however, and can be mitigated by contract specifications con-
sidering all local, state, and federal requirements.
The aesthetic quality of the area, itself, will be disrupted for a short
duration during construction and then during rehabilitation of the disturbed
landscape. Excavating, filling, and reqrading in the vicinity of the pipeline
corridors will aesthetically impact the area. These adverse visual impacts,
however, will be brief, as the areas required for rights-of-way will be restored
to as near their original state as possible after construction is completed.
Excavations exposing earth will result in some soil erosion and some
siltation entering the Rogue River, but strict adherence to contract specifi-
cations regarding erosion and sedimentation control will minimize these effects
of construction on water quality. Four stream crossings—Sparrow Hawk Creek,
Sand Creek, Darnielle Creek, and Wineteer Creek—will necessitate diversion
of normal stream flows. Provisions have been made in the contract documents
for bypassing these natural flows without reduction, so the life cycle of
aquatic organisms should not be significantly affected.
Ideally, a sewage treatment plant should be located away from residential
areas, or, if it is located in the proximity of residential areas, it should
be carefully screened by trees and plants, and the site should be landscaped
to be consistent with the existing surface configuration. The proposed plant
will be located next to a mobile home court so it may have a small adverse
aesthetic impact, but if it is carefully screened and landscaped the effect
could be minimized.
Several irrigation crossings will also be required. If construction
schedules cannot be undertaken during the nonirrigation season, then con-
struction will be conducted in a manner acceptable to the owner of the
irrigation system, in order to avoid unauthorized interruption of irrigation
service in the area.
19/ These impacts do not differ for Alternative "A" except the "A" may
have a greater primary impact on aesthetics because the treatment
plant is located in a more developed area.
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The secondary impacts, discussed previously, cannot be avoided altogether.
The proposed project will have a long-term environmental impact upon land
resources in the Service District, since it will induce or permit population
growth and is, in fact, designed to accommodate suburban development of a
farm-rural residential area and to intensify development of currently developed
areas. This accelerated growth and development could lead to unavoidable
impacts normally associated with suburbanization—increased noise and con-
gestion, greater air and water pollution, and ecosystem and habitat destruction
and disruption./n/
20/ Alternative "A" will avoid some of the impacts because the growth it
will permit will be consistent with and directed by the Comprehensive
Plan; that is, concentrated in the eastern sector until growth
pressures and the Comprehensive Plan dictate otherwise.
Alternative "B" will not have these impacts because no such growth
would occur. However, Alternative "B" would not provide a solution
to the failing septic tanks and drainfields that are creating a
health hazard in the Service District.
It should be noted that certain county zoning procedures may mitigate
some of the adverse effects of the proposed project, (see n.17).
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CHAPTER FOUR
RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF THE ENVIRONMENT AND THE
MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY
The long-term impacts created by the proposed project will be both
beneficial and adverse in nature, enhancing or reducing certain elements
of the area's environment for future generations. Water quality within the
Service District, for example, will improve as a result of the proposed
action:
1. Quality of the surface and groundwaters will be enhanced due
to the elimination of pollution sources, primarily failing
septic tanks.
2. Health hazards posed by malfunctioning septic tank/drainfield
systems in the Initial Service Area will be alleviated.
3. The quality of the Rogue River will be enhanced due to the
discharge of a high quality effluent from the treatment
plant, and elimination of partially treated waste discharges.
4. The quality of water supplies from wells will be improved.
On the other hand, the availability of sewerage facilities will stimulate
population growth and suburban development leading to increased waste loads
from storm water runoff, which may, to some extent, offset the improvements
in water quality in the Rogue River.
The provision of an adequate wastewater collection and treatment system
will exert an influence on land use development in the future, which will
probably reduce the range of uses associated with the land resources of the
Redwood Service District. The project will provide needed sewer service
in the eastern sector, and will allow "planned-for" expansion in that area.
To many people it may be beneficial to construct houses over the entire
Service District, but premature development limits the future options for
land use.2V The character of the area will change from rural to urban as
intensive land uses replace existing land uses. The small family farms
will be replaced by single family homes. Existing agricultural, open and
vacant, and forested areas will be lost due to the utilization of these
lands for urban purposes. The production of agricultural products (mostly
for home use) will also decrease. Thus, the long-term quality of the
environment and the potential productivity of much of the Service District
would be diminished by the resultant growth and development, should it
occur prematurely in the western sector.
21/ Clearly, where there are no people to move into an area, the land will
remain undeveloped, but Josephine County is going to grow. There will
be a strong incentive, even necessity, to go where sewers have been
constructed, as will occur in the Redwood Service District.
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CHAPTER FIVE
IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES WHICH WOULD BE
INVOLVED IN THE PROPOSED ACTION SHOULD IT BE IMPLEMENTED
Certain irreversible resource commitments--such as permanently
committing land, construction materials, and biological, human, economic
and aesthetic resources--will be involved in the construction and operation
of the proposed sewerage facilities for the Redwood Service District.
The major resource commitments will be construction materials and
land. The required concrete pipe, steels, lumber, clay and asbestos
compounds and other materials for construction of the structures will
be irretrievably committed to the proposed use. The time and energy
required to construct the facility and operate it are also irreversible
commitments. In their entirety, the construction and use of the sewerage
facilities are irreversible due to the large commitment of renewable and
nonrenewable resources involved, which makes removal or non-use of the
physical facilities unlikely.
The land necessary for the treatment plant site will prevent any other
significant uses for the life of the project. The destruction or disruption
of soil and plant communities along the proposed pipeline corridors will
not be entirely irreversible. After construction, the corridors will
be restored and replanted with native vegetation or could even be utilized
for agricultural purposes or open space.
The population growth and development associated with providing an
adequate wastewater treatment and collection system must be considered
irreversible. As the Redwood Service District becomes more developed,
the farmlands, open spaces, and forested areas will be irreversibly lost.
There will also be an irreversible loss of rural aesthetics connected
with this urbanization process. The present rural character of the area
will be altered as a consequence of suburban development. 221
The proposed project will also commit future generations to an
irreversible approach to water quality management in the sewerage area.
221 Alternative "A" (Phase One) would not have an effect on the land use
pattern and character of the wester half of the Service District.
Suburban-type growth would be limited to the eastern sector as specified
in the Comprehensive Plan, until development pressures, if any, required
extension of sewers to the western sector.
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CHAPTER SIX
ALTERNATIVES TO THE PROPOSED PROJECT
Four alternatives were identified by the engineering consultants and
summarized in the applicant's environmental assessment statement. Due to
further study and receipt of comments from various interested agencies,
groups and individuals, the alternatives have been narrowed considerably.
The two District alternatives under consideration in the environmental
impact statement are listed below. Their distinguishing features and
environmental and energy impacts are described.* Table 6 is a summary
of the environmental impacts of the alternatives, including the proposed
project.
Alternative "A"
An interim activated sludge plant (0.50 mgd) and sewage collection
system to initially serve the eastern half of the Redwood Service
District with effluent disposal to the Rogue River. A second
phase of the project would be to abandon the interim plant and
construct a treatment plant at the "proposed project" plant
site at the west end of the Service District, when and if growth
and the Comprehensive Plan dictated. (It is entirely possible that
it would not have to be moved).
This alternative would initially serve approximately 1,550 people and
1,310 acres of land—that portion of the Redwood Service District, as
shown in Figure 2, located north of the Redwood Highway, east of Darnielle
and Hubbard Lanes, and a portion of the District south of the Redwood Highway
which borders Allen Creek Road. This portion of the District is essentially
the same as the Initial Service Area except for the "arm" to the west along
the Rogue River which is excluded.
Alternative "A" proposes construction of those facilities needed: 1) to
solve existing waste disposal problems; 2) to alleviate a public health
hazard posed by malfunctioning on-lot septic systems in the area; 3) provide
positive protection of water quality in the Rogue River; and 4) provide
adequate excess capacity to accommodate growth pursuant to the Comprehensive
Plan.
Alternative "A" consists of the following major features:
1. An interim activated sludge plant located near the intersection
of Darnielle Lane and South River Road—approximately 1.7 miles
east of the plant site for the proposed project.
2. The proposed sewage treatment plant would adequately serve a
projected 1995 equivalent population of 4,800 persons. Nominal
average flow capacity of the plant would be about 0.50 mgd.
* The EIS considers only the activated sludge method of sewage treatment.
Other methods were evaluated by the District's engineer in the pre-
liminary engineering report (CH2M, 1966). The selected method meets
the requirements and goals of state water quality standards while
being more cost-effective than extended aeration, and less demanding
of land resources than lagoons.
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34
3. The plant would provide a reduction of not less than 85%
of BOD and Suspended Solids and produce an effluent which meets
effluent requiements and water quality standards for the Rogue
River.
4. Gravity interceptors, including the Redwood Interceptor
15,000 feet long (ranging in size from 12" to 21"); the Willow
Interceptor 6,300 feet long, (10" to 12" in size); and the
Darnielle Interceptor 9,600 feet long (12" in size). With
a service life of 50 years (2025) these interceptors would be
designed to serve 9,000 people and 1,310 acres.
5. When the growth potential of the eastern sector is near
realization, and if the Comprehensive Plan has been changed to
provide for urbanization of the western sector, a new expanded
treatment plant could be constructed at the "proposed project"
plant site subject to consideration of other feasible alternatives
at the time. The Redwood Interceptor would be extended from the
abandoned interim plant site to the new plant.
Table 5 below indicates the design criteria used for the treatment
plant and interceptors, which are the same as those used for the proposed
project.
TABLE 5
DESIGN CRITERIA FOR ALTERNATIVE "A"
Facility
Component Design Population Design Flow Design Period
Treatment Plant 4,800 0.50 MGD 20 years
Interceptors 9,000l/ 3.54 50 years
iy Based on expected saturation (3 units per developable acre-3 people
per unit) of the Alternative Service Area.
The interceptor configuration would remain the same as the one for
the proposed project with the Willow and Darnielle trunks feeding to the
Redwood Interceptor .ll/ The basic difference is that the plant site has been
moved east to an interim site and all lines will be sized only to accommodate
growth in the Alternative Service Area. (1310 acres) (see Fig. 4).
23/ The Darnielle Interceptor, which serves an area that is not designated for
urbanization by the Comprehensive Plan, would be sized to serve Rogue
Community College and the growth that is projected to occur in conform-
ance with the plan and existing zoning. The Darnielle Interceptor is
necessary to eliminate use of failing septic tank/drainfields, and
eliminate the package plant at the Community College.
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TABLE 6
SUMMARY OF ENVIRONMENTAL IMPACTS OF THE MAJOR ALTERNATIVES,
INCLUDING THE PROPOSED PROJECT
Project
Alt. "A"
Alt.
— — - - ' - -_
Category Environmental Assessment
in Environmental Impact
- Component Units
ECOLOGY
Terrestrial Species 1.69
Aquatic Species 4.20
Terrestrial Habitats 1.28
Aquatic Habitats 3.0
PHYSICAL/CHEMICAL
Biochemical Water Quality 4.62
Chemical Water Quality 6.0
Physical Water Environment 4.62
Air Quality 3.52
Land Use 3.06
Noise Pollution 1.0
1. SUBTOTAL 32.99
AESTHETICS
Land 2.43
Air 1.77
Water 1.98
Biota 1.20
Man-Made Structures 2.92
Composition .07
SOCIAL
Environmental Interests 3.95
Health and Safety 4.5
Community Well-Being 3.19
2. SUBTOTAL 22.01
TOTAL (1 and 2) 55.0
TOTAL
Number of Red Flags
Minor Major
1
1
3
1
2
4
12
2
1
1
1
1
1
7
19
5
3
8
1
2
1
4
8
16
Environmental Assessment
In Environmental Impact
Unitsl.
1.69 (3.71)
4.20
1.28 (2.64)
3.0
4.62
6.0
4.62
3.52
3.06 (5.35)
1.0 (1.36
32.99(39.02)
2.43 (2.96)
1.77 (2.31)
1.98 (4.8)
1.20 (3.37)
2.92 (3.28)
.07 ( .56)
3.95
4.5 (6.0)
3.19 (4.2)
22.01(31.43)
55.0 (70.45)
TOTAL
Number of Red Flags
Minor Major
1
1
3 (1)
1
2 (1)
4 (2)
12 (7)
2
1
1
1
1
1
7
19 (7)
5 (2)
3 (2)
8 (4)
1
2
1
4 (2)
8 (2)
16 (6)
Environmental Assessment
in Environmental Impact
Units
4.2
4.59
3.23
3.0
4.62
6.0
4.62
3.52
6,95
1.75
42.48
2.96
2.31
4.8
3.37
3.28
.56
3.95
5.61
4.59
31.43
73.91
1. Numbers In parentheses are the expected impact units if Alternative "A" does not expand into the western sector of the Service District.
The lower environmental effects (as shown by higher numbers) reflect the lack of secondary impacts in the western sector. As is shown
(by numbers not in parentheses), if Alternative "A" does expand, its total environmental effect is the same as the proposed project.
2. There are no red-flags for Alternative "B" because it maintains the status quo, i.e., there is no environmental change. The eastern
sector will continue to experience surfacing sewage and its associated adverse effects.
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A cost analysis for Alternative "A" is outlined below. The analysis
is based on a two-phase project and the need for a 0.50 million gallon per
day sewage treatment interceptor facilities to serve the Phase-One
needs (20 years). It should be noted that Phase Two abandonment and
relocation of the treatment plant may never take^place because all pro-
jected residential growth could be accommodated within the eastern sector.
1. CAPITAL COSTS Phase I
Secondary Treatment Plant
Redwood Interceptor
Phase III/ Present Worth
Willow Interceptor
Darnielle Interceptor
Total
2. OPERATING & MAINTENANCE COSTS
Treatment plant and Interceptors
Delay & Additional Engineering
Total Present Worth
$ 839,000
529,800
198,600
307,200
$1,093,000(STP)
513,300
$1,874,600 $1,606,300
62,800/year
77,300
193,700
$ 839,000
282,400
529,800
132,600
198,600
307.200
$2,289,600
665,300
818,900
193,700
3,967,500
J/_ The timing of Phase Two is unknown but for the purpose of cost analysis
and comparison it is assumed to begin at the end of the Phase One
cost-effective period of 20 years. If it were to occur later or not
at all, it is possible that these costs would be substantially lowered.
Environmental and Energy Impacts
Primary environmental impacts associated with Alternative "A" -
would be the same as those for the proposed project except that
Alternative "A" primary environmental impacts resulting from the
construction of the treatment plant and the Redwood Interceptor
would occur in two phases. The first phase would involve construction
of an interim treatment plant and sewers in the eastern half of the
Service District (the Alternative Service Area). The second phase,
occurring 20 or more years later, would involve construction of the
ultimate treatment plant at the west end of the Service District,
and extension of the Redwood Interceptor, assummirg growth and the
Comprehensive Plan so require. It is entirely possible (and consistent
with the Comprehensive Plan) that all of the projected 50 year growth for
the Service District could be accommodated within the eastern sector at
a density of 6 units per acre, (that area east of Willow and Shroeder
Lanes and south of the Redwood Highway).
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Existing water pollution problems in the Service District would be
eliminated, including the discharge of raw wastes into the Rogue River.
Existing health hazards associated with failing septic tanks would also
be eliminated. The discharge from the Redwood School (probably the most
objectionable instance of failure) would be eliminated. The plan would
also pick up the waste flows from the Rogue Community College and River
Haven Mobile Estates, which are presently served by small package plants.
Since this alternative does not initially contemplate service to the
western portion of the Service District, secondary environmental impacts
will be largely limited to the Alternative Service Area. These would occur
as the result of residential development permitted by the construction of
the treatment facilities. The secondary impacts of this alternative would
be identical to the environmental effects that the proposed project has on
the eastern portion of the Sanitary District, except that development of the
area between Darnielle Lane and Willow and Shroeder Lanes would occur
according to the Comprehensive Plan.
Assuming that the Alternative Service Area growth potential was near
realization and that the Comprehensive Plan was amended to permit develop-
ment of the western sector, Phase Two of Alternative "A" could commence.
With the shift of the treatment plant and extension of 'the Redwood Inter-
ceptor and other sewers, secondary impacts would begin occurring in the
western half of the Service District. These impacts would be associated
with residential growth and would be comparable to the impacts of the
proposed project but occurring in a different time frame, (see Table 6)
The primary advantages of Alternative "A" is that it provides for ordered
growth of the Service District consistent with the existing Comprehensive
Plan; it allows the western sector to maintain its rural character without
the risk of premature development.
Alternative "A" provides capacity for at least the 20 year growth
of the Service District while contributing to the orderly development of
the eastern sector pursuant to the Comprehensive Plan. It does not place
the potential development pressure on the western sector that might occur
with the extension of sewers to that area. The area would maintain its
farm residential character until the Comprehensive Plan is changed and
growth pressures are sufficient to develop it. 24/
24/ County zoning and sewer development procedures may mitigate these
adverse impacts on land use caused by the proposed project, (see
Exhibit 7)
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38
Table 7 shows the projected energy consumption associated with
Alternative "A" (the proposed project and Alternative "B" are shown for
comparison). As the Table indicates, Alternative "A" will result in lower
energy consumption than the proposed project over a 20 year period.Is/
This is strictly a function of the population of the area—more people
means more homes, more automobiles and, thus, more fuel consumption.
Alternative "A" and the proposed project are based on, the same develop-
ment pattern—low density sprawl. This pattern has already occurred
in the eastern portion of the Service District, but it has not developed
in the western portion. Alternative "A" gives the county some future
options as to the type of development that will be allowed to occur,
if at all, in the western sector. The result may be more "energy-
efficient" than permitting low density sprawl development to occur.
TABLE 7
SUMMARY OF ENERGY CONSUMPTION OF THE MAJOR ALTERNATIVES,
INCLUDING THE PROPOSED PROJECT
Usage
Home
Auto
Total Billion
BTU's per year
Proposed
Project
610
442
1052
Alt. "A"
471
_34T_
812
Alt. "B"
311
_225
536
Proposed
Project
1844
1331
3179
Alt. "A"
1844
J131
3179
Alt. "B"
334
242
576
Alternative "B
im n
No-Action-Continued Utilization of Individual Source Treatment
Systems (Septic Tanks and On-Site Packaged Treatment Plants)
25/ Assumming the ultimate population for the entire Service District is
reached, the 50 year energy consumption levels will be the same.
However, this assumption is open to question because the Comprehensive
Plan does not presently project urbanization of the entire Service
District and it is possible that in the interim before sewers are
extended to the west the county may choose to direct growth elsewhere.
-------
39
A number of individual source treatment systems could potentially be
utilized within the Redwood Service District. This alternative considers
the use of septic tanks throughout much of the area as a technically
feasible alternative to the construction of an extensive sanitary sewer
system, thereby eliminating the need for the proposed project or other
alternatives. Land use controls and conformance to state subsurface
disposal regulations would be necessary, however, to create a properly
functioning septic tank/drainfield system.
Properly sited, constructed, and maintained septic tanks and drain-
fields would allow limited growth to take place within the Service
District without creating an additional waste load burden on the Rogue
River, if certain conditions were met. These conditions would include:
1. Controlled use of septic tanks in suitable areas. Large portions
of the Service District are suitable for septic tank disposal and
treatment facilities, if growth is controlled and development den-
sities are not allowed to exceed certain limits.
2. A strict enforcement program to control and monitor the periodic
pumping of septic tank waste from failing septic systems. Such a
program would insure that (a) septic tank wastes are discharged
into a collection system for conveyance to a plant; (b) payment is
made for such treatment; (c) discharge of septic tank waste into
streams or on land is prohibited; and (d) a record of failing septic
tanks is developed to provide an adequate data base for judging
performance and to justify the need of future service extensions.
3. It should be noted that some areas of the Service District
(particularly in the eastern sector) are not capable of permitting
effective operation of septic tanks and drainfields. The combination
of poor soils and a high groundwater table causes system failures
regardless of the corrective measures taken, short of abandonment
and connection to a sewerage system. Within the eastern sector of
the Service District, there are only a few areas where septic tanks
and drainfields can work, and in these areas the main reason they
are successful is because they are located on large lots. Most
of the eastern sector has been developed on lots of less than one
acre (this is only 20 percent of the minimum lot size now recommended
in the area for septic tank and drainfield development), and there
is no way to make the individual systems work properly.
Another possible individual source treatment system would involve
on-site packaged treatment plants, treating sanitary wastes at each home
or within neighborhoods. Although advanced waste treatment facilities
are available in inexpensive packaged units ($2,000 to more than $10,000),
it is not considered to be feasible to solve the existing and expected
problems of the Redwood Service District with such facilities. The many
point sources produced by a multiplicity of small package wastewater
treatment plants scattered throughout the area operated by a variety of
individuals and different organizations, often without proper training
and supervision, would be contrary to present state policies and regulations,
and would be expected to result in continued water pollution and health
hazards. It is apparent that the eastern sector of the Service District
needs sewers.
-------
40
Environmental Impacts
Within the Redwood Service District, septic tanks are the predominant
form of sewage treatment facilities. In the eastern portion the density
of development has, however, exceeded the assimilative capacity of the land
resources, primarily due to the lack of land use controls and the construction
of a majority of the septic tank and drainfield systems in unsuitable sites.
Degradation of surface water quality and groundwater has resulted. Adverse
impacts upon the physical environment would continue to occur in the eastern
portion until the presently improperly sited septic tanks and drainfields
were phased out of use.
This alternative would cause limitations to be imposed upon the types
and locations of growth and development. Controlled use of septic tanks and
drainfields in suitable areas may ease the demand for sanitary sewers, which
in turn, would also enable the land use conflicts within the Service District
(especially the western portion) to be resolved before irreversible resource
commitments occur and form the basis for future land use patterns. It
should be noted that the Service District will continue to develop regardless
of whether the project is built, although it will be slower growth and the
densities will be much less, but people will continue to settle in the
Service District.
Depending on the physical conditions such as high groundwater table,
soil limitations, and poor drainage, there is a significant potential
for the health hazard problem to become more pronounced. Widespread
failures of subsurface disposal systems would also lead to aesthetically
unappealing sights and odors and adverse socio-economic impacts.
-------
41
CHAPTER SEVEN
COMMENTS AND RESPONSES TO THE DRAFT EIS
This section contains letters of comments from individuals and groups
to the Redwood Sanitary District draft EIS. Those letters which commented
directly upon the draft EIS have been reproduced in this document. Wherever
a response is required of EPA to the letter, a response page follows that
letter.
The following table is a listing of the comment letters received, the
page in this chapter on which they can be found, and a general category
listing of their contents. Comment categories are shown in an attempt
to indicate those aspects of the proposed action about which the commentors
were most interested and concerned. This may serve to direct the interested
reader to those sections of the document which he may wish to restudy.
In addition to those letters which comment on specific areas within the
draft EIS, EPA received numerous letters voicing opinions on the project.
Because these letters do not directly comment upon the draft statement nor
do they require a response from EPA, they are not reproduced in this docu-
ment. A listing, however, is included in table form which separates letters
into categories of support or opposition to the Redwood Sewer Project. We
have attempted to point out areas with which these letters were most con-
cerned. A brief summarization of the issues raised most frequently has
been included after the table of comments.
On July 15, 1975 at the Josephine County Fairgrounds, EPA held a
public hearing on the Redwood draft EIS. The hearing was attended by
approximately 200 people of which 31 read testimony into the official record.
Because of the length of the official hearing record and the costs involved,
we have not reproduced the document for the final EIS. A table is provided,
however, listing the speakers, their support or opposition to the project,
and the areas in which they were most concerned. The Public Hearing Record
is available for public scrutiny at the Josephine County Library, Grants
Pass, Oregon; EPA's Oregon Operation Office, Portland, Oregon; and EPA's
Region X Office, Seattle, Washington.
Many petitions, form letters, postcards and newspapers coupons that
merely express support or opposition to the project have been received
by EPA. Because these submittals do not raise any issues that require a
response by EPA they have not been included in this final statement. They
are also on file in EPA's Region X office and available for review.
The Environmental Protection Agency Region X wishes to express its
appreciation to all commenting agencies, groups and individuals for the
time and effort spent in reviewing the draft EIS. All comments were presented
to the Regional Administrator and were considered by him in EPA's decision
making process.
-------
Date
iceived
1975
7/23
7/25
7/28
6/30
7/15
8/1
8/13
7/25
8/4
7/31
7/21
i
TABLE 8
COMMENTS RECEIVED ON DRAFT ENVIRONME
IMPACT STATEMENT
- 42 -
From
U.S. Department of Soil
Conservation SErvice P. 45
Department of the Army
Corp of Engineers-Portland
U.S. Department of Interior
Pacific N.W. Region P. 52
Advisory Counsil on Historic
Preservation P. 62
Department of Housing and
Urban Development P. 64
Oregon State Department of
Environmental Quality P. 67
Oregon State Executive Department
(Intergovernmental Relations Div.)
Josephine County Department
of Roads P. 80
Oregon Studen Public Interest
Research Group (OSPIRG) P. 90
Redwood Area Citizens
Association P. 94
Signe M. Carlson P. 96
:NTAL
GENERAL
TONE
Informative
No comment
Informative
Informative
Informative
Supports
Propose Project
General
Supports Propos
Proj. Informati
Critical of
Proposed Projec
Critical of
Proposed Projec
Critical
0)
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O
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Ol
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'Wildlife
X
X
] Recreation
X
i
I/I
O
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t
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-------
TABLE 8
COMMENTS RECEIVED ON DRAFT ENVIRONMENTAL
IMPACT STATEMENT
Date
eceived
1975
7/17
8/28
7/28
7/25
- 43 -
From
L. H. Chadbowen
Harold H. McClure P. 99
Virginia G. Webb P. 115
Robert W. Weir P. 120
V,
GENERAL
TONE
General
Critical
Critical of
Proposed Proje
Critical
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Costs
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-------
UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
1220 S. W. Third, Portland, Oregon 97204
July 22, 1975
Br. Richard R. Thiel, Chief
Environmental Impact Section M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington, 98101
Dear Mr. Thiel:
We have reviewed the draft environmental impact statement for Redwood
Service District, Josephine County, Oregon. Our comments are:
1. Page 14, Fish & Wildlife: The environmental impact statement
refers to the Oregon list of rare and endangered animals. Are
there any animals in the project area which are on the
"United States List of Endangered Fauna?"
2. Page 14 et a!, Soils: The soils in the proposed project area
are generally "wet," with shallow ground water table and are
located in proximity of irrigated land. Will the proposed
sewer system cause the growth of a residential area which will
then demand public assistance in drainage?
3. Are there any historical or archeological resources in the area
which will be affected by the proposed project?
The Soil Conservation Service does not presently have any project which
would be affected by this proposal.
We appreciate the opportunity to review and comment on this draft
environmental impact statement.
Yours truly,
/•
James W. Mitchell
State Conservationist
< ,{
cc:
Office of the Coordinator of Environmental Activities,
Office of the Secretary, USDA
Administrator, SCS, Washington, D.C.
Chairman, Council on Environmental Quality (5 copies)
j'J', -31975
-44-
-------
- 45 -
Response to Comments by United States Department of Agriculture, Soil
Conservation Service
1. The "United State List of Endangered Fauna" was consulted. No
animals within the Redwood S.D. or approximate thereto are on
the list.
2. Because the soils in the area are generally saturated during the
wet season and shallow ground water tables are near irrigated
land, increased residential growth could create future drainage
problems. At this time, however, we do not know whether public
assistance will be necessary.
3. See response to Advisory Council on Historic Preservation.
-------
DEPARTMENT OF THE ARMY
PORTLAND DISTRICT. CORPS OF ENGINEERS
P. O BOX 2946
PORTLAND, OREGON 97208
REPLY TO
ATTENTION OFi
NPPEN-EQ
21 July 1975
v"
Mr. Richard R. Thiel, Chief *
Environmental Impact Section M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Thiel:
The draft environmental impact statement for the Redwood Service
District which you furnished to our North Pacific Division Office,
has been referred to this District office. We have reviewed the
statement and have no comments relating to the Corps of Engineers'
functional area of responsibility and expertise, basically:
flood control, navigation and hydropower.
This opportunity to review and comment on the draft statement is
appreciated.
Sincerely yours,
Chief, Envi
ntal Quality Branch
RECEIVED
.VL 251975
EPA-EIS
- 46 -
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
PACIFIC NORTHWEST REGION
P.O. Box 3621, Portland, Oregon 97208
July 24, 1975
ER-75/556
Mr. Richard R. Thiel, Chief
Environmental Impact Section
M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Thiel:
We have reviewed the draft environmental impact statement
concerning the Redwood Service District, Josephine County,
Oregon and offer the following comments for your considera-
tion in preparing the final document.
GENERAL COMMENTS;
Although the draft statement contains numerous references
to current ground-water problems such as failures of septic
tanks because of high water-table conditions and pollution
of a large proportion of the wells of the area, it does not
describe the pertinent aspects of the occurrence of ground
water in the area, the "normal" quality of ground water there,
and aquifer characteristics related to the problems. The
reader assumes on the basis of the nature of the proposed
project that the construction of a waste-treatment plant
and sewerage system will necessarily improve the quality of
ground water in the project area and relieve the problem of
health hazards related to ground water; however, the neces^-
sary data are not supplied to permit evaluating such impacts.
The statement should include at least the following: (1) a
description of the aquifer(s) involved in the problem,
RECEIVED
-47- JUL281975
EPA-FJS
-------
including pertinent hydrologic characteristics; (2) a map
showing the water-table configuration or a sufficient number
of depth-to-water or water-table measurements; and (3) the
distribution of wells in the area, and especially the distri-
bution of polluted wells.
A map of wildlife ranges concerned, along with a list of
animal species affected by the project, would be beneficial
to reviewers.
It is difficult to determine what impacts on outdoor recrea-
tion would occur as a result of the proposed project. Because
tourism is cited as the second most important industry in
Josephine County and because the project is expected to induce
future county growth, a detailed assessment of potential
primary, secondary, and tertiary impacts to park and recrea-
tion facilities, lands, and waters should be provided in the
final environmental impact statement.
The Oregon Statewide Comprehensive Outdoor Recreation and
Open Space Plan (SCORP) would provide a good basis for assess-
ing the impacts to recreation supply and demand. That docu-
ment is the State's official outdoor recreation plan, prepared
and maintained pursuant to Public Law 88-578, the Land and
Water Conservation Fund Act, as amended. The SCORP defines
outdoor recreation goals and objectives and contains valuable
information on recreation supply, demand, and needs. It
suggests recommendations and priorities for action to meet
recreation needs. For additional information, EPA may wish
to contact David G. Talbot, State Parks Superintendent,
300 State Highway Building, Salem, Oregon 97310 (503-378-6305)
Compliance with the National Environmental Policy Act should
be coordinated with the separate responsibilities of the
National Historic Preservation Act of 1966 and Executive
Order 11593 to ensure that historical and archeological
resources are given proper consideration. Briefly, cultural
resources should be treated as other aspects of the environ-
ment are, i.e., they should be inventoried, their signifi-
cance evaluated, impacts upon them assessed, and mitigative
measures discussed in environmental statements. To satisfy
these requirements in the final statement, we have the
following suggestions.
2
- 48 -
-------
(o
The "National Register of Historic Places" and the Oregon
State Historic Preservation Officer should be consulted to
determine if sites on, or eligible for, the National Register
will be affected by the proposal.
To learn of known archeological sites in the project area, we
suggest that Dr. David Cole, Museum of Natural History,
University of Oregon, Eugene, Oregon 974Q3, be consulted.
Dr. Cole can also advise on whether or not an archeological
survey should be conducted prior to construction. An ab-
sence of known archeological sites in an area is frequently
only an indication that the area has not been inspected by
a trained archeologist .
The results of the above consultations should be reported
and documented in the final statement.
SPECIFIC COMMENTS:
Page 2? last paragraph. Criteria used to determine contamina-
tion of wells would be helpful.
Page 10, 5th paragraph. Accurate population projections
are necessary to evaluate alternative plans; thus, additional
information concerning inadequacy of estimates would be useful
Page 13, under "Water Quality". This section should address
the problem of ground water contamination as well as degrada-
tion of the Rogue River and other surface waters,
Page 13, footnote j./, item 1. Concentrations listed in
standards are based on tests for total coliform rather than
specifically for fecal coliform.
Page 14,third paragraph. It would be helpful if the factors
of urbanization which have caused a decreased use of Sand
Creek and Allen Creek by steelhead were explained.
Page 15, paragraph F. The ultimate population projection
should state the year of expected projection. An updated
projection would be desirable. It is difficult to see where
more than 5 - 10,000 population by 1990 or 15,000 by the
year 2000 is justified.
3
- 49 -
-------
10
Page 18, paragraph A. The use of the phrase "Impacts on the
Ecology" is not correct. Ecology is a study of ecosystems
and not a natural physical thing. The proper phrase is
"Impacts on the Ecosystems." Ecosystem reactions to impacts
would be more technically descriptive.
Page 19, 4th par a g raph, 4th line. Reference is made to "a
great deal of excavation" during construction of the treat-
ment plant. Information on the estimated volume of excava-
tion, on whether excess spoils would be produced on the
proposed disposition of any such spoils, and on the impacts
of spoil disposal, if any, should also be included.
Page 21, 4th paragraph. It is stated that sludge would be
disposed of by land application on agricultural lands after
drying. The probable location or availability of such dis-
posal areas and the approximate distance of transport and
associated impacts should be included.
Page 22, 4th paragraph. Four "flags" were set on primary
impacts (Table 3, page 17) for "community well-being." They
are not clearly defined in this section.
Page 23, paragraph B. The title, "Impacts on Physical/
Chemical," seems inappropriate for a discussion on zoning,
land-use and other people-related topics.
Page 27, 2nd paragraph. Increased development will also
lead to erosion during continuing construction activities
and to more rapid runoff of precipitation from buildings,
streets, etc.
Page 27, 3rd paragraph. Residential areas will produce more
than "neutral smells." Air pollution would also be associated
with such development.
Page 28, table 4 and first paragraph. Logic behind assump-
tion that multiple family units will be constructed in the
eastern sector of the service area should be documented.
Exhibit 2. The Description of an Environmental Evaluation
System explains the general methodology used to arrive at
quantitative indices of environmental impact (Environmental
Impact Units) shown on tables 3 and 6, but in no case has
4
- 50 -
-------
the actual method of arriving at the figures been fully
explained in the draft environmental statement. Many
assumptions that must have been made by the evaluators in
arriving at the quantitative but dimensionless units have
not been identified. Consequently, the reader is provided
with no means for assessing the evaluations.
Exhibit 3. The material presented in exhibit 3 is important
enough to the understanding of the existing environment,
that it might be of more value if presented in the main text
rather than the appendix.
Exhibit 3, page 9, paragraph 4. Reference is made to "enlarge-
ment of the flood plain at the western end of the District
near the proposed treatment plant site." This is the first
mention of the flood plain that was noted in the statement.
Information on soils that is provided later in Exhibit 3
suggests that the proposed sewage treatment plant site may
lie on the flood plain of Rogue River, which is mapped as
Newberg-Evans soil association (Exhibit 3, Figure 5, page 11),
but the boundaries between units on the soils map are not
sufficiently clear to determine this positively. It would
be advisable to describe the site with respect to the limits
of the flood plain and to evaluate relevant impacts if the
site is on the flood plain.
Exhibit 3, page 13, third paragraph. The district largely
is rural and rural residential placed on alluvium composed
of unconsolidated gravel, sand, and clays in the Rogue
River drainage. Quartz diorite is found north and south of
Grants Pass, bordering the alluvial deposits. No mineral
industry activities will be adversely affected by the project.
Exhibit 3, page 16, third paragraph. Population projections
referred to are not present.
Please let us know if we can be of further assistance in
the review of this statement.
Sincerely yours,
Roy H. Sampsel
Special Assistant to
the Secretary
5
- 51 -
-------
- 52 -
Response to the United States Department of Interior
1. The Redwood area is basically composed of granite soil types which
are underlain by bedrock. The groundwater table lies above the bedrock
at varying depths. Domestic wells within the area range in depth from
50 feet to 150 feet. Test wells dug by the Bureau of Reclamation this
spring hit groundwater at 24 inches below the surface of the soil. This
depth will vary during the wet season and also in the spring and summer
when irrigation is taking place.
There were no maps available to show the distribution of contaminated
wells. See response #5 for discussion of contaminated wells.
For more detailed information on soils and groundwater, the reader may
contact Mr. Pete Pescador, Soil Scientist of Josephine County. Mr.
Pescador has soil profiles available for review.
2. As noted by the Department of Interior's letter it js_difficult to
determine impacts on outdoor recreation resulting from expected
increases in population. EPA can only make a generalized statement
about recreation supply and demand within the project area. Presently,
there is one park (Schroeder Park) within the confines of the Redwood
Service District. It can be expected that with increased population
growth, usuage of Schroeder Park would also increase, although to
what extent is unknown. The county, in its Comprehensive Plan, has
projected that the size of Schroeder Park will be expanded over the
next 20 years.
EPA cannot project the increase in recreational use of other areas of
Josephine County resulting from an increase in population in the
Redwood area. EPA has assumed that demand would increase county-wide
and that local, State and Federal recreation and park agencies would
make the proper responses.
3. Both of the sources have been consulted by EPA (see attached letter
from Paul Hartwig), and they have indicated that no historic sites,
will be affected by the proposed project. Prior to construction a survey
will be conducted to determine if any potential historic sites are in the
area should be protected.
4. Dr. Cole was also consulted (see attached letter) and he recommended
contact with Dr. William Lyon. EPA has contacted Dr. Lyon, who was
unaware of any archeological sites in the Redwood area. EPA will,
however, arrange to have a survey made prior to any construction. If
a potential site is located both Dr. Lyon and Dr. Cole will be contacted
and arrangements made to protect the site.
5. The Josephine County Health Department utilized a standard coliform
test design merely to show the presence of coliform, but not the MPN.
A positive result would indicate that coliform is present in the
well water, and the well would be classified contaminated. According
to Mr. Bill Olson of the Health Department, some tests for fecal coliform
-------
- 53 -
were run on a number of contaminated wells, but the results were nega-
tive. The text of the EIS has been changed to reflect these results.
6. See response to comment letter from Josephine County Department of
Roads.
7. This section addresses only "existing conditions" and not conditions
after a project is built or not built. Contamination of groundwater
(wells) is discussed on page 2. A more detailed description of exist-
ing water quality is given in Exhibit 3, page 7 and 8 of the Appendix.
8. Oregon State Water Quality Standards refer specifically to fecal coli-
form. Please refer to Exhibit 4, page 3, paragraph 1.
9. The ultimate population is expected to occur by the year 2025 accord-
ing to county estimates.
10. At this time it is unknown how much excavation will be required, but
it is assumed that any excess spoils will be used in landscaping or
disposal of pursuant to State regulations.
11. The District's engineer has not designated a site for sludge disposal.
There are, however, areas of land in close proximity (within 20 miles)
which would probably be suitable for sludge disposal pursuant to State
regulations. These lands are presently used for hay production and
could continue that activity. There would be few impacts from sludge
transport and disposal. The transport of sludge would take • place
at infrequent intervals so truck traffic and noise would be tolerable.
Odors from land application could be avoided by burying the sludge.
12. There is no assumption that the easter sector will develop in multiple
family units. In fact, the Comprehensive Plan does not call for such
densities. It does, however, recommend a density of up to 6 units per
acre in the easter sector which is substantially higher than the 3 units
per acre projected under the proposed project. EPA assumed that
Alternative "A" would direct more growth to the easter sector than the
proposed project would and that the higher resulting density would
contribute to lower energy consumption.
13. Three paragraphs above the quoted sentence in the comment letter
(Exhibit 3, page 9, paragraph 1) is a statement on the treatment plant
site and flood plain. It is noted that the treatment plant is within
the 50-year flood plain. The treatment plant will be protected against
the maximum expected 100-year flood (see attached EPA criteria).
14. The response to the Josephine County Road Department's letter contains
the table. The text of Exhibit 3 has been changed.
-------
OREGON STATE
HIGHWAY DIVISION
HIGHWAY BUILDING
TOM McCALL
GOVERNOR
F. B. KIABOE
fli«tr»1or of Highwtyi
SALEM, OREGON
November 25, 1974
97310
Mr. Cecil Ouellette
Environmental Protection Specialist
U.S. Environmental Protection Agency
Oregon Operations Office
1234 S.W. Morrison Street
Portland, OR 97205
Dear Mr. Ouellette:
This is in response to your request for information
on historic sites located within the proposed sewer treatment
project near Grants Pass, Oregon.
There are no properties listed on the National Register
of Historic Places located within the proposed project area.
Nor are there any properties listed in the statewide Inventory
of Historic Sites and Buildings located within the proposed
project area. However, this area has not been adequately
surveyed and there may be properties of historic significance
within the boundaries of the projeot. Of special interest
should be the downtown region of Grants Pass, which is on the
fringe of the proposed service district boundary.
We appreciate this opportunity to comment.
rely,
B. Hartwig
State Historic Preservation Office
PBHjlb
- 54 -
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UNIVERSITY OF OREGON
October 25, ISM
Cecil OoeUette
Envtrcrnmetrijtl Protection Specialist
PratocUan A^eaKif
1234 S. W, MorriKoo Street /
, Oregon
Dear Mr.
We baye recelypd a cc^g? «€ yosn- letter
-------
TECHNICAL BULLETIN
DESIGN CRITERIA FOR MECHANICAL, ELECTRIC,
AND FLUID SYSTEM AND COMPONENT RELIABILITY
Supplement to Federal Guidelines for Design,
Operation, and Maintenance of Waste Water
Treatment Facilities
Office of Water Program Operations
U. S. Environmental Protection Agency
Washington, D. C. 20460
For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402 • Pr)ce 85 cents
- 56 -
-------
Works Design Criteria
100. WORKS DESIGN CRITERIA
t
110. WORKS LOCATION
The potential for damage or interruption of operation due to
flooding shall be considered when siting the treatment works.
The treatment works' structures and electrical and mechanical
equipment shall be protected from physical damage by the
maximum expected one hundred (100) year flood. The treatment
works shall remain fully operational during the twenty-five (25)
year flood, if practicable; lesser flood levels may be permitted
dependent on local situations, but in no case shall less than a
ten (10) year flood be used. Works located in coastal areas
subject to flooding by wave action shall be similarly protected
from the maximum expected twenty-five (25) and one hundred
(100) year wave actions.
Existing works being expanded, modified, upgraded or rehabili-
tated shall comply with these criteria to the degree practicable.
The flood and wave action elevations used to implement these
criteria shall be determined and justified by the Grant Applicant,
using available data sources where appropriate. Elevations for
-8-
- 57 -
-------
Works Design Criteria
a specific location may be available from local or state studies
as well as studies by the following Federal organizations: U, S,
Army Corps of Engineers, U.S. Geological Survey, U.S. Soil
Conservation Service, National Oceanic and Atmospheric
Administration, and Tennessee Valley Authority.
The works shall be accessible in all normal seasonal conditions,
including the expected annual floods.
120. PROVISIONS FOR WORKS EXPANSION AND/OR UPGRADING
' '" * " "-"' "" ' " " ' " " • f • -" ' in-""-' • •• ""I'-i i • —
All new works and expansions to existing works shall be designed
for further expansion except where circumstances preclude the
probability of expansion. During a works' upgrading or expansion
the interruption of normal operation shall be minimized and
shall be subject to the approval of the RegionaJ. Administrator.
130. PIPING REQUIREMENTS
131. Pipes Subject to Clogging
131. 1 Provisions for Flushing of Pipes
The works shall have provisions for flushing with water ,
^v
and/or air all scum lines, sludge lines, lime feed and
lime sludge lines, and all other lines which are subject to
clogging. The design shall be such that flushing can be
accomplished without causing violation of effluent limita-
tions or without cross-connections to the potable water
system.
- 589-
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Advisory Council
On Historic Preservation
1522 K Street X.\\". Su;,c 4 10
\VnshingtonD.C. 2U()0>
June 26, 1975
Mr. Richard R. Thiel, Chief
Environmental Impact Section M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Thiel:
This is in response to Clifford V. Smith, Jr.'s request of June 13, 1975
for comments on the environmental statement for Redwood Service District,
Josephine County, Oregon. Pursuant to its responsibilities under Section
102 (2) (C) of the National Environmental Policy Act of 1969, the Advisory
Council on Historic Preservation has determined that your draft environ-
mental statement is inadequate regarding our area of expertise as it does
not contain sufficient information to enable the Council to comment sub-
stantively. Please furnish additional data indicating:
I. Compliance with Section 106 of the National Historic Preservation
Act of 1966 (16 U.S.C. 470[f]). The Council must have evidence
that the most recent listing of the National Register of Historic
Places has been consulted (see Federal Register, February 4, 1975
and monthly supplements each first Tuesday thereafter) and that
either of the following conditions is satisfied:
A. If no National Register property is affected by the project,
a section detailing this determination must appear in the
environmental statement.
B. If a National Register property is affected by the project,
the environmental statement must contain an account of steps
taken in compliance with Section 106 and a comprehensive
discussion of the contemplated effects on the National
Register property. (36 C.F.R. Part 800 details compliance
procedures. )
II. Compliance with Executive Order 11593 "Protection and Enhancement
of the Cultural Environment" of May 13, 1971. ...'„._
- - - RECEIVED
JUN 301975
- 59 -
-------
A. Under Section 2(a) of the Executive Order, Federal agencies
are required to locate, inventory, and nominate eligible
historic, architectural and archeological properties under
their control or jurisdiction to the National Register of
Historic Places. The results of this survey should be
included in the environmental statement as evidence of
compliance with Section 2(a).
B. Until the inventory required by Section 2(a) is
complete, Federal agencies are required by Section
2(b) of the Order to submit proposals for the transfer,
sale, demolition, or substantial alteration of
federally owned properties eligible for inclusion in
the National Register to the Council for review and
comment. Federal agencies must continue to comply
with Section 2(b) review requirements even after the
initial inventory is complete, when they obtain
jurisdiction or control over additional properties
which are eligible for inclusion in the National Register
or when properties under their jurisdiction or control
are found to be eligible for inclusion in the National
Register subsequent to the initial inventory.
The environmental statement should contain a deter-
mination as to whether or not the proposed undertaking
will result in the transfer, sale, demolition or
substantial alteration of eligible National Register
properties under Federal jurisdiction. If such is the
case, the nature of the effect should be clearly indicated
as well as an account of the steps taken in compliance
with Section 2(b). (36 C.F.R. Part 800 details compliance
procedures.)
C. Under Section 1(3), Federal agencies are required to
establish procedures regarding the preservation and
enhancement of non-federally owned historic, architec-
tural, and archeological properties in the execution
of their plans and programs.
The environmental statement should contain a determination
as to whether or not the proposed undertaking will contri-
bute to the preservation and enhancement of non-federally
owned districts, sites, buildings, structures and objects
of historical, architectural or archeological significance.
2
- 60 -
-------
III. Contact with the State Historic Preservation Officer.
The procedures for compliance with Section 106 of the National
Historic Preservation Act of 1966 and the Executive Order 11593
require the Federal agency to consult with the appropriate
State Historic Preservation Officer. The State Historic Pres-
ervation Officer for Oregon is David G. Talbot, State Parks
Superintendent, 300 State Highway Building, Salem, Oregon 97310.
Should you have any questions or require any additional assistance, please
contact Brit Allan Storey of the Advisory Council staff at P. 0. Box 25085,
Denver, Colorado 80225, telephone number (303) 234-4946.
Sincerely yours,
Michael H. Bureman
Acting Assistant Director
Office of Review and Compliance
cc:
Sheldon Meyers-EPA:FLO
3
- 61 -
-------
- 62 -
Response to Comment Letter From Advisory Council on Historic
Preservation
During preparation of the draft EIS, EPA consulted Mr. Paul p. Hartwig,
Oregon State Historic Preservation Officer, who indicated there were no
properties on the National Register that were located in the project area or
that would be affected by the proposed project (see Hartwig letter attached
to response to Department of Interior letter). He also stated that no pro-
perties on the statewide Inventory of Historic Sites and Buildings were
located in the project area.
EPA has consulted the August 5, 1975 Federal Register which contains
the National Register of Historic Places. No site on the list will be
affected as the list only contains one site in Josephine County. This site
is the Wolf Creek Tavern and is not located near enough to the project area
to be affected by a sewage treatment facility and its effects.
Mr. Hartwig noted that the area has not been adequately surveyed,
which was also the feeling of Dr. William Lyon (see response to Department
of Interior letter). Prior to construction of any project EPA will conduct
a survey to locate, inventory, protect and nominate any historic, architec-
tural, or archeological properties to the National Register. EPA will work
closely with Mr. Hartwig and Dr. Lyon in the conduct of the survey.
-------
REGION X
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
ARCADE PLAZA BUILDING, 1321 SECOND AVENUE
SEATTLE, WASHINGTON 98101
July 14, 1975
Office of Community, Planning
and Development
!N REPWY REFER TO:
10D
Dr. Clifford V. Smith
Regional Administrator
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA. 98101
Dear Dr. Smith:
Subject: Draft Environmental Impact Statement
Redwood Service District
Josephine County, Oregon
We have reviewed the draft statement on the proposed treatment and
sewage facilities for the Redwood Sanitary sewer Service District
We are very concerned with this project since it appears that a
good portion of the district lies in a flood prone area. We would
not like to see the construction of sewer c ollection lines that
would encourage residential construction in these areas. We
suggest that further investigations be made since HUD at this time
does not have detailed studies to delineate the exact location of
the flood hazard area. The County probably is showing very good
judgment in adopting the comprehensive plan which designates most
of the area for agriculture and low residential use.
I
Thanks.,
the opportunity to comment.
'Robert C. Scalia
Assistant Regional Administrator
- 63 -
RECEIVED
JUL 231S75
JUL 151975
REGIONAL ;VX'WSTnATOg ;
-------
- 64 -
Response to Department of Housing and Urban Development
1. EPA agrees that Urban growth within flood plain areas can result ir)
adverse environmental impacts. Josephine County has provided for
limitation of flood plain development within their Comprehensive Plan,
The Plan recommends as a goal "that subdivisions and development of
land subject to periodic flooding be discouraged". The county is
adequately insuring restriction of flood plain development.
-------
DEPARTMENT OF " ; ^F
ENVIRONMENTAL QUALITY "
1234 S.W. MORRISON STREET • PORTLAND, ORE. 97205 • Telephone (503) 229- 5301
ROBERT W. STRAUB
GOVERNOR
July 31, 1975
Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
Attention: Dr. Clifford V. Smith, Regional Administrator
Gentlemen:
Re: Draft Redwood E.I.S.
The Department of Environmental Quality has reviewed the draft
Environmental Impact Statement for the Redwood Service District and
offers the following comments for your consideration.
The Redwood Service District is an area suffering from water pollution
problems and severe potential health hazards as a result of failing sub-
surface sewage disposal systems. Construction of a community system to
collect, treat and properly dispose of sewage appears to be the only
reasonable way for solving the existing problem. The alternative designated
as the "Proposed Project" in the draft E.I.S, appears to be the best
alternative for solving the problems for the following reasons:
1. It will solve more of the existing public health and water
quality problems resulting from inadequate sewage disposal than
will other presented alternatives.
2. It will afford the greatest flexibility for meeting possible
future needs of the area.
The draft E.I.S. dwells at length on possible excessive growth in the
Redwood Area that will be caused by construction of sewers. This pre-
occupation is evidenced in part by frequent reference to "excess capacity"
in the draft E.I.S. in place of the "reserve capacity" which grant regulations
require to meet reasonable future needs.
Installation of sewers in the Redwood Area will not, in our opinion,
cause excessive growth or create development as the Draft E.I.S. implies.
Growth and development, if it is to occur, will be caused by creation of
new jobs in the Grants Pass Area or other forces which attract people to
the area.
RECEIVED
A.jn 7 «.*7c
DEQ-l
cn
- DO -
-------
Environmental Protection Agency
Region X
July 31, 1975
Page 2
Growth and development in Oregon generally and in the Redwood Service
District specifically can be, and pursuant to state law, must b,e controlled
through the land use planning process. Such plans must be developed and
adopted and may from time to time be revised in accordance with a process
which is responsive to public needs and desires as well as state goals
and guidelines.
Therefore the construction of sewers will not grant a right of
development in any manner contrary to an adopted land use plan. Sewers
will make it possible to properly accommodate development on land which is
not suitable for subsurface sewage disposal, but then only as long as the
proposed development is consistent with the land use plan.
We believe it would be appropriate in the final E.I.S. to use the
words "reserve capacity" in place of "excess capacity". We would also urge
revision so that the final E.I.S. more accurately reflects existing Oregon
land use control methods and requirements.
Sincerely,
LOREN KRAMER
Director
HLS:ak
66 -
-------
- 67 -
Response to Oregon State Department of Environmental Quality
1. See following letter dated August 21, 1975 from the Environmental
Protection Agency to the Department of Environmental Quality.
-------
U.S. ENVIRON MENTAL PROTECTION AGENCY
REGION X
'•£ 1200SIXTHAVENUE
5 SEATTLE, WASHINGTON 98101
? . AUG ?, 1. 1975
Mail Stop 613
Mr. Loren Kramer
Director, Oregon Department
of Environmental Quality
1234 S.W. Morrison Street
Portland, Oregoa 97205
Dea r Mr^,Kraliie.^'^
Thank you very much for your .July 31, 1975 comments on our
draft Environmental Impact Statement (EIS) for a proposed construction
grant to the Redwood Sewer District. The final EIS should be released
in September, at which time the Environmental Protection Agency's
(EPA) decision concerning a grant for a project in the Redwood area
can be made.
However, prior to the release of the final EIS, we feel we are
able to address the issue of land planning and sewers which you discuss
in your comments. EPA's construction grant regulations require that
before awarding initial grant assistance for any treatment works project
the Regional Administrator shall determine:
"That the treatment works will comply with
all pertinent requirements of the Clean Air
Act and other applicable Federal, State and
local environmental laws and regulations."
(40 CFR 35.925-14).
Additionally, 40 CFR 35.935-4 subjects all treatment works grants to
the following condition:
"The construction of the project, including the
letting of contracts in connection therewith,
shall conform to the applicable requirements
of State, territorial, and local laws and ordinances
to the extent that such requirements do not
conflict with Federal laws and this subchapter."
Our Office of Regional Counsel has reviewed recent decisions of
the Supreme Court of Oregon (Fasano v. Board of County Commissioners
- 68 -
-------
-2-
of Washington County, 507 P.2d 23 (1973); Baker v. City of Mi
533 P.2d 772 (T975)) which assert that comprehensive pTan?~are the
basic and controlling land use planning instruments within the State
and that such plans are legislative in nature.
Based on the holdings of the Supreme Court of Oregon as to the
legal status of adopted comprehensive plans, our Regional Counsel con-
cludes that such plans, when duly adopted in the State of Oregon, should
be considered laws, regulations or ordinances with which EPA-funded
construction grant projects must comply, as stated in the above-cited
EPA regulations.
We believe that this recognition of the legal status of compre-
hensive land use plans is supported by recent program guidance from
Administrator Train. In addition, as a result of litigation relating
to a construction grant project in South Medford, Oregon, EPA obtained
assurances in a March-25, 1975 letter from Kessler Cannpn, then Director
of the Department of Environmental Quality, that in regard to future
projects, the Board of Commissioners would be required to complete a
form in which the Board certifies that it has reviewed the project and
that it finds that the project does not violate applicable County land
use plans. EPA has viewed such a requirement on the County Commissioners
as a commitment of the State to a policy which insures t!ie compliance
of construction grant projects with County land use plans.
Based on the foregoing, EPA considers itself bound to respect the
policies and decisions expressed in comprehensive plans when awarding
construction grants in the State of Oregon. My staff has concluded
that the alternative designated as the "Proposed Project" in the draft
EIS contradicts the comprehensive plan adopted by the Josephine County
Planning Commission in 1971. At this time, funding that alternative
would violate EPA's regulations as well as both State and EPA policies.
Members of my technical and legal staff are available, at your
convenience, to discuss these matters with you. The other issues
which you raised in your comments will be addressed in the final EIS,
Clifford V. S^cnyJr., Ph.D., P.E.
Regional Administrator
cc: Board of County Commissioners
of Josephine County
be: 000
Environ. Impact Section is
- 69 -
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AN EQUAL OPPORTUNITY EMPLOYER
EXECUTIVE DEPARTMENT
INTERGOVERNMENTAL RELATIONS DIVISION
240 COTTAGE STREET S.E.
ROBERT W. STRAUB
GOVERNOR
STAFFORD HANSELl
Director
SALEM, OREGON 97310
August 8, 1975
Mr. Richard R. Thiel, Chief
Environmental Impact Section M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Thiel:
Re: Draft EIS-Redwood Service District
Josephine County, Oregon
PNRS #7506 4 250
Thank you for submitting your draft Environmental
Impact Statement for State of Oregon review and comment.
Your draft was referred to the appropriate state
agencies. The State Department of Fish and Wildlife, the
State Soil and Water Conservation Commission, the States
Department of Land Conservation and Development and the
State Highway Division offered the enclosed comments which
should be addressed in preparation of your final Environ-
mental Impact Statement.
We will expect to receive copies of the final
statement as required by Council of Environmental Quality
Guidelines.
Sincerely,
. Y
William H. Young
Administrator
WHY:1m
Enclosures
RECEIVED
AUG131975
EPA-EIS
- 70 -
-------
REFER TO
FOR
PROJECT NOTIFSCATON AND REVIEW SYSTEM
STATE CLEARINGHOUSE
240 Cottage Street S.E., Salem, Oregon 97310
Ph: 378-3732
P N R S STATE REVIEW
7506 4 250
Return Date;
JUL ^
ENVIRONMENTAL IMPACT REVIEW PROCEDURES
1. A response is required to all notices requesting environmental reviev
2. OMB A-95 (Revised) provides for a 30-day extension of time, if
necessary. If you cannot respond by the above return date, please
call the State Clearinghouse to arrange for an extension,
ENVIRONMENTAL IMPACT REVIEW
DRAFT STATEMENT
( ) This project does not have significant environmental impact.
(X ) The environmental impact is adequately described.
( ) We suggest that the following points be considered in the prepara-
tion of a Final Environmental Impact Statement regarding this pro-
ject.
( ) No comment.
TO REGION 3:
REMARKS"
6/16/75 - Redwood Service District, Josephine Co.
Major impact to the state highway system would be installation of lines ,
within state right of way and future residential growth within the service
district.
- 71 -
-------
OREGON PROJECT NOTIFICATION AND REVIEW SYSTEM
STATE CLEARINGHOUSE
Intergovernmental
Relations Division
240 Cottage Street S . C . , Salem, Oregon 97310
Ph: 378-3732
P N K S STATE REVIEW
Project ft: 7506 4 250 _ Return Date: July 21 T 1975 _
ENV T RONMENT AL IMP AC T KEVIEW PRC )££fiURE S
1. A response is required to all notices requesting environmental review,
2. OMB A-95 (Revised) provides for a 30-day extension of time, if
necessary . If you cannot respond by the above return date, please
call the State Clearinghouse to arrange for an extension.
ENVIRONMENTAL IMPACT REVIEW
DRAFT STATEMENT
( J Thi.s project does not have significant ei vironmental impact.
( ) The environmental impact is ade luately described.
( X ) We suggest that the following points be considered in the prepara-
tion of a Final Environmental Impact Statement regarding this pro-
ject.
( ) No comment.
REMARKS
All activities below the bank line shall be subject to DSL Fill and
Removal Law and permits shall be acquired prior to activities in
that area.
Disturbed soils shall be vegetated prior to fall rains.
Conversion of sewage discharge from many groundwater sources to a
single point source discharge .of treated effluent with relatively
high chlorine residual will have some adverse impact withiri the
mixing zone of the effluent. Dilution flows will provide for fairly
rapid mixing.
We support alternative "A" , as this provides for further construction
if indicated by actual growth within the project area.
- 72 -
Agency Dept' of Fish & wildlife By Norman Behrens & Irving W, Jones
-------
^ OREGON PROJECT NOTIHCAT2O5S! AND REVIEW SYSTEM
STATE CLEARINGHOUSE .,, u. -.> £ a V !
"^TTr-ic^Tr^i-n
• vi ; ^ 1U7-
.' • ' I .- ~ \ U : ^
Local Government Relations Division ;
240 Cottage Street S.E., Salem, Oregon 97310
Ph: 378-3732
P N R S S T A T F REVIEW
,,.,L *ND WATER
.-. u.-i COfttMISStOi
Project #;
75064250
-"
Return Date:
JUi 21 1975
UL ^ 'J/ W
BMVTRONMEMTAL IMP
REVIEW PROCEDIIRFS
1. A response is required to all notices requesting environmental review.
2. OMB A-95 (Revised) provides for a 30-day extension of time, if
necessary. If you cannot respond by the above return date, please
call the State Clearinghouse to arrange for an extension.
ENVIRONMENTAL IMPACT REVIEW
DRAFT STATEMENT
( ) This project does not have significant environmental impact.
( ) The environmental impact is adequately described.
(,/-) We suggest that the following points be considered in the prepara-
tion of a Final Environmental Impact Statement regarding this pro-
ject.
( ) No comment.
REMARKS
The local Soil and Water Conservation District feels that
The problem of the redwood area is of an extremely complicated nature. The people
of the area are concerned to the extent that two large factions have developed.
We feel that the people of the area, who are most concerned, should make the final
decision. We are concerned about preserving our agriculture land in production and
providing for an abundance of high quality water.
- 73 -
nrl LMrit t,t-.
-------
OREGON PROJECT NOTIFICATION AND REVIEW-SYSTEM* o?
-H.\0 CONSERVATIG,
STATE CLEARINGHOUSE ^P^OP--^
! '\ * r- ' *
Local Government Relations Division ' '" -r
240 Cottage Street S.E., Salem, Oregon 97310
Ph: 378-3732 «- -• '
P N R S STATE REVIEW
Project # : /' !) 0 6 4 2 5 G Return Date: U
ENVIRONMENTAL IMPACT REVIEW PROCEDURES
1. A response is required to all notices requesting environmental review
2. OMB A-95 (Revised) provides for a 30-day extension of time, if
necessary. If you cannot respond by the above return date, please
call the State Clearinghouse to arrange for an extension,
ENVIRONMENTAL IMPACT REVIEW
DRAFT STATEMENT
( ) This project does not have significant environmental impact.
( ) The environmental impact is adequately described.
( v'J We suggest that the following points be considered in the prepara-
tion of a Final Environmental Impact Statement regarding this pro-
ject.
( ) No comment.
REMARKS
Afl**^
* \j LI *
i i » . .. . ii
ML
${
-------
ENGINEERING DIVISION
COUNTY COURTHOUSE
PHONE: 476-8881 - EXT. 404
MAINTENANCE OFFICE
201 RIVER HEIGHTS WAY
PHONE 476-8881 - EXT. 411
GRANTS PASS, OREGON 97526
July 22, 1975
Mr. Richard R. Thiel, Chief
Environmental Impact Section M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Re: Comments on Draft EIS on the Redwood District Project
Dear Sir:
It is understood that in an environmental impact statement a high degree of
latitude exists at the perogative of the author. A predestined goal or concept in
the mind of the author would deflate its value and strength, rendering it as a token
exercise to satisfy the criteria set out for ourselves, by ourselves, in directing
the flow of "our" federal funds.
The "Description of an Environmental Evaluation System" set forth in Exhibit 2
of the Draft EIS is an excellent and ideal measuring device, allowing the means for
the author to continually weigh the impact with which his statements may "contaminate"
the necessary objectivety of the report. The methodology described in this exhibit
ranges from "Comprehensive" to the "Ability to Detect Environmentally Sensitive Areas",
of which "Objectivity" and the need to be "Based on Explicitly Defined Criteria" are
major components.
The assessment of environmental impacts, to quote from Exhibit 2 should be-,
"OBJECTIVE, because to be meaningful the methodology must provide im-
personal, unbiased, and constant yardsticks immune to outside tampering by
political or other external forces."
"BASED Of! EXPLICITLY DEFINED CRITERIA, because it is important to insure
that evaluation criteria and values are not arbitrarily assigned. It is im-
portant that the methodology provide explicitly defined criteria and that
procedures for using these criteria be explicitly stated; in this respect,
the methodology must also document the rationale upon which the criteria
are based."
These two concepts are re-accented here, as adherence to their principle with-
in the Draft EIS is felt to be lacking. Evidence of this is brought forth in the
statements below from the Draft EIS, and appear to indicate that the author approach-
ed the task with snmp prp-conceived desired results regarding project alternatives."'
- 75 -
-vf.sr
-------
Summary Sheet, second page, first paragraph.
"Thus, the "no-action" alternative (in the eastern portion where land use
controls have been lacking) would not meet national and state water quality
goals and requirements and, thus, not be a solution to the Service District's
waste disposal problems.
If land use controls have been lacking, they have been lacking in the whole
County including the whole Redwood District and not just the "eastern portion".
The eastern portion of the Redwood District has undergone a relatively higher de-
gree of development than the western portion due to its closer proximity to the
City of Grants Pass and not because land use controls have been lacking in that
specific area.
Summary Sheet, second page, last paragraph.
"It is also possible that all project growth for the Service District
(over 50 years) could be confined to the eastern sector utilizing the zoning
densities recommended by the Comprehensive Plan, and thus, the plant would
never have to be moved."
It is true that this is possible, however, so are alot of other things. The
desires of the District residents may not be for 6 units per acre even though this
is a maximum density consistent with the Comprehensive Plan. Alternatives for parcels
of SR-1 acre and SR-2.5 acre are realistic and viable development alternatives for an
area served by sanitary sewers.
Hence the justification for never having to move the plant is based on arbitrar-
ily assigned population density criteria, without mention of other alternative den-
sities and their effect on plant location.
Page 2, paragraph 4 .
"An environmental health survey was conducted in 1970 by the County
Health Department. It was performed house to house and constituted a 50
percent sampling of homes in the entire Service District. There are no more
recent comprehensive surveys for the area, but results of EPA site inspections
appear to support the findings of the Health Department survey."
The scope of the EPA survey should be described. The statement that "results
of EPA site inspections appear to support. . ." is not based on explicity defined
criteria.
Page 10, paragraph 5.
"For the purposes of this EIS, the CH2M projection will be used for all
alternatives, but a caveat should be added. During its research EPA examined
numerous population projections for Josephine County and it appears that the
CH2M and PL&S estimates are high. Rather than provide its own projection, or
evaluate an alternative utilizing a lower design population (which would be
like comparing apples and oranges), EPA utilizes the CH2M projection. When a
project is finally selected, EPA may require the District to provide a new
projection to support present sewer line sizing. The major effect of a design
population of a project is on cost. EPA's use of the CH2M projection in the
2
- 76 -
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is valid because it will permit an evaluation of the relative environ-
mental impacts and costs."
The statement was made that "EPA examined numerous population projections for
Josephine County and it appears that the CH2M and PUS estimates are high". Again
a lack of explicit criteria confronts the reader as to the dates and sources of the
"numerous population projections". EPA should publish its own projection if they
are to require another one from the District. However, either would merely reflect
another individuals best estimate of future trends based on history.
Page 24, Footnote 10; Page 34.. Footnote 23
"Alternative "A" (Phase One) would only serve that portion of the Initial
Service Area that is east of Darnielle Lane. The area that Alternative "A"
would serve has been designated as the Alternative Service Area in Figure 2
(on page 5). It includes a portion of land (between Darnielle Lane and Willow
Lane and Schroeder Lane ) that is not designated by the Comprehensive Plan to
be urbanized. Because of the need for sewer service in this area and the need
to provide service to Rogue Community College the Darnielle Interceptor will
be constructed and sized in conformance with existing zoning densities and
projected growth."
'The Darnielle Interceptor, which serves an area that is not designated
for urbanization by the Comprehensive Plan, would be sized to serve Rogue
Community College and the growth that is projected to occur in conformance
with the plan and existing zoning. The Darnielle Interceptor is necessary
to eliminate use of failing septic tank/drainfields, and eliminate the package
plant at the Community College."
Throughout the report EPA relies heavily on the Comprehensive Plan as a justi-
fication and/or advantage in defining the area of initial sewer service. Inasmuch
as the Plan is a most flexible document always open for revision by due process, EPA
arbitrarily established a need for an area outside of the existing Comprehensive Plan
recommendation, without explicity defined criteria. This analyzation, however correct,
does not appear to be made objectively and is inconsistent with previous reliance on
the Comprehensive Plan by EPA.
Page 27, paragraph 5.
"The composition component is a general "aesthetic quality" indicator
in that it measures the aesthetic quality of an area by looking at all
aesthetic parameters together. EPA HAS ASSUMED THAT AN AREA WITH OPEN SPACE,
PASTURE LAND, AND A RANGE OF WILDLIFE IS MORE AESTHETICALLY PLEASING THAN
A RESIDENTIAL AREA (OTHERS MAY DIFFER WITH THAT ASSUMPTION). Thus, the pro-
posed project, and its consequent secondary impacts, lowers the general
aesthetic value of the western sector of the Service District, but does
not have as great an effect on the eastern sector because it currently con-
tains a large amount of residential development."
EPA's assumption that an area with open space, pasture land, and a range of
wildlife is more aesthetically pleasing than a residential area is totally inappro-
priate because it is just an assumption. However it was the basis for stating that
the general aesthetic value of the western sector of the Service District would be
lowered. However relatively precious our open spaces in this nation appear, it seems
3
- 77 .
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quite realistic that a residential area is more aesthetically pleasing to some people.
More specifically an impersonal and unbiased approach was not utilized and values were
arbitrarily assigned.
The preceeding excerpts while perhaps appearing dogmatic, nevertheless in the
aggregate create impressions in the mind of the reader which do not stem from sci-
entific data (explicitly defined criteria), objectivity and impersonal ness. If these
are the ground rules for the Environmental Evaluation System (Exhibit 2 of Draft EIS)
set out by EPA, then strict voluntary adherence should be accomplished in the Final
EIS for this project.
The following comments are matters of technical corrections which should be
in the Final EIS.
Page 2, paragraph 3.
"In 1965, the eastern sector of the Service District was declared an
"emergency area" by the Josephine County Health Department, . . .".
The eastern sector as described by EPA in the Draft EIS (page 15, paragraph 3)
is that area east of Darneille Lane. The emergency area is east of Dowel!
Road (which is about one mile east of Darneille Lane).
Page 3, Part B Facility Components
B . Fa c i 1 i ty Components
"The proposed project to be constructed consists of an activated sludge
plant, a major interceptor 22,000 feet (about 4.2 miles ranging in size from
12" to 27"), plus 83,500 feet of additional lines (two smaller interceptors,
mains and laterals). The entire sewerage system, at later development, as
shown in Figure 4, totals 157,000 feet (over 16.5 miles) of sewer lines."
The total project, as proposed is more nearly 89,000 feet, not the 22,000
feet of major interceptor plus 83,500 feet of additional lines.
D
The entire sewerage system at later development, if 157,000 feet would equal
29.7 miles not 16.5 miles.
Page 8, paragraph 6
The special election for the general obligation bond issue was November 6,
1973 not 1974 as stated in the Draft EIS.
Page 32, paragraph 3
There are no pump stations in the proposed project as stated here and as
shown on the map of the Proposed Sanitary Sewer System. The only pump would |C
be at the plant site itself to lift the sewage into the treatment units.
In closing I will comment on the following quote (page 12, paragraph 4) relative
to the Environmental Evaluation System (EES): "The system is designed to produce
environmental impact values in numerical units, with the larger positive numbers
4
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indicating the least adverse impacts. The important consideration in comparing
the impact values for each alternative is to consider the relative differences be-
tween the existing value and the values produced by each alternative. The larger
the negative value, the greater the adverse impact of the alternative. A positive
value would indicate a beneficial effect."
Numerical values placed on concepts most often lack the depth and intent of
the communicators meaning in written words and often serve as an over simplification
of the involved issues.
I feel the most important consideration to keep in mind is that the "system
does not produce environmental impact values", nor does it create the relative
differences between alternatives. The system is merely a tool which will remain
lifeless on the workbench until someone picks it up. That someone, whoever they
may be, produces the environmental impact values and creates relative differences
between alternatives.
Thank you for this opportunity to make comments on the Draft EIS.
SijTcere,ly,
JL*.
Robert Weber
Civil Engineer
Josephine County Road Department
RW:fb
- 79 -
5
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- 80 -
Response to Josephine County Department of Roads
1. Revised per request -- see Summary Sheet.
2. EPA recognizes that a wide range of densities are possible within the
limits of the Comprehensive Plan and that the will of the people will
largely determine the zoning configuration of the local area. The
need and timing for relocation of the Alternative "A" sewage treatment
plant will depend on the densities that develop. Thus, as stated in
the draft EIS, the plant may never need to be moved, or it may have
to be moved as early as 20 years after construction, or it may have
to be moved at 30, 40 or 50 years after start-up.
3. The Health Department survey disclosed widespread failures of septic
tanks in the eastern sector of the District. Their results were
based on a random door-to-door sampling of homes within the District.
EPA's inspections were much less extensive and a great deal more cursory,
but they did indicate that there was surfacing sewage in many parts of
the eastern sector. In July and October of 1974 and April of 1975, EPA
representatives visited the area and found evidence of surfacing
sewage at the Redwood School, Dun Rovin Trailer Court, and some resi-
dences. It was felt that these inspections and conversations with
County officials and local citizens confirmed the Health Department's
findings of a wide-spread problem.
4. EPA examined four population projections for Josephine County in addi-
tion to the estimates of CHgM and PL&S; projections by Bonneville
Power Administration (BPA), the Center for Population Research, Stevens,
Thompson and Runyon, inc., and Brown and Ca1 dwell, Inc. They are as
fo11ows:
JOSEPHINE COUNTY POPULATION PROJECTIONS
1975 1980 1985 1990 2000 2020
BPA 36,900 39,000 41,800 44,900 49,600 60,500
Center for
Population
Research 39,600 46,100 52,500 58,900 75,000 125,300
ST & R — 58,000 — 65,000 80,000 121,000
Brown and
Caldwell — - 58,000 - 74,500 104,400
There were no figures for the Redwood area other than those provided by
CH2M and PL&S, but if it is assumed that the District will contain 11,8 percent
of the county population (as is estimated by PL&S), it can be seen that the
District will have about 15,300 people in 2025 compared to the 23,000 projected
by PL&S. This is computed by assuming a county population of 130,000 in 2025.
From these figures it appears that the PL&S projection is very high.
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- 81 -
5. EPA believes that the provision of sewer service for the area not
designated for urbanization by the Comprehensive Plan is consistent
i with the goals of the Plan. Sewer lines within the area will be sized
to provide for projected growth consistent with densities permitted by
the Plan.
6. EPA recognizes that aesthetic values are subjective. As stated on
page 27 assumptions were made as to EPA's characterization of a pleas-
ing environment and it was noted that others would differ. EPA, however,
will stand on its interpretation and definition of what constitutes
an aesthetically pleasing environment.
7. Revised per request -- see page 2.
8. Revised per request -- see page 3.
9. Revised per request -- see page 8.
10. Revised per request -- see page 32.
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scci6et>c poulic mcetiesc KesexKcb ououp
Hughes Building, ^th Floor
115 SW 4th Ave.
Portland, Ore. 9720*f
RECEIVED
July 31, 1975
AUG 4 1975
Richard R. Thiel, Chief EPA-F'S
Environmental Impact Section M/S V*3
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Richard:
This letter contains OSPIRG's comments on the Draft Environmental
Impact Statement for the Redwood Sewage District. In summary, these
comments show that the project, as proposed, will apparently violate
several state-wide goals for land-use planning and Josephine County's
Comprehensive Plan. The comments also note that the EPA will be in
apparent violation of several of its own regulations and a portion of
the Federal Water Pollution Control Act Amendments of 1972 if it awards
a grant for the project as planned.
In an attachment to the EIS which summarizes Josephine County's
procedures for zone changes, the EPA states:
"Basically the procedures mitigate the adverse impact of
sewers on land use, at least as far as those impacts relate
to a project's conformance with the comprehensive plan.
No zone change will be permitted unless it conforms to the
comprehensive plan."
The EPA cannot dispense with the adverse land-use impacts of
sewerage projects it funds so lightly. Under Oregon law (ORS 197r28Q)
actions of counties to implement comprehensive plans must comply with
interim state-wide land-use goals listed in ORS 215.515. ORS 197.015(^)
includes sewerage plans as part of a comprehensive plan;
"'Comprehensive plan' means a generalized, coordinated land-
use map and policy statement of governing body of a state
agency, city, county or special district that interrelates
all functional and natural systems and activities relating
to the use of lands, including but not limited to sewer and
water systems, . . ." (Emphasis added.)
This project is also an existing planning activity. Under ORS 197.275,
"It is intended that existing planning efforts and activities
shall continue and that such efforts be utilized in achieving
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- 83 -
Richard R. Thiel
July 31, 1975
Page Two
the purposes of ORS 197.005 to 197,^30, 215.055, 215.510
215.515, 215.535 and 453.3^5."
Under ORS 215.515 are listed three goals which appear pertinent
to this project.
"(b) To conserve open space and protect natural and
scenic resources.
(e) To provide for an orderly and efficient transition
from rural to urban land use.
(h) To develop a timely, orderly and efficient arrangement
of public facilities and services to serve as g framework,"
Josephine County's procedures do not insure that these goals will be
met. That fact is that:
1. The project does not comply with the Comprehensive Plan of
Josephine County;
2. If implemented as planned, the project will create pressures
for a change in the Comprehensive Plan;
3. Such a change in the Comprehensive Plan will apparently
violate Oregon's interim state-wide land-use goals; and
4. A grant award for construction of the project as planned
will violate the EPA's own regulations for grant awards
and the 1972 Federal Water Pollution Control Act Amendments.
1. The project does not comply with the Comprehensive Plan of Josephine
County; the size of the interceptor is based on a population density
15 times that allowed in most of the area under the Comprehensive Plan.
The EIS states (page 8) that the interceptor is designed to serve
between 20,000 and 23,000 people. This latter figure according to
the EIS (page 10) is based on an ultimate population of three units
per developable acre throughout the district. On pages 1^-15, the
EIS states that in the Comprehensive Plan most of the district is
designated as Farm Residential (5 to 10 acres per dwelling unit) and
that the predominant zoning classification for the district permits
development on minimum five acre tracts of land. As a result, for
the design population to be achieved, the Comprehensive Plan would
have to be changed.1
2. If implemented as planned, the project will create pressures for
a change in the Comprehensive Plan. Having a facility in the ground
that is not being used to anywhere near full capacity will in itself
create pressure for development. Given current and projected scarcity
While exhibit 6 of the draft EIS contends there is a dual recommendation in
the Comprehensive Plan for the eastern portion of the District, we find no
mention of this in the Plan's text. We have not seen the Plan map.
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Richard R. Thiel
July 31, 1975
Page Three
of funds for local governments nation-wide and the effects of inflation,
the local government can be expected to be reluctant to extend service
to new areas before a facility already in the ground nears capacity.
In addition, the method of funding the local share will create
pressures on local government to encourage development of the area.
The major portion of the local share of funding is to be financed
by $7^5,000 in general obligations bonds (EIS page 8). These bonds
will be paid back by property owners through assessments and connection
charges. The local government will be pressed to encourage sufficient
development to pay off these bonds on schedule. Pressures resulting
from this type of funding have been noted in the study done by Urban
Systems Research and Engineering Inc. for the Council on Environmental
Quality entitled "Interceptor Sewers and Suburban Sprawl: The Impact
of Construction Grants on Residential Land Use, Volume I".
3. A change in the Comprehensive Plan to allow the population pro-
jections on which the interceptor size is based will apparently
violate Oregon's interim state-wide land-use goals.
a. Before evaluating the project in light of these goals, it
is necessary to look at the district's comprehensive plan
classification, its population density and use of the land,
and the sewage disposal problems which are cited as reasons
for the project.
(1) Comprehensive Plan Classification.
The draft EIS notes that most of the area is classified
as Farm Residential in the Comprehensive Plan, and
quotes the plan as follows (EIS page 15):
"Farm Residential areas (5 to 10 acres per dwelling unit)
are intended to encourage rural residential living in
an agricultural or open environment through large lot
size development that will minimize conflict between
residential and farm use and establish densities con-
sistent with soil suitability and physical characteristics.
Availability of community water and sewer services is
very unlikely in these areas." (Emphasis added.)
(2) Population density, and use of the land, and sewerage
problems.
The draft EIS (page 15) notes that the district can be
divided into two areas: eastern and western, with
markedly different characteristics.
(a) The eastern portion: According to the draft EIS
(page 15), this portion is:
"« . . fairly well developed and experiencing
severe problems with disposal systems ....
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Richard R. Thiel
July 31, 1975
Page Four
The eastern portion of the District is developed
to a much greater density, [than the western portion]
Within the eastern portion of the District the five
acre minimum lot size serves the purpose of limiting
septic tank development rather than preservation of
rural areas."
In summary, the EIS is saying that the area has
sewage problems and that it is developed to a point
where it is no longer suitable for preservation
as a rural area.
(b) The western portion: On the same page of the draft
EIS, the western portion is described asj
". . . less densely developed with large lots and
fewer sewage disposal problems ... [than the
eastern portion]. Within the western portion of
the District, development has occurred on a scale
consistent with present zoning regulation. In
this sector, the minimum lot size serves two
purposes; it preserves the rural character of the
area and it permits development on septic tanks
only where enough land is available to allow proper
operation of a drainfield."
The draft EIS (page 2) "estimates" that approximately
10 to 15 percent of the sewage disposal systems
"having problems" are located in the western
portion of the service district. The study of
systems in this district noted a total of 173 systems
"having problems". Ten percent of this would be
17 systems in the western section. Moreover, the
EIS lists two classes for systems "having problems".
These are "malfunctioning" and "questionable". The
draft EIS gives no estimate of how many of the
10 to 15 percent of these systems in the western
district were actually found to be malfunctioning,
and how many were merely questionable.
In summary, the sewage problems are much smaller in
the eastern portion, it is not clear how serious the
problems are, and the area is still suitable for
preservation as a rural area.
b. Possible violations of state-wide goals in the eastern section.
The major sewage problems appear to be in this portion. The area
is also more densely developed than the rest of the district, al-
though the EIS does not clearly state how densely developed.
Whether these two factors justify planning for 15-fold change in
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Richard R. Thiel
July 31, 1975
Page Five
population density (from one dwelling per five acres to three
dwellings per acre) is another question. Serious questions re-
main as to whether such a change would comply with the following
two interim state-wide land-use goals as listed in ORS 215.515:
"(e) To provide for an orderly and efficient transition
from rural to urban land use.
(h) To develop a timely, orderly and efficient arrangement
of public facilities and services to serve as a framework
for urban and rural development."
c. Apparent violations of state-wide goals in the western section.
We seriously question that "problems" with 17 to 25 disposal systems
many of which may be merely "questionable" -- constitutes justifica-
tion for putting in any sewer at all, let alone one planned for a
15-fold increase in population in an area now constituting open
space. Such an action directly contradicts the following interim
land-use goal (ORS 215.515):
"(b) To conserve open space and protect natural and scenic
resources." (Emphasis added.)
Moreover, if any part of this district should be developed to the
projected density (and we have raised questions that it should)
it should be the eastern section alone. Given the markedly
differing population densities of the two areas, opening up the
western portion for development simultaneously with the eastern
district would place the County in apparent violation of goals (a)
and (h) already noted in the previous section. As we have pointed
out in part 2, putting in the interceptor as planned will create
pressures for development of these areas.
4. A grant award for construction of the project as planned will violate
tjie EPA'a own regulations for grant awards and the 1972 Federal Water
Pollution Control Act Amendments.
a. According to Title II (201(f)) of the 1972 Federal Water Pol-
lution Control Act Amendments:
"The administrator shall encourage waste treatment
management which combines 'ope_n_ space' and recreational
considerations with such management." (Emphasis added.)
The current designation for most of this area in the Comprehensive
Plan is intended to encourage living in an "open environment".
Awarding a grant for a project based on an ultimate population of
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Richard R. Thiel
July 31, 1975
Page Six
three dwellings per acre when the area is currently designated
as an "open environment" evidences disregard for the portion of
the law quoted. This is particularly true for the less densely
developed western section.
b. ^0 CFR Chapter 1 135.935-^ requires that:
"The construction of the project, including the letting
of contracts in connection therewith, shall conform to the
applicable requirements of State, territorial, and local
laws and ordinances to the extent that such requirements
do not conflict with Federal laws and this sub-chapter."
As pointed out above, the project does not now conform with the
County Comprehensive Plan population densities. A change in this
plan to allow the population levels projected might violate
wide land-use goals in the eastern portion of the district. It
almost certainly violates these goals in the western portion.
c. kO CFR Chapter 1 §35.925 states that:
"Before awarding initial grant assistance for any project
for a treatment works through a grant or grant amendment,
the Regional administrator shall determine that all of
the applicable requirements of §35.920-3 have been met
and shall further determine:
35.925-7(a) The design, size and capacity of such works
are cost effective and relate directly to the needs to be
served by such works, including reserve capacity."
(1) Two separate questions arise here. There is a serious
question that a sewer capable of serving three dwellings
per acre is the most cost effective method of dealing
with sewage disposal problems in the district. This
is especially true of the western district which has
an estimated 17 to 25 systems with "problems". There
is no indication as to how many of these "problems"
are actual malfunctions and how many are merely "ques-
tionable".
(2) If the state-wide goals will not allow the population
density that the project is designed to serve in the
district or portions of the district, no argument can
be made that such excess capacity is cost effective.
It is noteworthy that the County Commission Resolution
(draft EIS, exhibit 6) dated August 22, 197^, regarding
zone changes in the eastern portion of the sewage district
does not mention these state-wide land-use goals. Since
- 87 -
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Richard R. Thiel
July 31, 1975
Page Seven
Oregon's Land Conservation and Development Commission
is charged with interpreting the goals under ORS 197.300,
the only way for the EPA to determine whether such changes
will be allowed under these goals is to seek review by
the LCDC. Under state law, EPA cannot do this direct.ly.
However, it can request the Department of Environmental
Quality to petitions for review:
"ORS 197.300(1) In the manner provided in ORS 197.305
to 197.315, the commission shall review upon:
(c) Petition by a state agency, city or county or
special district, any county governing body action
that the state agency, city, county, or special district
considers to be improperly taken or outside the scope
of the governing body's authority under ORS 197.005 to
197.^30, 215.055, 215.510, 215.515, 215.535 and
Without such a review, the regional administrator will
have no way of making a determination that the project
is or is not cost effective (or that it complies with
state-wide goals.)
We recommend that the EPA request the Oregon Department of Environmental
0_uality to petition the Oregon Land Conservation and Development for
such a review.
Apart from the considerations set forth above, there is one
statement in the draft EIS that we hope the EPA will clarify in the
final EIS. On page 8, the following statement appears:
"If the proposed project is not approved for Federal funding
and an alternative is selected, a new bond election would have
to be held. In such a case there is a risk that the voters
would not approve another bond issue, and based on public
objection to the proposed project, the risk could be sub-
stantial."
This statement raises questions about the extent to which funding fears
will undermine objective consideration of alternatives. Specifically,
we would like to know what weight this consideration will be given
compared to consideration of cost effectiveness and compliance with
state and local laws required by EPA regulations and open space con-
siderations noted in the 1972 Federal Water Pollution Control Act
Amendments.
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Richard R. Thiel
July 31, 1975
Page Eight
We hope these comments are helpful in your evaluation of the
project. If you have any questions please feel free to call.
S incerely,
Sally Rose,
OSPIRG Summer Intern
srrdh
cc: Henry R. Richmond, III, Esq.
Mr. John Vlastelecia
Mr. Hal Sawyer
Mr. Loren Kramer
Mr. Hal Brauner
Josephine County Commission
- 89 -
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- 90 -
Response to Oregon State Department of Environmental Quality
The OSPIRG letter focuses on the Federal, State and local laws and
regulations governing landuse and sewer construction. The Environmental
Protection Agency being fully aware that 6ne of the major issues concerning
the proposed project was its compliance with Federal, State and more
importantly the local comprehensive land use plan asked for a legal opinion
from EPA's Region X counsel. The result of their research is the basis for
the "Preface" section to this final EIS.
We hope that the "Preface" deals adequately with those many concerns
in this comment letter. In addition, two specific requests in the OSPIRG
letter are answered below.
1. Please see letter from Oregon State Intergovernmental Relations
Division which includes comments from LCDC.
2. Josephine County did indicate to EPA that a new bond election would
probably have to be held if the scope of the project was changed. EPA
has not verified this with the County's attorney, nor has it been
EPA's experience that a reduction in project scope requires a new
election. The reference to the possibility of a new bond election
was included to show that additional delay may follow the selection
of Alternative "A".
In terms of the decision-making process the possibility of this delay
will be considered only insofar as it relates to the continuation
of a bona fide health hazard within the eastern sector. The perpe-
tuation of a health hazard is an environmental impact that EPA is
mandated by NEPA to consider.
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STEVEN P. PICKENS ROBERT p. WEBBER
PICKENS AND WEBBER
ATTORNEYS AT LAW
521 South Riverside — AAedford, Oregon 97501
Telephone 779-6023 — 773-7339
29 July 1975
311975
Richard R. Thiel, Chief
Environmental Impact Section M/5 443
ENVIRONMENTAL PROTECTION AGENCY
1200 Sixth Avenue
Seattle, WA 98101
Re: Draft Environmental Impact Statement on Redwood
Service District, Josephine County, Oregon - EPA
Project C-410411
Dear Mr. Thiel:
The following is submitted for your consideration on
behalf of the Redwood Area Citizens Association. The
Redwood Area Citizens Association is against the pro1-
posed service. The Association feels that the EIS is
deficient in a number of areas. These comments are pre-
sented in the order they arise in the EIS.
The statistics cited to establish that a problem exists in
the area are from a County Health Survey in 1970. There
is no evidence provided to establish what was causing the
sewage systems to malfunction. The statistics from th$t
same survey indicate that 24% of the domestic wells in the
area were contaminated, but goes on to state that only 68%
of the wells are in approved locations and that only 36%
are of approved construction. If the reasons for the prob-
lems in the system is poor design or construction, then the
individual owners should be responsible for the replacement.
It would be an extreme remedy to force the service on the
entire district. We feel that the EIS should pinpoint the
cause of the malfunctions.
In regard to the population projection, EPA indicated that
after a project is selected, a new population projection
may be required to determine sewer line sizing. It would
be much more appropriate to require the projection prior
to selecting the project to aid in selecting the right
project.
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Thiel/Webber
29 July 1975
Page 2
Under Social and Economic Impacts, page 22, the EIS correctly
recognizes that community well-being is an important impact
consideration. In this particular case, the most important
consideration. The ground swell of resistence to the pro-
posed project rose when it became evident to a substancial
number of area residents that the sewer would make their
present life style impossible. They had moved to this area
because of its rural character and believed it would remain
rural under the comprehensive plan.
The area is presently dependent on wells for it's domestic
wa_^ejL_s_uppiy. As the density of the area increases, can the
ground water table supply the needs? This would seem to be
a real impact, but it isn't considered in the EIS.
The EIS includes consideration of two (2) alternatives to
the proposed project. The Redwood Area Citizens Association
feels that there are a number of other alternatives which
should be considered or at least have an explaination as to why
they have been rejected. Some of the more obvious alternatives
include:
Extending the sewer presently reaching the
:ern edge of the Redwood Service District to
serve the problem area.
2. Allow the use of individual sewage disposal
units.
The comments presented by the proponents, at the EIS hearing
attempted to justify the need for a sewer system because
of problems at the Redwood School, Rogue Community College
and some private trailer courts. The members of the Redwood
Area Citizens Association are strongly opposed to the use
of the money to solve problems which are the responsibility
of an entire school district, thp entire county and indivi-
dual land owners.
The proponents also imply that it is the responsibility
of the residents of the Redwood District to provide a
place to live for all the people moving to Grants Pass in
the next 50 years. The members of the Association do not
feel any such obligation and in fact are opposed to the
idea of making this area urban, regardless of who pays the
bill.
4
- 92 -
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ThieI/Webber
29 July 1975
Page 3
Thank you for your consideration of the above.
Sincerely,
PICKENS & WEBBER
Robert F. Webber
On Behalf of the Redwood
Area Citizens Association
RFW/jh
cc: Redwood Area Citizens
Association
- 93 -
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- 94 -
Response to Robert F. Webber (Redwood Area Citizens Association)
1. In the draft EIS, EPA discusses reasons for septic tank failures within
the Redwood Service District. The factor contributing the most to
septic tank malfunctions are soil suitability, shallow ground water
table, density of community development and general lack of proper
maintenance. This was further evidenced on July 15, 1975 at EPA's
Public Hearing on the Redwood draft EIS, when Bill Olson of the
Josephine County Health Department stated that "...the soils in the
area all have several disadvantages: 1. shallow soil restrictive
layers; 2. temporarily prsent water table; 3. insufficient slope to
provide removal of interfering ground water." Improved design and
better maintenance techniques will only provide a temporary solution
to the problem of the eastern sector.
2. As density increases ground water supplies may prove to be inadequate
to serve the needs of local residences. In such a case a community
wide water system may become necessary. As stated in your comment
it should be considered as an environmental impact.
3. Extention of the service from Grants Pass to the eastern edge of the
service district was considered as an alternative but was dismissed
as not being feasible. The City of Grants Pass notified Josephine
County that they would not provide service to the Redwood District
due to an inadequate capacity of the treatment plant to handle the
additional waste water flow. See also response to Virginia Webb.
4. Please refer to response to Harold H. McClure.
-------
- 95 -
1083 Me a man Drive
Grants Pass, CR 97526
July 17, 1975 RECEIVED
JUL 21 1975
Mr. Richard R. Thiel, P. 3., Chief EPA-FfS
LJ-3. Environmental Protection Agency, Region X
1200 Sixth Avenue
Seattle, '.Vashington 98101
Dear Lr • Thiel:
At
3
of
the public henring on the Draft £15 for the Redwood
of Grants Pass we turned in a five page critique
the statement.
we re a
reauest f:
1965, the
clared an
Cur main points
of the following: "in
Service District was declared an ' emergency
Hie Josephine County Health Department,..."
only a few hundred acres of the eastern sector
Dowell Road, the Rqgue River, Allen Greek
Redwood Highway/ P- 22; "comaunity health will
r correction on p. 2
eastern sector of the
rea1 by
It was
bounded
the
be
la. proved" (as a result of a sewer plant). MO deaths
thit are sanit ntion-relqted ha ve occurred over the past
ten years and sanitation-related diseases, like hepa-
titis, hnve been minimal and no different from other
are^s of the count y--in feet, much better by fsr than
such areas as Takilma, etc., where really serious
sanitation problems h^ve been corrected by \r oper
septic tanks and privies. There is no com unity health
problem in the Redwood
in
Cur other points concerned the need for full informa-
tion on on-site packaged treatment plants, the cost ->i
Impact of a piped and treated water supply, phasing
out of the Grants Pass Irrigation District, filling
irrigation ditches and constructing storm drains to
take their place, street improvements and lighting,
additional schools, police qnd fire protection—all
the projected costs that would follow close on the
heels of a rapid increase in population because of a
sewer. ;/e also need full information on the expected
makeup of the new residents, since we have a 20,£ un-
employment problem. How could retired people who would
need no jobs be expected to nove from Anaheim to just
another highly taxed urban -irea?;,
v/L^i
-------
- 96 -
Response to Signe M. Carlson
1. Revised per request -- see page 2.
2. Deaths by sanitation-related diseases and the incidence of those
diseases are obiously the best indicators of a severe health problem,
but most health officials rely on other "signals" as well as disease
incidences to determine that a health hazard exists. The most common
signals are surfacing sewage, bacterial contamination of groundwater
(wells), and high fecal coliform counts in surface waters. While there
may be a low rate of sanitation-related diseases when these "signals"
are occurring, their presence, particularly in populous areas, indicate
that a potential health hazard (with real danger) exists. Frequent
examples of these "signals" exist in the Redwood Service District, to
the extent that the Health Department has declared one section an
"emergency area". These facts have convinced EPA that a community
health problem exists in the District, and that they require a community
solution. Our present standard of living here in this community simply
doesn't permit us to wait until widespread deaths or an epidemic results.
3. All of the secondary impacts listed in this letter are common results of
the urbanization process and they do incur substantial local costs. To
project this cost or even make a "ballpark" estimate is beyond the
necessary scope of an EIS.
-------
-97-
/!/>*>
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RECEIVED
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-------
- 86 -
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-------
- 99 -
Response to Comments by Harold H. McClure
1. EPA has and is still investigating new developments in the field
of wastewater treatment, including individual disposal systems.
EPA has found that in specific situations such systems operate
satisfactorily. The Redwood area, however, contains poor soils
for subsurface systems and experiences high groundwater conditions.
These factors make the use of subsurface systems infeasible in parts
of the District where suitable land area is not available.
Systems that do not require subsurface disposal of solids are still
in the experimental stage within the U.S., and as such they are not
considered (at present) a viable of fundable solution to wastewater
treatment problems.
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- 110 -
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- 112 -
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I
•51-
PAGE 4-. -,.-•-'-
A FARM BUREAU OPINION - ".
PrGo
OREGON AGRICULTURE
OCTOBER 19/-5
3'ryatldn" of farm
ssaantial goal
Preservation of farm land has become
one of the high priorities for goals and
and guidelines being considered by the
Land Conservation & . Development
Commission. The need to maintain food
production, open space, "green belts" and
"green spots" was mentioned by partici-
pants in both spring and fall rounds of
workshops conducted by LCDC for citizen
participation and input.
Goals and guidelines, or both, must in-
clude protectfons to allow farmers the
"right to farm". If we are going to be
locked-in. to farming by urban growth
boundaries, exclusive farm use zones or
other devices to preserve farmlands,
farmers must have assurances against
nuisance suits and regulations governing
dust, odor, noise and other conditions that
exist in agricultural production.
Disproportionate share of property
taxes, high tax rates, realistic farm jjse
assessment values and acceptance of farm
use assessed values for estate and inheri-
tance taxes are additional considerations.
Farm lands _must_ also be exemgt_from
Isewer and domestic water assessments and
related taxes. ~^
Vs
Many city dwellers want to move to the"]
country to get away from city noises and f
crowded conditions. They want the pleas-
ures and benefits of country living, ,but
some are requesting conditions be imposed
on farmers without consideration of pos-
sible consequences. Some situations: s-
Some farmers in urban 'growth areas
cannot use aerial application of chemi-
cals as plane or helicopter operators
cannot find an insurance company to
cover their liability.
- Several fur farmers and livestock opera-
tors have been put out of business by
suits requiring them to "abate a
nuisance".
-- Farmers have been asked by police of-
ficers not to work at night as noise from
their equipment prevents neighbors
from sleeping.
By requiring that farmlands be preserved
the Legislature must protect the farmers'
"right to farm" if Oregonians want food
production, ~~opeh"Tpa£e, "green belts/',
"efc 7
sJswsro^
YOU AND YOUR TAXES
By Ellsworth W. Jones, Service Director, WFB Life Insurance Company
TAX BREAK RETIREMENT
election
off :r TC '«.
Employees
o'Je:t';d-but here's a breakdown
Tothe,Editor:
I am writing in support of'
the candidacy of Jesse Fasold,
.for the non-partisan position of
Superintendent 'of Public
Instruction. - ;" ,~ ,.»
- Having been active as a lay
person in education for .a num-
ber of years, I sincerely believe
that Oregon education needs
Jesse Fasold in this position
at this time.
Many new programs have
been undertaken in the past
few years and it would create
severe problems for local dis-
tricts if there were to be a
change in the direction of the
state department's programs.
I especially . support Mr.
Fasold's position on local con-
trol of education. He strongly
believes that decisions affecting
local districts should be made
at the local level and not be
state mandated.
Mr. Fasold will work to
support the efforts of local
school officials to maintain
good education^ programs
without imposing unnecessary
burdens on local people
A vote for Jesse Fasold ii a
vote for strong local control of
education.
Rcbert Humphrey?
Route 1, Box 33
Si.blimity, Oregr.n
<
t.1
TO THE EDITOR:
There is a fpderal pubiirg-
tion entitled "Federal Reg :te."
which any fedeial agency ',.:,!
use -to enact laws inu r:
-------
- 115 -
Response to Comments by Virginia Webb
1. EPA did not investigate the historical land use within the District
although it appears that it was largely agricultural. Presently,
the District displays a mixture of land uses including residential,
commercial and agricultural areas. The western sector consists of
a residential-agricultural mix. The data presented in "Exhibit A"
of Ms. Webb's letter (the data has not been verified by EPA) does
show a relatively wide range of agricultural activities occurring
in the District.
2. EPA did not find any statistics on the occupations of District residents.
Due to relative lack of employment opportunities within the District
it is probable that most non-farming workers are employed outside
of the District.
3. Revised per request -- see page 25.
4. It is probable that the air pollution level of the District would
increase as population growth and urbanization occur. As noted by
Ms. Webb, the increase in automobile traffic would be the primary
cause of increased air pollution levels. It is not anticipated that
the increase will exceed levels established by Oregon air quality
standards because of improved vehicular pollution control, expanded
use of unleaded gasoline, and improved public transportation should
it prove feasible.
5.and 6.
It is possible that a stormwater drainage system will prove necessary
as residential growth occurs within the District. Construction of the
system will have temporary adverse impacts related to construction
activities. The cost of the system is beyond the scope of this report.
The addition of stormwater runoff from a urban drainage system would
have an adverse effect on the water quality of the Rogue River, but
it is not expected to violate water quality standards. As noted in
the draft EIS, page 31, the decrease in water quality from stormwater
will paritally offset the improvements in water quality resulting from
sewerage system construction.
7. EPA indicated in its discussion of aesthetics that it assumed open space
and rural areas were more aesthetically pleasing than residential areas
(an assumption not^shared by everyone). This change in aesthetic
quality would have the greatest effect on development patterns: those
desiring a rural setting would move from the area or not buy into it,
while those people desiring a residential environment Iwould be attracted
to the area.
8. It is possible that construction of a storm water drainage system would
entail placement of culverts and paved spillways at the edge of the
-------
- 116 -
Rogue River. It could cause a change in the aesthetic quality of the
riverfront depending on one's aesthetic values.
9. Connection to the Grants Pass sewerage system was an alternative
that was evaluated by the District and EPA, but rejected for the
following reasons:
a. A 1969 study by the engineering firm of Brown and Caldwell
indicated that a regionalized sewer system serving Grants Pass, the
Harbeck-Fruitdale area, and the Redwood area would not be economically
feasible (C^M reached the same conclusion).
b. The City of Grants Pass was under pressure to expand and upgrade
their plant before the Redwood Service District could organize and
obtain financing approval. Thus, the Grants Pass sewage treatment
plant has been sized to serve only the City of Grants Pass and the
Harbeck-Fruitdale area.
c. The best way to provide service to the three areas (from one
treatment plant) would be to locate the plant at the west end of the
Redwood Service District. This location would, obviously, not elimi-
nate the concerns surrounding the proposed project. It would also
result in the abandonment of the existing Grants Pass treatment plant.
-------
^%
RECEIVED
2 5 J975
EPA-RS
-------
- 118 -
/
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-------
PROPOSE!
Redwood Interceptor
Darneille Intercept
-------
- 120 -
Response to Comments by Robert W. Weir
The I0-1nch line referred to would not be constructed Immediately
but would be deferred until the Comprehensive Plan directs growth
to the area, and there 1s sufficient denand. Josephine County
has adopted procedures (which Include public hearings) that govern
amendment of the Comprehensive Plan and extension of sewers.
-------
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'wildlife
Recreation
Costs
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Water Quality
Mitigation
,Pop. Projection, Growth
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Land Use, Planning
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-------
- 123 -
SUMMARIZATION OF SUPPORTIVE COMMENTS
This section briefly summarizes the major points of the numerous
comment letters received in support of the proposed project. These letters
are listed individually in Table 9 where the main concerns are listed.
The two most common reasons for support were closely related:
1. Supporters of the proposed project were concerned about health
hazards in the eastern sector; and
2. There was concern over contaminated wells and surface waters.
Some brief quotes from these letters follow:
"The health and lives of our children and many residents who live
near the Redwood Elementary School are in imminent danger because of
unsanitary conditions caused by overflowing raw sewage at and around the
school."
"Due to septic tank failures and contaminated ditches our water supplies
could be threatened."
"The Redwood Sewer project is desperately needed. . .We believe our
health could be threatened by the contaminated ditches and the wells could
become infested with all the seepage."
"I would love to be able to drink good well water again. Sewers would
certainly help us do this."
". . .the health of persons living in this area is threatened due to
possible contamination of wells."
Another concern expressed in a few of the letters related to growth
within the project area. Several citizens felt that the sewer was necessary
to prevent continued growth of the District. Some brief quotes follow:
"Do (sic) to the population growth in this part of the country, I think
that the Redwood Sewer Plant is needed."
"The intensified growth of the surrounding area with the moratorium
on subsurface systems, would all seem to point to the dire necessity of an
adequate system "
The support of a sewerage system for the Redwood Service District is
fully recognized by EPA. Concerns over health hazards, unsanitary conditions
and the building moratoreums are valid. Two of EPA's final EIS alternatives
would provide a system which would relieve these conditions. The "Proposed
Project" alternatives, however, has been designated by EPA to be in violation
of the County's Comprehensive Plan. (See Preface) Alternative A would also
-------
- 124 -
relieve these conditions in the eastern sector. EPA notes that out of the
twenty-two letters of support for a sewerage system, fifteen letters are
from people residing at the River Haven Mobile Estate and another four are
from people also residing in the eastern sector. Alternative A, will
alleviate health hazards, unsanitary conditions and allow for growth in
areas now restricted due to poor septic tank soil conditions.
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TABLE 10
LETTERS RECEIVED IN OPPOSITION
- 125 -
Date
Received From
O
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'wildlife
(---•-
Recreation
Costs
Wetlands
iFisheries..- -
.Water Supply
i iiWater Quality
: I \]
| 'Mitigation
i
I
x • x
'•
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1
X
\
i x 'pop. Projection, Growth
i •
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i
Reserve Capacity
(Historic Preservation
Land Use, Planning
•I
x x "Agriculture
, : Construct! on Impact
.- i.. ; ii
^ ^ i Alternatives
;
i i
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1 , ^
iFloodplain Development
Federal Policy
i Sludge Disposal
j
Air Quality
Health and Sanitation
-------
Date
eceived
1975
7/28
7/25
7/28
7/28
7/28
7/28
7/28
7/21
7/28
7/28
7/28
7/25
7/30
8/04
TABLE 10
LETTERS RECEIVED IN OPPOSITION
- 126 -
From
George and Eleanor La Rosa
Mr. & Mrs. Robert E. Bushnell
H.E. Rogers
Richard Bays
Ida Larsen
Mrs. Carl Sether
Robert Weir
Mr. & Mrs. Gerald K. Bushnell
Edgar W. White
Robert and Iva La Rosa
Loren Knight
John D. Ada
GENERAL
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TABLE 10
LETTERS RECEIVED IH OPPOSITION
- 127 -
From
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jWild and Scenic River
'Wildlife
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Recreation
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Wetlands
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Water Quality
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Reserve Capacity
Historic Preservation
Land Use, Planning •
Agriculture
Construction Impact
,.
Alternatives
Floodplain Developmerr
Federal Policy
Sludge Disposal
Air Quality
Health and Sanitation
-------
Date
eceived
1975
7/28
7/28
7/25
7/31
8/04
7/15
7/21
7/21
-
TABLE 10
LETTERS RECEIVED IN OPPOSITION
- 128 -
From
Mr. & Mrs. James M. McDonald
George R. Tweed
Robert T. Kendell , Jr.
Mamie Bucholz
Mr. and Mrs. Leo E. Morrow
Mrs. John F. Richter
Bonney M. Carlson
Mr. and Mrs. W. J. Ritchea
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-------
- 129 -
SUMMARIZATION OF OPPOSITION COMMENTS
This section will present a brief summarization of the comment letters
that either opposed the proposed project or the concept of a sewer system
regardless of service area size. There were a wide range of objections but
this summary will center on the most common which were; 1) high cost, 2) land
use plan violation, 3) loss of agricultural land, 4) lack of alteratives, and
5) nonexistence of a health problem.
With regard to the cost of the sewer, many people feared that large
sewer assessments would force them to sell or subdivide their land:
"As proposed (the proposed project); it could be catastrophic to a
majority of the people, some of whom are . . . living on fixed incomes with
their land as their lifeline."
"With the coming of development people on fixed income such as retirees
will be forced from their homes by expenses for drainage, water systems and
other urban type improvements."
A number of area residents were concerned with possible violation of
the Josephine County Comprehensive Plan:
"The construction of the Redwood Sewer will change an area that is
principally farm land protected by the Comprehensive Plan of 1971 into an
urbanized growth area."
Preservation of agricultural land was frequent concern of those opposed
to a sewer project:
"When my wife and I bought this property we thought we ... could enjoy
having . . . chickens, garden, some beef and enough pasture to feed them. Now
somebody wants to build wall-to-wall houses and bring in 17,000 to 20,000 more
people "
"Enough houses in this purely agricultural area to warrant a sewer would
be hazardous to agriculture."
"As a result of the proposed sewer, zoning will be changed, it will no
longer be zoned for agriculture."
Within the draft EIS, EPA examined three alternatives which did not
include an evaluation of individual disposal systems such as Magic Flush or
Clivus Multrum. Several commentators were critical of this omission:
"Wrte up some data on the many systems like Magic Flush, etc. used
throughout the world "
The last area of major concern was the existence or non-existence of a
health hazard:
-------
- 130 -
"What's all this talk about 'potential health hazard' ?"
"...there have been no deaths from sanitation and the number of diseases
have been minimal "
EPA agrees that sewer assessments may represent a high cost to some
property owners, but it is unavoidable in an assessment program that figures
the cost based on lot size.
Concerns over violation of the Comprehensive Plan are well taken and
the reader should refer to the Preface for EPA's position on the subject.
Related to Comprehensive Plan violation is the loss of agricultural land
which would occur should the District urbanize. The Comprehensive Plan, and
not EPA, is the controlling factor in this area. EPA is rejecting the proposed
project because it results in a loss of agricultural land contrary to the Plan.
Any project that EPA approves will be designed to conform to that Plan.
With regard to the lack of alternatives explored by EPA, the reader
should refer to the response to the comment letter of Harold McClure in the
Comment and Response chapter.
EPA feels that the existence of a health hazard within the eastern
sector has been sufficiently documented by the County Health Department and
EPA's own site inspections. Poor soil conditions coupled with a shallow
groundwater table and relatively dense development make most of the eastern
sector unsuitable for septic tank development. It is the belief of EPA
that sewers are necessary in this area.
Because the proposed project, as submitted to EPA, has been eliminated
from consideration (see Preface) two alternatives are left. Of these,
Alternative A is most responsive to the needs of the area. It eliminates the
existing health hazard while providing for growth, pursuant to the Comprehensive
Plan.
-------
TABLE 11
PUBLIC HEARING TESTIMONY
- 131 -
Date
Deceived SPEAKERS
7_]5_75 Harold McClure
Signe Carlson
Dave Brasheares representing Jose-
phine County Planning Department
• • • —
' Robert Weir
i
! Ruby Jorgenson
i
George Kurtz
] Elmer F. Bond
Cora Johnson
Leo Morrow
Bob Taylor
M. C, Lougridge representing the Grant
Pass and Josephine County Chamber of
Commerce
GENERAL
TONE
Opposed
Opposed
Concerned with
EIS inadequacie
Supports pro-
posed project.
Opposed
Opposed
Supports
Supports
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Date
'.ecelved
7-15-75
•
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TABLE 11
PUBLIC HEARING TESTIMONY
- 132 -
SPEAKERS
Robert Weber - Representing the
Redwood Area Citizens Committee
Cecil Smith
Paul Brandon
R. C. (Dick) Humphrey representing
CH9M Hill
Bill Olson representing Josephine
County Health Department
Robert Kendall
Debbie Barnhart
Mr. Meyers
Kim Jordan
Anne Basker representing Josephine
County Commissioners
Virginia Webb
Dale Smith representing Grants Pass
District #7 Board of Directors
GENERAL
TONE
Opposed
Supports
Supports
Concerned with
EIS inadequacie
Supports pro-
posed project.
Supports
Opposed
Opposed plan-
ning procedures
Opposed
Supports
Supports
Opposed
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-------
Date
Deceived
7-15-75
j
TABLE 11
PUBLIC HEARING TESTIMONY
- 133 -
SPEAKERS
ij
Leroy Merkel
Emil Seleska
Peggy Gilbert
Ed White
Carmen Isbell
Dick Sackett
Margaret Richter
Bob Weber representing Josephine
County Road Department
Mrs. James M. Dunne
(Entered, written letter)
GENERAL
TONE
Supports
Supports
Opposed
Opposed
Opposed
Supports
Opposed
Supports
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APPENDIX
-------
PHILIP C. PATTERSON
TUCT AIA
EXHIBIT 1
LANGFORD AND STEWART
PLAN NF.1VS - U IlBAN D US I G N E US - All* JANHT J. HUMNKUS, Ol-TJCJi MANAGER
4» tiAwnionNK MEOFonn, OKKGON 97501 TKI.KPHOM. (sojj 772-5^03
August 7, 197'i
Josepliine County Board of Commissioners
Joscpliine Coiuity Courthouse
Grants Pass, Oregon 9752G
Dear Commissioners:
Jii accordance -with your request, I have prepared a population forecast for
the Redwood Sewer Service District for the year 2025. The projection includes a
forecast for total comity population, sewer district population and assessment
district population. A forecast was not made for the entire drainage area which
could be served by the location of the proposed treatment plant. The above areas
are shown on the attached map..
Any population forecast is based on historic patterns, recent trends and
assumptions of probable future conditions. There are, of course, obvious limita-
tions on anyone's ability to see future conditions and the longer the period of time
in the forecast, the less reliable the future assumptions. This can be best illus-
trated by taldng yourself back in time to the year 1920. From that point in time,
consider how many of the events and how much of the technological change could
have been foreseen which occurred by 1970.
For the purposes of the forecasts included herein, it was assumed that the
historical growth patterns of Josepliine County provide the most reasonable basis
for estimating future growth. Patterns of growth since 1900 have included two
world wars, at least one major depression, tremendous technological advances,
sweeping social changes and transportation systems v/hich developed from horse
and buggies to rockets to the moon. Even though the rate of change is said to be
accelerating, it would seem reasonable to assume that patterns of the last 50 to
70 years include a sufficient spectrum of change to indicate to some degree how
local population patterns have responded in the past and may respond in the future.
PHII.ir "C. PATTEIXSO'iN' AIA NRD M. I.ANC.FOUD I,YI.li A. STHWAUT
-------
/
X
Josephine (. .cy Board of Commissioners
August 7, 1D74
Pago 2
The lands of technological and transportation changes ma}' have different
effects in the future than in the past and may alter local growth patterns differently.
However, economic ups and downs most likely will be with xis at least 50 years and
these fluctuations have had a greater influence on growth than have changes in
technology as such. This is not to say that technology and economics are separate
and independent factors. It is simply that population growth can be more easily re-
lated to the gross pattern of economic change than to the myriad of advances in
technology.
There are many other considerations such as current national population
growth patterns, federal policies, probability of war or peace, etc., all of which
are significant but unpredictable. Historic patterns have been influenced by all of
these factors and more. Historic patterns are not necessarily a valid indication of
future patterns but, in terms of 50 year forecasts, they appear to be the most rea-
sonable indicators available.
Population for the sewer service district was forecast as a part of the total
county population. The following paragraphs set forth trends, patterns and assump-
tions used to develop the projection.
Between 1900 and 1970, the population of Josephine County increased from
7,517 to 35,546. This amounts to an average annual growth rate of about 2.3 per-
cent. Between 1920 and 1970, a period of 50 years, the county's population grew
from 7, 655 to 35,546, or at an average annual growth rate of 3.1 percent. The
growth rate has varied considerably from year to year and from decade to decade.
Actual census figures by decade are as follows:
1900 - 7,517 1940 - 16,301
1910 - 9,567 1950 - 26,542
1920 - 7,655 1960 - 29,917
1930 - 11,498 1970 - 35,546
Since 1970, population estimates indicate that the county has grown at an
average annual rate of 6.0 percent to reach a population of 42, 300 in 1973. Average
annual growth rates by decade and for selected periods are as follows:
. 1900 - 1910 2.5% 1940 - 1950 1.6%
1910-1920 -0.8% 1950-1960 1.1%
1920-1930 1.5% 1960-1970 2.0%
1930-1940 1.4% 1970-1973 6.0%
1900-1970 2.3%
1920-1970 3.1%
-------
no Coxinty Board 01
August 7, 1074
Page 3
Based on the above historic patterns, it has been assumed that the total
county population will increase at an average annual rate of 0.0% per year to the
year 2025. This rate is slightly above the 1900 - 1970 rate and slightly below the
1920 to 1970 rate. Further, it was assumed that the growth rate between 1973 and
1985 would be higher than the 51 year average because recent trends show a 6. 0%
per year growth. This rate appears to be slowing but will probably exceed 3% per
year for the next few years. The total county population growth, pattern has been
projected as follows:
1973 - 1985 3.7% per year
1985 - 1995 3.0% per year
1995 - 2025 2.77% per year
These estimated growth rates approximate an average overall annual rate
of 3.00% per year and yield estimated populations as follows:
1973 42,300
1985 65,000
1995 87,350
2005 114,664
2025 198,041
The above listed projections may be slightly high but are consistent with past
patterns. If they are high, the facilities will have a. longer period of adequacy. In
our judgement, it is more desirable to have facilities serve a longer period than
anticipated rather than a shorter one. However, any major difference in anticipated
time periods for public facilities can be a problem to the community.
*
Based on the above projections, population was apportioned to the total sewer
service district and to the assessment district. The sewer service district now ac-
counts for 7.1% of the total county population. It was assumed that the district will
account for an increasing percentage of the county total because it is in the urbanizing
area of the City of Grants Pass and because sewers mil further stimulate growth.
The statement that development follows sewers should have more truth in the future
than it has had in the past. Recent state actions relating to septic systems, etc.,
should more strongly direct urban or suburban growth to areas with community
disposal systems.
-------
Joscpliino Co;, / Board oi' Commissioners
August 7, 1974
Pago 4
III addition, it was assumed that the sewer service district would be fully
developed by the year 2025. Based on the population forecast for the entire county,
this appeal's to be a reasonable assumption. This means that by the 2025 date the
sewer service district will have a population of 20,490. The full development pop-
ulation was arrived at by reducing the total area of 3,480 acres by 25% for streets,
parks, etc., to arrive at the net developable area. It was assumed that the net area
would develop at an average of three housing units per acre with an average of three
persons per unit.
The total population of the service district would account for 11.89o of the
total county population by the year 2025. TMs amounts to an increase of from 7.196
in 1973 to 11. 8% in 2025, which also appears reasonable and is consistent with pre-
vious assumptions.
It was also assumed that some development would occur in the sewer service
district outside of the boundaries of the assessment district. Based on records of
the County Health Department it appears that about 12 permits per year can be ex-
pected in the area outside of the assessment district. It was also assumed that no
new septic tank permits would be issued within the assessment district. Based on
these assumptions, the population forecast for the sewer service district is as
follows:
Sewer Service District
Without Sewer With Sewer
1974 . 3,000 3,000
1985 3,660 5,200
1995 3,960 - 7,7?4
2005 4,110 11,282
2025 4,260 23,490
The above forecast without sewers is based on a decreasing number of permits
each year. County polic3r relating to lot size now requires 5 acres for a septic tank in
this area. As growth occurs, availability of such parcels will decrease and population
increases will be correspondingly limited. Estimates used in this forecast are:
1974-1985 - 20 new units per year; 1985-1995 - 10 new units per year; and 1995-2025
5 new units per year.
-------
Josephine County Board of Commissioners
August 7, 1974
Page 5
Assuming the forecasts made above for the sewer service district, a
projection has also been made for the assessment district. Some additional assump-
tions have been made to apply to this smaller area. General development policies of
the county will direct growth into this general section of the county into the assess-
ment district. This policy direction will continue until about 1985 and, for the pur-
poses of this projection, it has been assumed that 1985 will be the year in which this
policy change will occur. For example, after 1985 new sewer lines will be extended
to other parts of the sewer service district and will encourage growth outside the
original assessment district.
It is also assumed that about 12 septic tank permits will be issued each year
in the service district outside of the assessment district. These permits mil absorb
some growth which might otherwise occur within the assessment district. Further,
the assessment district will reach full development by the year 2025. Between 19S5
and 1995 the assessment district mil receive 65% of all of the growth of the sewer
service district. Additional sewer extensions outside the assessment district will be
in the form of laterals along individual streets rather than as a. major effort to sewer
the entire remaining areas outside the assessment district boundary. This process •
of adding smaller areas together with construction time requirements should continue
to direct development into the assessment district until 1995.
Any public water systems provided in the area will be developed first in the
assessment district. This will further stimulate growth in this area. As the assess-
ment district approaches full development, the rate of growth will decline because of
limitations of site selection, etc., as it does in other urbanizing areas. The forecast
for the year 2005 is based on 80% of full development and that for the year 2025 on full
development.
B
Forecasts for the years 1975 to 1985 are based on estimates for the total sewer
service district. Assuming 12 units per year in the sewer service district outside of
the assessment district, the estimated population growth of the assessment district is
equal to that of the total sewer service district with sewers less the existing population
outside the assessment district (1350) and new septic tank permits.
Based on the above considerations, the population forecasts for the assessment
district are as follows:
-------
Josephine County Board of Commissioners
1 August 7, 1974
Page 6
Assessment District
Without Sewer With Sower
1974 1,650 1,650
1985 N/A 3,454
1995 N/A 6,342
2005 N/A 8,424
2025 N/A 10, 530
No attempt was made to project population for the entire drainage area. It
is assumed that sewer service provided in this area would occur in the form of
relatively small areas annexing to the sewer service district. Such gi*owth could
moderately affect forecasts for both the sewer service district and the assessment
district but not to any significant degree. Terrain conditions indicate a generally
lower housing density and soil conditions would permit a greater use of scpuc tanks,
both of which would tend to reduce the general demand for a community sewer system.
The foregoing projections represent a complex series of assumptions relating
to growth in Josephine County during the next 51 years. The assumptions, if not
wise, are at least consistent with past population and development trends in the
County. What the next 51 years will bring is certainly beyond my grasp. (However,
it does appear that, if a sewer system is constructed as planned, it will be used and
will greatly enhance the livability and values of this section of the County 71 •. •: .-
If you have any questions or require further information or supporting data,
please do not hesitate to contact me. •"
i
• Respectfully submitted,
PATTERSON / LANG FORD & STEWART
Ned M. Langford
NML:jjh
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EXHIBIT 2
DESCRIPTION OF AN ENVIRONMENTAL EVALUATION' SYSTEM
A methodology for assessing environmental impacts of a vater
quality plan should use a framework that will produce meaningful assess-
ments and follow the spirit of NEPA. To insure that the methodology
developed would be responsive to the needs of the water quality planner,
it was decided that the methodology should be .
• COMPREHENSIVE, because the environment is an intricate
system of living and nonliving elements held together
by complex processes, and because environmental concerns
relating to large-scale projects range widely from phys-
ical impacts on natural resources - air, land, water -
to fehe impacts on living organisms - plants, animals,
microorganisms - to a variety of impacts on people,
including aesthetic, cultural, and social concerns.
• SYSTEMATIC, because to be effective as a decision-making
planning tool, environmental impact assessments must be
replicable by different analysts and must withstand
scrutiny by various interest groups.
* INTERDISCIPLINARY, because environmental concerns that
are related to resources, living organisms, and people
obviously require a broad range of talents and disci-
plines for analysis, including the physical, biological,
and social sciences.
• FLEXIBLE, because to be useful the methodology must be
able to assess impacts from both small and large-scale
projects, requiring resources (people, time, and money)
commensurate with the scale of the project.
• OBJECTIVE, because to be meaningful the methodology
must provide impersonal, unbiased, and constant yard-
sticks immune to outside tampering by political or
other external forces.
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• BASED ON EXPLICITLY DEFINED CRITERIA, because It ia
important to Insure that evaluation criteria and
values are not arbitrarily assigned. It is important
that the methodology provide explicitly defined criteria
and that procedures for using these criteria be explic-
itly stated; in this respect, the methodology must also
document the rationale upon which the criteria are baaed
• ABLE TO ASSESS TOTAL IMPACT, because to compare alter-
natives it is important not only to specify individual
impacts and their magnitude, but also to provide an
overall assessment.
• ABLE TO DETECT ENVIRONMENTALLY SENSITIVE AREAS, because
to be useful in the local coinmunity the methodology must
provide a warning system of the local environmental
problems.
Elements of the Environmental Evaluation System
Using these requirements, the EES developed by Battelle-Columbus
for assessing water quality management plans and associated projects
consists of five basic features: it
(1) Identifies potential beneficial and adverse impacts
C2) Measures the magnitude of an imp.act
C3) Evaluates the importance of an impact
(4) Determines individual and total impact
(5) Indicates environmentally sensitive areas.
This section of the report discusses how these elements are
included in the EES.
Identification of Impacts
The first feature of the EES relates to techniques for identify-
ing potential beneficial and adverse impacts. Recall from Figure 1, the
environment is described by a set of environmental indicators which are
-------
used to Identify the environmental impacts. To accomplish this identifi-
cation in an orderly fashion, it Is desirable to employ a comprehensive
checklist of environmental quality parameters to insure that the analyst
checks for impacts on all important attributes of environmental quality.
The parameters included in the checklist must be carefully defined to
indicate the geographic scope covered by the projects. However, a too
lengthy checklist might discourage use of the list.
The approach selected by Battelle-Columbus for developing the
checklist was to view the environment as a hierarchy of systems, subsys-
tems, and parameters. By so structuring the environment, the analyst is
less likely to overlook something completely, or to misplace emphasis.
The hierarchical structure used in the EES has four levels:
Level 1 - Most general information—ENVIRONMENTAL CATEGORIES
Level 2 - Intermediate information—ENVIRONMENTAL COMPONENTS
Level 3 - Specific information—ENVIRONMENTAL PARAMETERS
Level 4 - Most specific information—ENVIRONMENTAL MEASUREMENTS.
These four levels of information are related schematically as shox
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Level 3 is the key level of environmental impact within the EES.
Each environmental parameter represents a unit or an aspect of environ-
mental significance worthy of separate consideration. In selecting param-
eters for inclusion in the EES it was decided that
• Parameters should be highly comprehensive indicators
of environmental quality
• Parameters should be easily measurable in the field
• Parameters should be relevant to water quality
management activities
• Parameters should be capable of being measured on a
project scale
• The total list of parameters should be as compact
as possible.
Use of these screening criteria helped strike an important balance between
too little and too much detail. Some of the parameters considered for use
in the EES are shown in Table 1. A complete listing of the parameters is
given later in the report in the section entitled "Content of the Environ-
mental Evaluation System".
TABLE 1. TYPICAL PARAMETERS USED IN THE EES
Ecology
Rare and Endangered Species
Waterfowl
Fish
Aesthetic
Odor
Sound
Aquatic Life
Physical/Chemical
Dissolved Oxygen
Turbidity
Soil Erosion
Social
Recreation Activities
Facilities Location
Community Involvement
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Groups of similar parameters in the EES are defined as environ-
mental components. Each of these components represents terms of inter-
mediate generality. The major classification, environmental categories,
is the grouping of components into similar areas.
Environmental measurements constitute the data needed to obtain
a representative parameter estimate. These estimates may come from
detailed empirical studies in the project area or from qualitative infor-
mation obtained from experts in the project area. The extent of field
data collection required is a function of project characteristics.
Measurement of Impact
The second, and certainly a more complex, feature of the EES
relates to impact measurement. Further, this measurement must be in a
systematic manner which clearly specifies assumptions and criteria and
which yields results that can be meaningfully interpreted, questioned,
and defended.
A variety of approaches to impact measurement are in practice.
.One is to handle "measurement" in a purely descriptive/verbal manner.
This is not satisfactory because criteria are not explicitly stated and
because it leads to use of different criteria by different analysts who
may consciously or unconsciously employ biased .criteria to justify
preconceived notions.
Another approach to impact measurement is to employ sorae form
of rating system employing letter codes or numbers such as
A «= major impact
B = moderate impact
C «= minor impact :
D = no impact.
Number sequences such as 1, 2, 3, 4, or 1, 2, 4, 8, are known to be
in use along with + and - to indicate beneficial and adverse impacts,
respectively. This approach has the advantage of providing more uniform-
ity and, hence, comparability in the way results are written down, but
still has the problem that criteria for assigning the letter or numerical
-------
codes are usually not documented leading to the use of different yard-
sticks by different analysts.
A third and final basic approach to measuring impact magnitude
Is to employ explicitly stated criteria for determining what constitutes
an impact of a given magnitude for each parameter on the checklist.
Results can then be examined with respect to validity of criteria (are
all relevant factors included in the criteria) and with respect to the
accuracy of impact magnitude measurement per se (are all the impacts cor-
rectly related to the criteria). This is the approach that Battelle
recommends for all methodology development which is intended to "cast the
die" for a large number of similar impact assessment activities.
Value Function Approach to Impact Measurement. One approach
employing explicit criteria previously developed by Battelle-Columbus is
to transform all quantitative and qualitative parameter estimates into
(3)
corresponding indices of environmental quality. The index is a number
between 0 and 1, where 0 denotes extremely bad quality and 1 extremely
good quality. To get the index, a "value function" was developed for
each parameter, and then applied to the parameter to get its environmental
quality index. A schematic example of the value function is given in
Figure 4.
x
0)
•a
(J
M
1
CJ
fi)
o
n
w
Measurements of Parameter
(in feet, acres, grams/liter, or other units)
FIGURE 4. SCHEMATIC OF A VALUE FUNCTION
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Some individuals may argue that aesthetic and social impacts
are qualitative in nature and therefore cannot be expressed in quantita-
tive units. Battelle-Columbus feels that if environmental analyses are
to be comprehensive and the results meaningful, a systematic way of
analyzing qualitative impacts is necessary. To date, this method of
analyzing impacts has been found useful by many decision makers.
Environmental Assessment Tree. One .of the most important parts
of an environmental impact assessment methodology is the technique em-
ployed to assess the magnitude of environmental impacts. If this is not
done properly, assessments of both individual and overall impacts will be
invalid.
Although from an analytical viewpoint, the "value function
approach" to assessing impact magnitude offers the ultimate in accuracy
and sensitivity, its application requires substantial manpower and data
resources frequently not available to state and local water quality plan-
ners. The value function approach was designed to evaluate the impacts
of projects in which capital investments might be as high as 100 million
dollars and which might cover several state areas; the scale of such
projects is clearly beyond that of most water quality planning projects.
Because the potential impacts of the larger projects are so widespread,
considerable effort is justified in the collection and analysis of data
and impacts from all the individual environmental parameters. Such
sophisticated approaches cannot be justified, however, in measuring the
magnitude of smaller scale projects.
The approach developed by Battelle-Columbus for quantifying
impacts for relatively small water quality management plans focuses the
analysis at the component level of the environmental hierarchy. Specif-
ically, a statistical technique, Automatic Interaction Detector (AID),
program was used for collapsing measurements or estimates of several
parameters into a single component-level environmental quality index. '
The AID program is a multivariate technique for determining what param-
eters and ranges of these parameters are statistically the most reliable
predictors of environmental quality.
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8
Although the parameters x*ere collapsed into a single component
they are still an explicit and integral part of the EES. Each parameter
in the EES instead of being defined by a value function is defined by
several ranges with each parameter range assigned a quality level in the
0-1 range. An example parameter is shown below.
Parameter Measurement
Between a and b
Between b and c
Between c and d
Between d and e
Parameter Quality Index*
0
0.4
0.6
1.0
Applying the above breakdown to a parameter such as dissolved
oxygen (DO) would produce the following:
1
2
3
4
Parameter Measurement (mg/1)
0 < DO < 2
2 < DO < 5
5 < DO < 7
7 < DO
Parameter Quality Index
0
0.2
0.7
1.0
By defining each of the parameters in the EES in this fashion,
the EES provides the planner with a clear indication of what ranges of
each parameter are considered good (1.0) and bad (0).
The result of the statistical analysis is an Environmental
Assessment Tree for each component. The structure of these trees is
shown in Figure 5. Also, use of an Environmental Assessment Tree can be
Illustrated by using Figure 5. To obtain the component's environmental
quality, first determine in what range the estimate of Parameter A is
located, and then follow the appropriate arrow to the next parameter box.
The same type question is asked for the next parameter, B or C, depending
* The index level assigned to parameter measurement ranges varies from
parameter to parameter.
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on the answer to Parameter A. The environmental quality of the component
Is determined by the intersection of the last arrow on'a branch with the
environmental quality scale. To reach this end point, it is necessary to
evaluate all parameters on a branch. If a parameter is not applicable to
an area, it is assigned a Range 1.
1.0
0.9
.8
0.7
0.6
Quality 0.5
(EQ)
O.A
0.3
.2
0.1
0
—
—
Range 2
lt%
—
—
__
Range 2 '
I <=11 dult
Range 1
Range 2
-*~
:ter B
Range 1 __
-*-
;ter C
Range 1
_
1.0
0.9
OQ
. 0
0.7
OS
.0
0.5 Quality
(EQ)
O.A
0.3
.1
0.1
0
FIGURE 5. EXAMPLE ENVIRONMENTAL ASSESSMENT TREE
Key features of the Environmental Assessment Trees are that one
does not need precise measurements of each parameter entering into the
impact analysis to determine an EQ measure and that EQ measures are deter-
mined for components, not parameters. All that is needed is an estimate
of the range of values for each parameter. This.is considered to be an
important feature of the developed methodology because it is expected that
state and local planners will not alx^ays have precise data on all param-
eters, but that they will want their best estimates to be reflected in
their impact assessments. Also, the component approach is much faster
than working with individual parameters. It is not possible to use
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10
parameter ranges in the value function approach to impact magnitude measure-
ments because precise parameter-by-parameter data measurements are needed;
such detailed measurements are, of course, justified and essential when
dealing with projects of the scale intended to be analyzed by the value
function approach.
As in the value function approach, information is needed on each
parameter because each is an intrinsic part of the overall system. However,
in using the assessment trees the measurements can be confined to a range
instead of a specific point.
Spatial, Time, and Responsibility Considerations. One other
important aspect of impact measurement must be mentioned. .In conducting
the analysis, regardless of the measurement approach used, it is often
necessary to break the analysis into different geographic sectors and time
frames if impacts on different geographic sectors or time frames are ex-
pected to be significantly different. The magnitude of impacts is then
assessed separately for each defined geographic area and time period.
This is required, for example, when impacts during project construction
(short term) and operation (long term) are expected to be significantly
different. Results of the separate analyses are then aggregated or
weighted in proportion to local considerations and desires of the public
to be affected. It is highly desirable to obtain citizen participation
in determining the relative importance assigned to each geographic area
and time period.
To identify and measure the construction and operation impacts,
it is useful to employ criteria for determining what impacts are assignable
to the water quality project. It is felt that impacts from the following
types of activities should be addressed in the EES by water quality manage-
ment planners.
• Direct construction; such as clearing of trees, excavation,
erecting of structures, and elimination of septic tanks
• Indirect construction; such as construction noise, traffic
congestion, increased sedimentation, and construction
solid waste
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11
•
• Direct use; such as wate-r quality changes, water-based
recreation changes, aquatic life changes, and location
of treatment facilities
.• Indirect use; such as direction of urban growth, land
use changes from urban growth, and recreation
accessibility.
Evaluation of Impact
The next element in the impact assessment process is the over-
all evaluation of environmental impacts to be caused by a proposed action
or project. Simply knowing the magnitude of impacts on each environmental
parameter is not sufficient—somehow impacts on the entire spectrum of
parameters must be aggregated into an overall measure of project impact so
that alternatives, can be compared. For this to be done systematically
requires a numerical weighting system to explicitly indicate the relative
importance that each parameter should have in the aggregation process.
Further, to insure that all elements of the environment are given adequate
and consistent attention in all assessments requires a parameter weighting
system that does not vary from project to project. By employing the fixed
parameter weighting system, it is possible to prevent an impact evaluation
system from becoming a rubber yardstick which would negate the value of
the system.
Fixed parameter weights also help prevent the traditional bias in
environmental analysis (toward narrow scope, direct impacts) that motivated
NEPA in the first place. Further, it is Battelle's observation that this
bias pervades impact statements and assessments not conducted with the aid
of a systematic evaluation system. One 200-page environmental assessment
on a water quality management plan reviewed by Battelle-Columbus had two-
thirds of one page devoted to aesthetics1 questions and impacts; it simply
reported that there were none—with no mention of criteria employed or
supporting data. The point is that if the objective of a proposed action
is to improve water quality, one must look beyond environmental impacts
on water quality when doing an assessment and consider the entire system.
The constrained view is appropriate if one is doing an analysis to assess
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12
the effectiveness of the plan in meeting specified water quality objec-
tives but not when doing an assessment of the overall environmental
consequences of meeting those objectives.
Without a fixed weighting system, the weighting, in all proba-
bility, would be performed by individuals who have been preparing water
quality plans in the past. Ideally a broad spectrum of the public should
have input into determining parameter weights, but this is administratively
impractical. Selection of some citizens to perform the weighting would
possibly solve this problem, but this would require a careful selection
and weighting procedure. In many situations for. political, social, or
other reasons, such combined weighting would probably not occur even if
the procedures were available.
This returns the weighting to the individuals preparing the
plans. Their backgrounds are not usually interdisciplinary, and they are
not trained to consider all parts of the system in the weighting process.
Consequently, over-emphasis would be given to areas of technical expertise
resulting in bias in the weighting process. The weights would vary from
plan to plan and from region to region. -Not only would problems occur
from failure to address certain parameters, but, also, evaluation of the
plan by EPA would be very difficult. For these reasons, Battelle recom-
mends use of a fixed weighting system for indicating relative importance.
Component Weights. Each of the components used in the EES
represents only a part of the total environment. It is, therefore,
important to view these parts together as part of an environmental system.
In doing so, however, it must be recognized that some components are more
important than others. Components of "lower" importance cannot be dis-
carded because they are still part of the overall system and must be
regarded as such in all projects.
To reflect the relative importance of the components as indi-
cators of the degree to which the water quality management projects may
disturb or enhance the dynamic stability of man's relationship with the
natural and social environment, all components were assigned relative
weights. These weights are expressed in Component Importance Units (CIU)
and are based on a total of 100 CIU.
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13
The relative importance of the components in the EES was ex-
pressed in commensurate units (CIU) by quantifying the research team's
subjective value judgments. The weighting technique used by Battelle-
Columbus is based on sociopsychological scaling techniques and the Delphi
Procedure. * » ' ' » These two methodologies are used to produce a
technique that, in general,
o Is systematic
• Minimizes individual bias
• Produces consistent comparisons
• Aids in the convergence of judgment.
Sociopsychological Scaling Technique. Numerous sociopsycho-
\
logical scaling techniques are available to rank and weight various
alternatives or sectors using single or multiple criteria. These tech-
niques are used to insure that the comparison between the elements is
consistent and systematic. The technique selected for use in the EES
vas "ranked pairwise comparisons".
In ranked pairwise comparison, the list of elements to be
compared is ranked according to selected criteria and then successive
pairwise comparisons are made between contiguous elements to select for
each element pair the degree of difference in importance. A weighted
list of the elements is the output from this procedure.
Controlled Feedback. Instead of using the initial value re-
sulting from the scaling procedure, an aggregate value based on several
iterations of the scaling technique is preferred. After each iteration,
the participants are given selected information about the group values.
This information can include the group mean and variance, or other perti-
nent information. In the weighting procedure employed in this research,
the participants' mean value was given in the feedback stage. All of the
scaling and feedback was performed via formal feedback statements, thereby
avoiding undesirable direct interchange of judgments of the individuals
in the test.
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14
Environmental Impact
After the Environmental Quality (EQ) for each component has
been measured by the component's Environmental Assessment Tree, and the
Component Importance Units (CIU) distributed to each component, it is
possible to determine the impact expressed by each component. The process
consists of multiplying the Component Importance times the Environmental
Quality once "without" the project and then "with" the project. The differ-
ence ("with" - "without") is expressed in Environmental Impact Units (EIU)
and is a measure of the impact on that component; a positive value expresses
a beneficial impact and a negative value expresses an adverse impact. The
following equation is used in the calculation.
Environmental Impact
(EIU) .
(Component Importance x Environmental Quality) -
(CIU) x (EQ) Wlth
(Component Importance x Environmental Quality)
(CIU) x (EQ) With°ut
For purposes of an environmental evaluation it is important to
understand what is meant by a "with" and "without" analysis. A "with"
project analysis considers the project constructed and in operation for
some period of time. A "without" analysis considers what the existing
condition would be at the same time in the future. A schematic is shown
in Figure 6.
Environmental
Impact
B
C
Project Constructed
Project not constructed
Present
Future
Time
FIGURE 6. "WITH" AND "WITHOUT" ANALYSIS
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15
•
In most situations the "without" condition can be treated as
identical to the existing condition for all practical purposes. In this
case environmental impact is the difference between A and B in Figure 6.
In other cases, however, the "without" condition cannot be
considered to be identical to the "existing" condition. An example of
such a situation would be the following. Assume that one is involved in
preparing an environmental assessment for an areawide plan for a metro-
politan area located downstream of some major form of other totally unre-
lated resource development project (e.g., construction of dam or reservoir)
Thus to identify and measure impacts generated by the areawide plan, the
baseline for the impact assessment must assume that the reservoir or what-
ever the other'development might be is already in place. In this case,
the environmental impact is the difference between A and C in Figure 6.
Thus the need to distinguish between the "without" and "exist-
ing" conditions is especially important in analyzing impacts in areas
where other forces are already known to be underway that will cause changes
in the environmental baseline condition.
c
Environmentally Sensitive Areas
Besides getting an overall view of the environmental impact, it
is also important to know if any fragile elements of the environment would
be disturbed by a proposed project. Examples of such elements are the
Redwood Forests, the Everglades, and the Painted Desert. Unfortunately,
fragile elements vary from project to project, and there is no special
formula to pinpoint them generally. Thus, each parameter of the EES must
be considered to be a potentially fragile element that could, for some
project, be crucial in determining the magnitude and significance of the
overall environmental impact. In other words the overall impact calcu-
lation in terms of EIU by itself is not enough to characterize environ-
mental impact adequately.
The approach used to identify these potential problem areas is
to call out with "red flags" those parameters that change sharply in the
adverse direction. These "red flags" are measured by changes in param-
eter ranges from the "without" to "with" condition.
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16
If a parameter changes from Range 4 to Range 3, it Is defined as
a negative range change while a 3 to a 4 is a positive range change.
Specific rules to detect these "red flags" are
Minor Red Flag: A negative change of one range in any parameter
for any spatial or time analysis
Major Red Flag: A negative change of two or more ranges in any
parameter for any spatial or time analysis.
It must be reeraphasized that a "red flag" is only a warning, not
an absolute definition of a problem. After a "red flag" is identified,
the planner must investigate the potential problem area in detail to
determine whether or not a problem exists. In the identification of "red
flags" all components are treated with equal importance.
Use of the Environmental Evaluation System
in the Planning Process
The purpose of this section of the report is to give the reader
an overview of the planning process and how the EES can be incorporated
into this process. With the aid of an example, use of the EES in the
planning process is illustrated in the final section of this report.
The planning process has been described by many individuals.
Depending on one's point of view, these descriptions may or may not be
correct. Battelle's description of the planning process is shown in
Figure 7. No attempt will be made to justify this description over other
equally acceptable descriptions.
Set
IPrlorttte-i
(
f
Develop
Alternative
Strangles
-
I
Evaluate
Effectiveness
of Alternatives
-o-
Environnpnc al
Assessment j
[loplenent |
ToK
FROBLEWS
FIGURE 7, DESCRIPTION OF TKE VATZR QUALITY PULVSING fRDCESS
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17
In order to assess systematically the environmental •; ,-'.ts of the proposed
action and of all reasonable alternatives, a framework of 4 u.vironnental categories,
17 components, and 64 parameters will be used.
*
ECOLOGY ' - AESTHETICS . '^j
Terrestrial Species and Populations Land
Vegetation Surface Configuration
Browsers and Grazers L<™d Appearance !
Small Game Animals Alignment of Stream, Reservoi. j
Pests and Estuary Shoreline
Aquatic Species and Populations Geological Surface Material
Vegetation - ^-ir
Fish odor
Waterfowl Visual
Pests Sound
Terrestrial Habitats and Communities ' Water
Rare and Endangered Species Flow
Species Diversity Clarity
Aquatic Habitats and Communities . Water Level
Kare and Endangered Species Floating Material
Species Diversity - Biota
Wooded Shoreline
PHYSICAL/CHEMICAL Terrestrial Animals
; Biochemical Water Quality Aquatic Life
Dissolved Oxygen . Vegetation
Inorganic Phosphate '.. Man-Made Structures
Inorganic Nitrogen Architectural Design Structures"
Fecal Coliform Compatibility with Other
Chemical Water Quality Structures and Natural •
Hazardous Materials Environment
Total Dissolved Solids Planting and Site Design '.
pH '.. Composition
' Physical Water Environment Composite Effect " •
Basin Hydrologic Loss Unique Composition *
Frequency of Extreme Flows
Temperature / ; SOCIAL
Turbidity Environmental Interests
Air Quality Recreational Accessibility
Particulate Matter Recreation Activities
Reactive Hydrocarbons ... Educational/Scientific
Sulfur Oxides . Historical/Cultural '
Nitrogen Oxides ,; Health and Safety
'.; Land Use Accident Prevention
Location of. Interceptors . Buffer Zone Development
Reserve Capacity of Sewers and . Facilities Location
Treatment Facilities System Overload
Soil Erosion 7 Community Well-Being
Solid Waste Disposal Controls Community Involvement
' Noise Pollution Population Served by Sewers
Frequency of Disturbing Noise Community Treatment
Intensity of Disturbing Noise Participation
By making measurements or collecting data on each of the above parameters
rejecting environmental conditions both "with" and "without" the proposed project
it is possible to perform an environmental impact analysis. The following steps
will be follov/ecl for developing the parameter data:
» Collect data or perform measurements for each parameter of environmental quality
as conditions now exist in the area to be affected by the project
» Extrapolate current conditions into the future on a parametcr-by-parameter basts so
that the futuie condition of environmental quality. "without" the project can be j
estimated
o Kstimate future conditions of environment;!! quality on a parameter-ln-parameter
basis to develop an estimate of future enviionmt.Mital conditions "with" the project
o
Determine Hie difference in cnviionmental quality between the "without" and
"with" condition; desii.ible or undesirable clum^es Horn the "without" to "with"
condition indicate beneficial 01 nd\eisc impacts respectively.
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>< j • EXHIBIT 3
Current Environmental Quality Conditions to be Affected by the Project
Geographical Location
The Redwood Service District is located in the Rogue River Valley
and lies immediately southwest of Grants Pass in Josephine County. Primary
access to the District is by Interstate 5 and by the Redwood Highway (U.S. 199)
which runs through the center of the District.
The Ecology
Vegetation _
The vegetation of the district consists predominantly of grasses, since
the land is largely in pasture use. Deciduous trees -are common such as Oregon
white oak, California black oak, madrone and ash. Shrubs include manzanita,
bitterbrush, poison oak and buckbrush.
As noted in the Timber Resource section the southern section of the ultimate
drainage area is forested with pines, spruce, oak and madrone.
Fish and Wildlife • '
The Rogue River is nationally known for its salmon and steelhead
fishing. !t has two runs of steelhead, sea-run cutthroat, three chinook salmon
races, coho salmon, four species of resident trout, six species of warm water game
fish, two species of sturgeon and shad.
Figures 1, 2, and 3 shov; the spawning areas adjacent to and near the District,
which lies between river miles 95 and 101. Winter steelhead, fall chinook, and
coho salmon utilize the areas shown on the maps. It should be noted that summer
steeThead utilize Sand and Allen Creeks within the District for spawning. Table 1
shows spawning and migration periodicity for these important fish species, and
Table 2 shews the peak angling months for several important fish species including
•chose named above. It should be noted that all three species that spawn in the
vicinity of the District do so at the time of peak surface runoff (generally winter
during heavy rains). If substantial amounts of inadequately treated sewage are
surfacing end flowing to the Rogue, there may be a potential danger to the fishery
resource.
Table 2 shows that fishing on the Rogue is a year round sport. As population
increases within the study area (and the county as well) more recreation
pressure will be put upon this resource. Preservation of spawning areas is
crucial to the maintenance of adequate resource populations.
The Redwood Service District and the ultimate drainage area support a v/ide
variety of wildlife. The valley lands of the District contain beaver, muskrat,
mink, raccoon^marten, ground squirrels, skunk, and shrews. Cottontail and
black-tail jackrabbits frequent the rural type areas, and river otter can be found
along the Rogue River.
In the forested foothills of the ultimate drainage area big game animals such
as black-tail deer and black bear are found, (the bear is a relatively rare sight)
-------
Jnn. Feb. Mor. Apr. May Juno July
, Sept. Oct. Nov. Doc.
Spring chinook
snlmon
Summer chinook
salmon
Fall chinook
salmon
Coho salmon
Summer stool-
head
Winter steel-
head
Sea-run cut-
throat trout
Rainbow trout
Cutthroat trout
Brook trout
Brown trout
TABLE 1 Spawning and migration pori&dicity, Rogue Basin. Dotted lines
indicate presenco of adult fish in the streams. Dashed lines
donoto migration period. Spawning1 occurs when indicated by a
solid lino.
-------
Tnblc 2. Rogue Basin sport fisheries, months of peak angling
Arcn
Rogue Rivor
(River miles
15-35)
(Rivor miles
35-65)
(Rivnr miles
65-90)
(River miles
90-125)
(River miles
125-165)
Illinois R.
Applcgate R.
Cascade Lakes .
Summer*
stcelhoad
Aug. -Sept'.
Sept. -Oct.
Sept. -Oct.
Sept. -Oct.
Aug. -Oct.
Sept.
Winter
s tcelhond
Do c « - J n n .
Dec. -Jan,
.Dec. -Fob.
Jan. -March
Dec. -Feb.
Feb. -March
Spring
chinook
April-
May
April-
May
May
May
June
Warm-
Fall " ' water
chinook Coho Trout fish
Sept.- Sept.- Mny-
Oct. Oct. Juno
Octoboi- October
Sept.
May & June &
Sept. Sept.
May & July &
June Sept.
Oct. -Nov. Nov. May
May
May &
Sept.
Lowland lakes
May
July
-------
} ) \ w,-
/-
./•' l\
(^ i
«,*IIM WI**N *
i>-
n A
ii^
.JIM
w
./> //
f*Ci ri-oiH*
^c
^%r*f:;'
,/--<_/^--s ^y \ -. ''
V
^•-^'.^.-./.J^
i-- » •'••' .••' '' A 1- ^ i --/
\^\l," .' •;'• V .rvA :.«./
•<
^
I
ROGUE
DRAINAGE BASIN
•A
'-"^•< fc'y
' " rbX.
^\y -A ^\
V •' XSx'-^V'^X*"N'• -i- ••)
S- r-\ * ,»s Vi-x" \ ,. / . /
/\-.^ Vrx"
. Figure 1 """
w/nfer steelfiead
spawning areas
SCALE or
-------
NISV9 30VNIVHQ
>.7,^-
\ .r
•'
v 1 \*.&
N
/ •
\;*\ •'. \ :i!..:\ :
't
-------
^-'vT/ vcr.^... >/>',/•/• ^ \\V'i '• ,,.-- /
-
' /K£^ "K I
/j&-"^ -'^- A v
/ , "--A
- K. ! i^,W
ROGUE
-. Figure 3
co/Jo salmon
spawning areas
SCALE or
> t • > » ' • •
-------
The District also supports populations of mountain and valley quail, ring-
necked pheasant, band-tailed pigeon, hawks, owls, many types of song birds, and
an occasional pileated woodpecker. Waterfowl include mallards, wood ducks, teals,
pintails, scaups, mergansers, some gadwalls, and geese. Blue heron, green heron,
and black crown night heron are frequently seen along the Rogue.
The study area also provides habitat for tha ring-tailed cat which is on
Oregon's list of rare and endangered mammals. As a furbearer the value of the
ring-tail cat is negligible, but because of its uniqueness and low numbers
preservation of its environment is very important.
Also located along the Rogue is the American Osprey which is on Oregon's
list of rare and endangered birds. Preservation of its feeding and nesting
areas is of great importance. The Rogue River shoreline of the District has been
designated as a critical waterfowl habitat area by Battelle Northwest in tne
report, "Oregon; Areas of Environmental Concern" which was done for the State
of Oregon Executive Department and Natural Resource Agencies.
Hater Quality
Rogue River water quality is protected by Oregon State Water Quality
Standards. The beneficial uses that are to be protected in the vicinity of the
District, are domestic livestock and municipal water supply, irrigation, power,
industrial water supply, mining, recreation, wildlife, and fish life. Special water
quality standards have been promulgated for the Rogue River (Oregon Administrative
Rules, Chapter 340) and the major ones are as follows:
"No v/astes shall be discharged and no activities shall be conducted which...
will cause in the Waters of the Rogue River Basin:
1. Organisms of the Coliform Group Where Associated with Fecal Sources
(MPN or equivalent MF using a representative number of samples.)
a. Mainstern Rogue River from the point of salt water intrusion,
approximately R.M. 4, upstream to Dodge Park, river mile 138.4,
Bear Creek; average concentrations to exceed 1000 per 100
milliliters, except during periods of high surface runoff.
2. Dissolved Oxygen (D.O.). Dissolved oxygen concentrations to be less
than 90 percent of saturation at the seasonal low, or less than 95
percent of saturation in spawning areas during spawning, incubation,
hatching, and fry stages of salmonid fishes.
3. pH (Hydrogen Ion Concentration). pH values to fall outside the
range of 7.0 to 8.5."
Generally, Rogue River water quality, adjacent to and below the District,
meets the standards, and what violations occur, are naturally caused. Table 3
is a compilation of water quality data for the Rogue near the District. It indicates
some dissolved oxygen violations, but these are rare and are caused by natural flow
and temperature fluctuations. The temperature violations occur during the summer
when stream flow is low and they are considered naturally occurring J"« The table
/
1. Draft Deyelj)pment Document for a Water Quality Management Plan for the •
Rogue River Basin, Department of Environmental Quality.
-------
8
also Indicates high phosphorous levels in the river but these are also measured at
upstream sampling stations where they occur year round. Since other streams
1n the area that originate in the Cascade'Mountains also contain high phosphorous
levels, it is generally believed that phosphorous is a largely naturally occurring
pollutant in the Rogue System.
These naturally occurring water quality problems are considered to have slight
impact on the beneficial uses the standards protect in the Redwood area, and, further
there is little that can be done to control these problems. The main control avail-
able is to prevent humans from compounding the minor natural problems with pollutants
generated from "human activity".
Station
9 Grants Pass
R.M. 101.2
Test of Grants
bss R.M. 98.1
•
b
Date
6/3/68
10/2/68
6/10/69
9/29/69
. 6/30/70
9/1/70
7/27/71
1/10/72
7/10/72
1/22/73
6/3/68
10/2/68
6/10/69
9/29/69
6/30/70
9/1/70
7/27/71
V10/72
7/10/72
V22/73
TABLE 3 ROGUE RIVER
Flow (CFS) Terp CC
1888
750
4740
1231
1678
961
1868
N/A
H/A
N/A
1888
750
4750
1091
1678 .
961
1868
N/A
N/A
N/A
20.0
13.0
13.5
17.0
16.0
IB.O
21.0
5.0
19.0
4.0
20.0
13.0
13.5
17.5
16.5
17.5
21.0
$.0
19.0
5.0
HATER QUALITY (REDWOOD AREA)
D.O. HG/L D.O. "i
10.1
8.4
10.1
9.9
9.1
8.1
8.6
13.0
10.2
13.0
10.3
8.0
9.8
10.7
6.9
7.8
8.5
12.5
9.8
13.0
113
82
99
102
81
88
98
105
109
99
115
78
:96
111
79
85
97
101
104
101
PH
8.3
7.3
7.1
8.3
7.5
7.3
7.7
7.3
8.0
7.3
8.3
7.3
7.1
8.3
7.1
7.1
7.1
7.3
7.7
7.3
Fecal
con/ioo KL
45
60
N/A
60
N/A
45
46
130
60
450
620
N/S
60
N/A
60
130
N/A
£0
620
Phosphorous
HG/L
0.14
0.30
0.09
0.36
0.27
0.21
0.17
H/A
N/A
N/A
0.24
0.32
0.16
0.54
0.28
0.24
N/A
N/A
N/A
K/A
Air Quality
The only air quality parameter that is presently measured in the
Redwood area is for particulate matter (soot, larger dust particles, etc.) and
that is sampled in Grants Pass. The geometric mean is 49.14 micrograms per cubic
meter, and is probably about average for urban areas within Oregon.
Hydrology
High flows in the Rogue River occur during the winter and spring
when most of the rain falls. Low flows occur in the late summer and fall. Since
the average low temperature is well above freezing there is little snowfall. This
results in rapid runoff of precipitation, with the rainfall showing up as runoff •
on Rogue River hydropgraphs within a few hours after a rainstorm.
-------
Floods in the valley are generally the result of heavy rainstorms, and occur
1n the winter when the ground is saturated. The floods are of short duration with
relatively high-peak discharges. The maximum discharge of record for the Rogue River
was 152,000 cfs at Grants Pass (compared to a mean annual flow of 3,470 cfs) which
occurred during the flood of December, 1964. This was a 50 year flood (meaning it
has a 2 percent chance of occurring in any future year), and it inundated many
portions of the District including the treatment plant site (see figure 4).
The groundwater table within the District is fairly shallow, which creates problem
for successful operation of septic tanks and the maintenance of well water quality. ^Al
of the District's domestic water is taken from individual wells, most of which are 50
feet or less in depth and yield from 5 to 20 gallons per minute. Problems arise during
the winter whan the ground is saturated with water and individual disposal systems
begin to fail which increases the potential for ground water (hence, well-water)
contamination from sewage.
Aesthetics
Topography
The dominant topographical feature of the Service District is the
Rogue River which forms the northern boundary of the District and ultimate drainage
basin. As the Rogue flows west from the District, the river valley narrows to
form the beautiful canyon for which the Rogue is famous. This section of the
Rogue, from the confluence of the Applegate River and the Rogue to the mouth of
the Rogue is designated as part of the National Wild and Scenic River System.
The stretch of the Rogue River that is adjacent to the District is slow
flowing with a generally straight alignment and high banks. The shoreline does
flatten out, with subsequent enlargement of the flood plain, at the western
end of the District near the proposed treatment plant site.
The District boundaries presently enclose an area that is relatively flat
(less than 3% slope) with an average elevation of about 900 feet above mean sea
level. The ultimate drainage area encompasses topography of a more varied nature.
This section of the study area includes portions of the foothills of the Siskiyou
Mountains, with elevations as high as 1600 feet above mean sea level. The area
is characterized by more rugged terrain and less land suitable to community
development needs.
Outside of the District and the ultimate drainage area, the most important
topographical features are the Coast Mountains to the west and the Siskiyou
Mountains to the south. Both affect the climatic conditions and drainage patterns
within the ultimate drainage area and the District. .
Soils
The Redwood Sanitary District and the ultimate drainage area are
composed of three main soil groups; the Barron series, a deep somewhat excessively
drained soil formed on granitic fans; the Newberg-Evans association, a well drained
soil lying principally in the Rogue River and Applegate River flood plains; and the
Siskiyou series, an excessively drained soil formed on forested upland slopes.
Figure 5 is a general soil map of the study area, and depicts the location and
extent of the three soil groups.
-------
10
The largest soil group in the study area is the Barren coarse sandy loam'which
lies upslopc from the Newberg-Evans association in the valley terraces and low!rinds.
Typically, the Barren soils have "dark grayish brown, coarse sandy loam, very friable
(crumble easily), slightly acidic surface layers, and light olive brown, coaruo
sandy loam, v/eak blocky, slightly acid subsoils to depths of 40 inches or rr.oro."
Most of the Barren soil within the study area has a slope of less than 3 percent, but
some southern areas have slopes ranging from 3 to 12 percent.
The next largest soil group in the study area is the Newberg-Evans association.
This association is comprised of 55 percent Newberg soil and 45 percent Evans soil.
The association is located primarily in the flood plain and valley terraces of the
Rogue River Valley.
The Nev/berg soils have dark brown, very friable, sandy loam surface layers
and dark brown, very friable, sandy loam subsoils. The Evans soils have thick,
dark brown, friable, loam surface layers and dark brown, massive, loam subsoils.
Both soils go to depths greater than 40 inches.
The third soil group is the Siskiyou series, located on steep slopes, with
coarse sandy loam surface layers and subsoils. There is 20 to 40 inches depth
to weathered quartz diorite and 60 inches to hardrcck.
Agricultural Land Capabilities:
Barron course sandy loam-The primary use for Barren soils is for irrigated
hay and pasture land. Within the District (where most of the Barron Series,
0 to 3 percent slope lies) the primary use of the soil is for this purpose. The
eastern portion of the District, because of- its urbanizing character, utilizes a
smaller percentage of its land for pasture and hay than the western section.
Other agricultural uses of the Barron series are limited by its erosiveness
and limited water holding capacity.
Newberg-Eva n s a s s o c i a tion-This soil association ranks with the most important
agricultural soils of Josephine County. Since the soils are adjacent to the
Rogue, they are easily irrigated, and are suitable for growing most crops appropriate
to the Rogue Basin.
Siskiyou coarse sandy loam-This soil has the least suitability for agricultural
development of tne three groups. Because of steep slopes and low water-holding
capacity its use for agriculture is limited. Within the study area, the Siskiyou
soils are not used for any agricultural purpose, but are predominantly forested.
Soil Limitations for Community Development:
The characteristics and capabilities of the soil are the crucial determinants
of an area's ability to support community development without the benefit of a
sewerage system. These limitations are discussed below.
Barron coarse sandy loam-The subsoil of this series is a semi-cemented
compact.clay loam which restricts the downward movement of water. During winter
months the topsoil becomes saturated. Combined with a shallow groundwater table,
this saturation often prevents successful operation of septic tanks in areas of
low density development. Within the District this problem is evidenced by the
failure of septic tanks and surfacing of effluent within the eastern portion of
the District.
-------
Figure 5 .
COUNTY KEY
«2«30'
DOUGLAS
JACKSON
CALI PORNIA
IDENTIFICATION LEGEND
(Josephine County)
Soil Series and
Symbol Land Types
Ae Abegg
Ba Barren
Bk Brock man
Ca Camas
Cd (Cd)*
Cm Coleman
Cv Cove
Ev Evans
Jo Josephine
Ke Kerby
Keg Kerby, gravelly
Ne Newberg
Ps Pearsoll
Ru Ruch
Si Siskiyou
Tk Tokilma
Vo
-------
12
.Development may occur on larger tracts of land, usually at least 5 acres
In size depending on the individual tract.
Newbe'rg-Evans association-This soil is better drained than the Barren series
and is not as limited in its use for septic tank drainfields. It is rated as
having a moderate degree of limitation in this respect, and it is recommended
that a 2'-2 acre minimum lot size be required for septic tank development. In terms
of construction limitations, the soil is easy to work with and presents no problems
to construction activities. However, the proximity of this soil type to the Rogue
and its location in the flood plain should be considered in any development plans
to avoid large scale damages to residences.
Siskiyou coarse sandy loam-Of the three soil 'groups, the Siskiyou series is
the most limited with regard to community development. Its steep slope creates
an extreme erosion hazard and rapid runoff of precipitation. It is recommended
that development on individual disposal systems be limited to 10 acre tracts of
land.
Climate
Since the study area is located south of the major Pacific Northwest
storm belt, it receives less annual rainfall and has fewer cloudy days than IT ore
northern areas of Oregon.
Table 4 gives climatic data, recorded in Grants Pass, for the period
1934-1965.
TABLE 4 CLIMATIC SUMMARY OF GRANTS PASS
Month
January
February
March
April
May
June
July
August
Sivtember
October
November
December
/.nnnnl •
Mean
maximum
46.0
53. 7
CO.C
C8.G
75.3
81.4
90.0
88.9
83.7
69. 1
53.3
47.0
6K.1
Temperature. F
Mean
minimum
32.5
33.9
34.8
38.2
43.2
48.0
51. C
50.2
45.2
41.0
3C. 1
34.2
40.7
Mean
39.3
43.8 .
47.7
53.4
59.3
64.7
70. ft
C9.6
6-1.5
55.1
44.7
40. C
54.4
Highest
recorded
65
72
84
94
99
108
110
105
10-1
93
74
65
110
Jxm-est
recorded
5
5
18
25
27
33
39
'. 3U
28
22
• 14
12
5
Precipitation, inches
Mean
6.04
4.71
3.35
1.89
1.3H
0.88
0.27
0.28
0.6H
2.82
4.24
5.89
32.42
Greatest
daily
3.00
4 30
2.30
2.00
1.61
1.50
1.52
0.60
1.50
5.27
2.47
4.07
5.27
Source: Itccords of U.S. Wcatliur Bureau for the period lU3-4-l'jGO.
Average annual precipitation is about 32 inches, with 75* of this total
falling between November and March.
-------
13
The area experiences mild temperatures throughout the year, averaging 68
degrees and 41 degrees at the high and low ends of the temperature range.
Generally, winters are wet with moderately cool temperatures and summers are
warn and dry. The average growing season, defined as the period between the
last 32 degree temperature in the spring and the first 32 degree temperature
in the fall, is 158 days.
The prevailing wind direction is from the west, approximately parallel
to the axis of the Rogue River Valley.
Mineral Resources
At the present time there are no mining activities underway within the
District and none were found in the ultimate drainage basin. The District is
largely rural and rural-residential so it is unlikely that mining would become
a significant activity in the area.
Timber Resources
Within Josephine'County the most important economic activity is
timber harvest and wood products manufacturing. Within the District there is
virtually no timber resource. That is not to say there are no trees, but means •
that there are few stands of 'trees suitable for commercial harvest. The main
species of trees in the District are pines, cottonwood, oaks and madrones. In
the southern section of the ultimate drainage area, which is largely forested, the
main tree species are pines, spruce, and some oak and Hadrone. At the present time,
there is no timber harvesting occurring in this area.
Recreation
The second most important industry in Josephine County is tourism,
with most of that industry seeking recreational opportunities such as boating,
camping, hunting and fishing. The Rogue River Basin provides extensive recreational
resources. Shroeder Park (owned by Josephine County) .is located within the District
and comprises approximately 15.2 acres. The County has indicated in its compre-
hensive plan that it would like to expand the park to 28 acres. Presently the
park offers limited overnight camping and has day use picnic areas. The park
also has a boat launching ramp which affords boaters and fisherman easy access
to fishing areas. There are no other designated recreation areas within the study
area, and most other recreational use is fairly limited.
Land Use Patterns
The Josephine County Comprehensive Plan was adopted in 1971 by the
Josephine County Planning Commission. Zoning regulations were adopted in 1973.
Figure 6 is a zoning map of the District and ultimate drainage area and Table 5
is an explanatory compilation of the relevant zoning designations for the study
arpa
area.
-------
14,r
•- ' -:: cr
«.. vv- ^
V)
S--NX- '-- iJ\\ ::- /*/
^x^---^
-------
TABLE
Designation
Suburban Residential: SR-5
5 LEGEND OF ZONING DESIGNATIONS1'
Characteristics
Suburban Residential: SR-2.5
Limited Commercial: LC
Light Industrial: LI
General Commercial : GC
5 acre minimum lot size
Use for agriculture, single-family
dwelling and planned development.
2.5 acre minimum lot size
Use same as SR-5.
6,000 square foot minimum lot size
Use limited to commercial activities.
No minimum lot size
Use limited to light industry, e.g.
auto service station, trucking terminal,
wholesale distribution and sales.
No minimum lot size
Use same as LC but includes labs, commercial
amusement or recreation use and wholesale
business, storage companies, etc.
1.
See Josephine County Zoning Regulations for complete descriptions.
Prior to the adoption of zoning regulations, the development of the Redwood
area occurred in a relatively haphazard manner, vn'th low density development
Occurring in the midst of large-size land parcels and vice versa.
The vast majority of land in tha western portion of the District and the
ultimate drainage area is presently used for agriculture or is vacant.
«i.
The predominate zoning classification within the study area is for Suburban
Residential (SR-5) which permits residential construction on minimum 5-acre
tracts.
The study area also contains suburban residential zones with 2.5 acre minimum
lot sizes, some commercial zones, and a small amount of Forest Resource District,
which requires a minimum lot size of 10 acres.
Presently, there is a great deal of development that has occurred (prior
to adoption of zoning regulations), and is inconsistent with current zoning
designations. Most of this development is residential and has taken place in
the ISA, where many homes are on lots of less than one acre. This portion of
the District is relatively densely developed so it is where most of the failing
septic tanks are located.
The western portion of the District is mainly zoned Suburban Residential
(SR-5) and most homes in the area satisfy the minimum lot size requirement. The
land is used for hay production, pasture, and sorie truck crops.
-------
16
The ultimate drainage area is largely zoned SR-5, with some SR-2.5 and
FR (Forest Resource District). Most of the area is forested with some agri-
cultural lands in the more level sections of the area. As in the western
District area most lands in the ultimate drainage area are sized and used in
accordance with county zoning regulations and the land use plan.
Social and Economic Characteristics
Population and Growth Trends
Essential to any type of community planning, population projections
provide the basis for design criteria for many public services, including
sewage treatment plants, interceptors and collection systems, water systems,
and school facilities. To make an accurate estimate, which is critical, one
must examine past growth trends, evaluate the conomic determinants of growth,
consider the objective (land availability, suitability, etc.) and subjective
(aesthetics, etc.) aspects of the area, and, finally, exercise some common
sense.
The response to the comment letter of the Josephine County Road Depart-
ment contains a table of population projections other than those of CH2 M
and PL&S. EPA feels that the PL&S prediction is too high.
In any case, it is more than likely that the District is going to continue
to grow, although the rate of that growth is dependent on a number of factors.
First, if no sewers are built, the amount of growth that can occur is
severely limited,, both by subsurface disposal regulations and existing zoning
patterns.
Second, growth is dependent on the birth rate (and mortality rate) and
the rate of in-migration. Nationwide, the birth rate is declining, and there
are indications that the nation's population may stabilize within the next
two decades. In addition to meaning that less people are born and, hence,
a lower growth rate, it also means that the quantity of in-migration will
decline over time because there is a smaller pool of people from which migration
can occur. Josephine County population growth contains a high in-migration
component. It has been estimated to be as high as 42 percent.
Third, growth depends on the economy of an area. In times when the economy
is booming so is population growth, and when the economy is unstable or on the
decline, population growth declines, sometimes to the extent of a net out-
migration occurring.
Even though the Josephine County economy is not the most stable, being
dependent on the volatile timber industry, growth will continue to occur
because of in-migration of retired people and the continued diversification of
the county economy.
The District will continue to grow because of its attractiveness to
retired persons and its proximity to Grants Pass.
-------
Economic Conditions
The major industry in Josephine County is forest products manufac-
turing. Two out of every three employees in the manufacturing segment of the
County economy are workers in the lumber industry. It is expected that the lumbar
industry will continue to dominate the County economy in the future.
The second most important, and most rapidly growing, sector of the economy
is tourism. In the decade 1960-1970, income from tourism doubled to an amount
in excess of 26 million dollars. With income and leisure time increasing, and
the growing amount of in-migration the tourist trade income is expected to double
again in 10 to 15 years.
Agriculture follows lumber and tourism in the economic hierarchy, and has
played a declining role in the County economy. Josephine County has a high
unemployment rate. From 1960 to 1970, the rate averaged 8 to 10 percent, and
was 11.5 percent in 1970. Since the rate is highly sensitive to economic
fluctuations of the timber industry, the rate may be much higher, 15 to 20
percent, at the present time (the timber industry is presently experiencing
hard times).
The Redwood Service District does not have any industry within its
boundaries, and given its rural-residential character, it is unlikely that
industrial development will occur. - It is likely, and in keeping with County
trends, that most District workers are employed outside of the District in the
lumber industry or its support activities (trucking, retail establishments, etc.).
Some District residents supplement their income by farming and there may be a
few who are wholly supported by that activity or dairying.
The agricultural resources (arable land) of the District may become more
valuable and important in the County economy of the future. Presently, the
County economy depends on the highly unstable lumber market and seasonal tourist
income. It has been recommended in one study ^/that the Josephine County
economy should diversify, and this includes expansion and intensification of the
agricultural industry. The study notes that dairying is a profitable activity,
and that through improved irrigation techniques, increased marketing efforts,
and improvement of farm management, agriculture could become a more prosperous
contributor to the economy. Overall, about 3.7 percent of land in the County
is devoted to agriculture, and only 10 percent of that is devoted to intensive
crops. If an active effort is undertaken to diversify the economy, including
expansion and improvement of agricultural practices, the land within the District
may become extremely important.
-------
-------
POLICY ON KATCR POLLUTION
The State policy on water pollution for the Rogue River Basin is EXHIBIT
set forth in the Oregon Revised Statutes, Chapter 835.077, as follows:
Whertos the pollution c' the waters of this State constitutes
a menace io.public !.?ullh *nd welfare, creates public nuicr.nccs,
is harmful to i.-ilolifc, fish and aquatic life arid ii:.p.^ira
domestic, ^oricultural, industr*,-,!, recreational and other
legitimate l-encficial uses of the water, whereas the problem
of water pollution in this State is closely related to the
problc.ii of water pollution in adjoining states; it is hereby
doclarerf to b-> tho pyoiic policy of this Mate to-consrrve the
waters of the Sui.e ?r.d to protect, maintain And improve the
Quality thercoi for iw'jlic water supplies, for the- propagation
of wildlife, fish and aquatic life and for domestic, agri-
cultural, industrial, municipal, recreational and other
legitir.nte beneficial uses; to provide that no waste shall
b.? discharged into any waters of this Stato without first
receiving th? necessary treatment or cthor corrective action
to protoct the legitiM3t.? beneficial uses of such waters;
to provide for ths prevention, abatcr.;?nt and control of new
or existing water pollution; and to cooperate with other
agencies of the State, agencies of other states and Federal
Government in carrying out these objectives.
QUALITY STANDARDS
The following is a condensation of several sections of the Oregon
Administrative Rules, Chapter 340, Regulations Relating_to Water Q-nlity
Control in Oregon. The general policy is one of nondegr<:dation.
GENERAL WATER QUALITY STANDARDS
The following General Water Quality Standards shall apply to all
waters of the State except where they are clearly superseded by Special
Water Quality Standards applicable to specifically designated wators of
the State.
No wastes shall be Hijch-irned and r.o activities shall be conducted
which either alone or in combination with other wastes or activities
will cause in any v/aters of the State:
1. Th2 dissolved oxygen content of surface waters to be less
than six (6) milligra::is par liter unless specified other-
wise by special standard.
2. The hydrogen-ion concentration (pli) of the v/otsrs to ha
outsicla the rar.nc of 6.5 to 8.5 unless specified otherwise
by special standard.
3. The liberation of dissolved gsses, such as carbon-dioxide,
liydrogsn sulficle or cny other gases, in sufficioi.t quantities
to cause objectionable o.-Jcrs or to faa dc-lcteriojs to fish
or othor aquatic lire, navnodtion, rocrjaticn, or other
reasonable uses trude of ruch waters.
4. The developr.ient of fungi or other grov/ths having a delet-
erious effect on sLrcau botto.iu, fir.h or other aquatic
• life, or which arc injurious to hsalch, recreation or
industry.
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5. The creation of tastes or odors or toxic or other con-
ditions tlwt ore caletcrious to fish or oilier iiquatic
life or affect the potability of fish or shellfish.
6. The formation of appreciable hotter or sludoe deposits
or the formation of any rrgr.mc or inorqcnic c;|josits
deleterious to fiih or other aquatic life or injurious
to public hcelth, recreation or industry.
7. Objectionable discoloration, -turbidity, scun, oily
sleek or floating solids, or cost the aquatic life with
oil films.
8. Bacterial pollution or other conditions deleterious to
waters used for t'....:estic purpor.es, livestock -.-atcnng,
irrigation, batnirs, or shellfish propagation, or L-a
otherwise injurious to public health.
9. Any rceasureable increase in temperature when the
receiving water tmparatures are 64 F. or greater; or
more then 0.5'F. -increase due to a singlo-.'ource
discharge v.'hen receiving water tenrc-rati'r:;? «:s-a 63.5 F.
or less; or morn than 2"F. ircrecsa due .to fill sources
combined whsn receiving water temperatures arc 62 F.
or less.
10. Aesthetic conditions offensive to the human senses of
sight, taste, sr.:sVI or toucn.
11. Radioisotopo coiicentrations tn exceed Msxi'm-'n Per-
• Ciissible CoMceritruUoris (.'il'C's) in dririkii-.j \.:>'.c.rt
edible fishas or Ehellfishes, i/ildlif'e, irrigated crops,
• livestock end dairy products or pose an external rad-
iation hazard.
12. The concentration of total dissolved gas relative to
atmospheric pressure at the point of sample collection
to exceed one hundred and five- percent (1CL/-) of satu-
ration, except i:hen stream flew exceeds the- 10-yecr,
7-day average flood.
SPECIAL WATER QUALITY STANDARDS
The provisions of this sub-section shall be in addition to and not
1n lieu of the'General Water Quality Standards, '..'here there is a con-
flicting requirement with the General l!at?r Quality Standards, the Special
Water Quality Standards shall govern.
Ho wastes shall be discharged and no activities shall be conducted
which either alone or in conjunction with other wastes or activities
will cause in the Waters of the Rogue River Basin:
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1. Organisms of the Coliforn Group Where Associated \*ith
Fecal Sources (liPi! or equivalent itr" using a represen-
tative msiber of samples.)
a. Mainstcnt Rogue River frcn the point of salt water
Intrusion, approximately R.I-J. <:•, upstre-tn to Dodge
Park, river mile 138.4, and l?e.:r Crock; avcrano
concentrations to exceed 1000 pnr 100 i.nlliV.tors,
except during periods of high surface runoff.
b. Rogue River above Do-ige Park and all unsrcscifirnj
tributaries, average concentrations to exceed 240
per 100 tr.illiliters, except c'unny periods of high
surface runoff.
2. Dissolved Oxygen (D. 0.). Dissolved oxygen concentrations
to be less then 90 percent of saturation at tuj Lfc?rcn«i1
low, or less than 95 percent of saturation in zr;:'..ning
areas during spawning, incubation, hatching, end fry
stages of salir.onid fishes.
3. pH (Hydrogen Ion Concentration). pK values to fall out-
side the range of 7.0 to 8.5.
4- Turbidity (Jackson Turbidity Units, OTU). Any rrcasurable
increases in natural strecrn turbidities i-iic-n rati'i'cl
turbidities are less than 10 JTU, or more thnn a 10 ocrcc-nt
cumulative increase in natural stream turbidities '.;hcn
strpsi?) turbidities nre r.iore than 30 JTU, oxc-r^ Tor cerUin
short-term activities v;hich nay be spacific«lly rtuthorized
. by the Department of Envircnrr.ental Duality ur.uir such
conditions as it may prescribe and which are r^cessary to
accomodate essential dredging, construction, or ot.ntr
legitirnate uses or activities where turoiu'ities in excess
•of this stsno'ard are unavoidable.
5. Temperatt're. Any measurable increases when strecm temp-
eratures are SS^F. or greater; or rore than 0.5"t:. in-
crease due to a single-source dischrirne when receiving
water temperatures are 57.5'F. or loss or tr.ore than 2"F.
increase due to all sources ccr.binad v/hen strc^"i tcnp-
eraturos are 56"F. or less, except for short-tor.! activities
which nay be specifically authorized by the L'cpartir.ent of
Environmental Quality under such conditions as it nuy
prescribe and which are necessary to accc;u.r.odjte legitimate
uses or activities where temperatures in excess of this
standard are unavoidable.
6. Dissolved Chemical Substances. Guide' concentrations listed
below to be exceeded except as may be specifically
authorized by ths Department of Environmental Quality upon
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such conditions as It may doom necfssary to carry out the
general Intent of Section 41-010 and to protect the
beneficial uses set forth in Table B.
ma/I
Arsenic (As) 0.01
Bariu.n (Ba) l.o
Doron (Bo) 0.5
Ccdniun (Cd) • 0.003
Chloride (Cl) 25.
Chror.tum (Cr) 0.02
Copper (Cu) 0.005
Cycnide (Cn) 0.005
Fluoride (F) l.o
Iron (Fc) o.l
Lead (Pb) 0.05
Manganese (Mn) 0.05
Phenols (totals) 0.001
Total dissolved solids 100.
Zinc (Zn) o.Ol
Note: Guide concentrations are currently under
revision.
WASTE DISCHARGE TREATMENT REQUIREMENTS
The degree of waste treatment required to maintain the dssired water
quality is based upon the uses hhich are mads of the receiving stream, the
size and nature of Its flow, the quantity and quality of wastes, and tha
presence of other sources of pollution on the St-ina watershed. The
standards prtsc-ntly set for the treatment of discharge are:
1. Spy?. 9 P. Hastes •
a. During tne period of low stream flov/s (approximately
June 1 - October 31 of each year), secondary treat-
ment resulting in monthly average effluent concen-
trations r.ot to exceed 20 ir.g/L of 5-d.iy 20 F. Bio-
chemical Oxygen Ds::ia»d (BCD) and 20 rr.g/L of suspended
solids or equivalent control.
b. During the psriod of high stream flov/s (spproximately
Movenibsr 1 - i'.zy 31 of each year) a mim'wum of
secondary treatment or equivalent shall bo provided
and all waste trcn tr.cn t and control facilities shall
be operated at maximum efficiency so as to minimize
waste discharges to public waters.
c. All sev?.?.qc wastes shall b? disinfected, after treat-
ment, equivalent to thorough mixing with sufficient
chlorine to provide 2 residual of at least 1 part per
million after 60 minutes of contact time.
d. More stringent waste treatment requirements may be
imposed, especially in headwater and tributary streams,
where waste loads may be largo relative to stream
flews.
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2. Industrial l-'nstes
a. Industrial waste treatnent requirements shall be
determined on an inclivid'.sa] basis in cccorrJr.nci.1
with tiie provisions of Sections 41-U10, 41-015,
41-020, 41-025, and 11-030 of thu Oregon Ad-nin-
Istretive Kules.
b. Where industrial effluents contain significant
quantities of potentially toxic ek.isnts, treat-
ment reqiiirc"'.3nts si;.1.11 LQ determined utilizing
appropriate bioassays.
WASTE DISCHARGE PERMIT REQUIREMENTS
Under the provisions of OUS 449.083, as amendcv.l by Senate Bill 77,
Chapter 835(1073), and of administrative rules legally adopted by the
Environmental Quality Co;tunission no wastes shall bo discharged into the
waters of the State without a permit from the Director of the Ocpartnont
of Environmental Quality. The Department has the authority to permit or
prohibit waste discharges, adopt, modify and enforce t/ater quality ar.d
waste treatment standards, develop, adept and implement Basin Hater
Quality management strategy plans, n.onitor v/cter quality cr.d wsstc
dischar:;os, and enforce compliance with Orogcn lavs, r-tar^.?t"d5. rules
and permits.
The Dcpartfnent also has responsibility for operating th
Pollutant Discharge Elimination System (liPDtS), a national i.-aste
discharge permit program, within the State of Oregon in compliance
with provisions of the Federal Water Pollution Control Act Ame
of 1972 (p.L. 92-500) and such regulations as iray be promulgated
thereunder by the Environmental Protection Agency (EPA). The new
Federal Act requires HPDES permits to be issued in accordance with
national effluent and performance standards and minimum treatment
requirements. Permit conditions arc based on the following, whenever
applicable:
1. Effluent limitations under Sections 301 and 302 of P.L
S2-500.
a. For point sources other than publicly owned treat-
ment works, compliance by not later then July 1,1577
with effh.'C-nt limitations ohuin^d through the
application of the Lest practicable control tech-
nology currently available as donned by the Admin-
' istrator of EPA.
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b. For publicly ov-ncd treatment works 1n existence on
July 1, 1977, corrpliancc with effluent limitations
obtained throuoh the application of secondary treat-
ment as defined by the Administrator of EPA.
c. For discharges into publicly oi.-ned treatment works,
compliance by not iatar tlun July 1, 1977 with such
effluent stjii^ards, prohibition, or pretreatrient
standards tor toxic and other hazardous wastes as may
be promulgated by the Administrator of EPA pursuant
to Section 307 of P.L. 92-500.
d. For all discharges, compliance by no later than
July 1, 1977 with any additional or r;ore .stringent
limitations that may be necessary to meet water quality
standards, treat";r>nt standards or schedules of
ccciplitince established by either state or federal
statute or regulation.
e. By not later than July 1, 1933, compliance by all
publicly owned treatment works with effluent require-
ments obtained by application of tha best practicable
waste treatment technology pur CUT. .it to Section 201 (g)
(2) (A) of P.L. 52-500 ^nd for all other disciiargcs
CO'iipTidiuie wi en effluent recyjirf: lonts obtained i)y
cpplicetion of the bast available technology econ-
c.iiicuiiy uchievaiilc fur a given cdte^ory or class of
point sources, pursuant to Section 3U4(b)(2) of
P.L. 92-500.
2. Effluent limitations for new sources included in lists of
categories published by EPA and meeting national standards.
3. Provisions for compliance with effluent standards, effluent
prohibitions and prstrcatrr.ent requirements for toxic
pollutants pursuant to Section 307 of P.L. 92-500.
.4. Provisions for ccrnplianca with areawide waste treatment
management plans, if any, adopted under Section 203 of
P.L.'32-500.
5. Allowable average and maximi.-m daily quantitative limitations
for K-vels of pollutants in effluent.
6. Schedule of compliance including appropriate interim dates
for meeting specific requirements within stated time, periods.
7. Specific monitoring, recording and reporting requirements.
Appropriate action will be taken by DEQ to enforce compliance with
specific provisions of each waste discharge permit, with general require-
ments of State and Federal statutes, rules and regulations, and with
water quality standards.
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TELEPHONE USE REPORT
EXHIBIT 5
TO BE USED ON ALL LONG DISTANCE
TELEPHONE CALLS, INCOMING OR OUTGOING,
AND ANY LOCAL CALLS MERITING RECORDING
PREPARE IMMEDIATELY - SUBMIT DAILY
ccr
ROUTING
DS
JV
CALL FROM: Lee S. Aronson
TITLE: Environmental Protection Specialist
LOCATION &
PHONE NO.:
CALL TO:
TITLE:
ORO 221-3250
DATE: 11/8/74
Bill Haight
TIME: 1 p.m.
Fish Biologist
LOCATION &
PHONE NO.: Ore. Game Comm.. Grants Pass 479-2276
SUMMARY OF CALL:
Bill gave me the following list of animals in the Service District and ultimate
drainage area.
Beaver
MuskraT"
Mink
Blue Heron
Raccoon "
Marten
RtVer~OYt"er
Ground Squirrels
Green heron
Black-crown night heron
Cottontai Is"
Black-tail jackrabbit
Black-tail deer
Ring-tail cat
Osprey
Pi leafed woodpecker
"Hawkl
Owls
'Songbirds "
Black bear
Mountain quail
Also Sand and Allen Creek have
summer steel head LlidL have been —
declining due to increasing urbanization,
Valley quail
Ring-necked pheasant
Band-tail pigeon
Mallard
Wood duck
Teal
Scaup
Pintail
.*»« j. 'i--s i
Taaa wa i
Merganser
ftnnco
Lee Aronson =//f .
KI'A-X 4
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IN THE. MATTER OF: )
)
Future .land use and sewer)
extensions within the )
Redwood Sanitary Sewer ) RESOLUTION
District. >
WHEREAS the Board of County Commissioners is the Governing
Body of Josephine County in matters relating to the Comprehensive
Plan and Zoning and as specifically set out in ORS Chapters 215
and 197, and;
WHEREAS, the Board of County Commissioners is also the
Governing Body of the Redwood Sanitary Sewer Service District
as set forth in ORS Chapter 451, and;
WHEREAS the Board of County Commissioners wish to set out
in writing their beliefs and policies regarding the future land
use within the Redwood Sanitary Sev/er Service District and;
• WHEREAS 'the Board of County Commissioners has reviewed ar.d
concurs with the population projections for the District recently
prepared by the Firm of Patterson ,. Langford, and Steward", and;
3 ' •
WHEREAS the Board of County Commissioners recognize:
-1. That the proposed sewer project for the District
could support a population density inconsistent with
the existing zoning in that: the District is presently
. zoned 2,5 and 5 acre minimum lot sizes which would
i
inhibit further development associated with the
installation of sewers.
2. That the Comprehensive Plan contains a dual
recommendation for the eastern portion of the
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Redwood Sanitary Sewer Service District: (a) until
. sewers are available, the future development should
progress in recognition of the poor soil conditions
for proper septic tank installations, i.e., large-lot
zoning should be used; (b) once sewers become available
the Plan recommends that the maximum allowable density
of development be increased to allow 3-6 dwelling units
per acre.
3. That in future years if the County continues to grow
in accordance with the aforementioned population.
projection, the Comprehensive Plan and the complementary
zoning wi'll have to be amended to reflect future demands
and needs.
4* That the aforementioned population projection is a
reasonable estimate.
NOW THEREFORE BE IT RESOLVED that in light of the above
* • •
"mentioned factors:
1. The"Board of County Commissioners intends to zone
the area in accordance with the Comprehensive Plan;
in that, specifically, when sewer facilities are
installed, the eastern portion of the District, being
served with sewers, should be rezoned to a classification
permitting a maximum-density of 3-6 units per acre..
Resolution - Page 2
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.2. That in future years if growth contimics as
I •
projected and if the need becomes apparent or
expressed, the future Boards of County Commissioners
will give serious consideration to, and will probably
permit, future extensions of the sewers into existing
unsewered areas of the District, and will sub-
sequently take action to amend the Comprehensive
Plan and Zoning.
Dated this
day of
s~'
, 1974.
2 ^ -•;
^*y ^^\ • /
Cn ai xrnan
J •
t • .^-*f- .. / .'!•
'^ -'~
•• Conur.issioner
Approved as to form:
Edv/ard B. Sites
Deputy District Attorney
Resolution - Page 3
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EXHIBIT 7
PROCEDURAL STEPS REQUIRED TO ATTAIN SEWER SERVICE FROM
THE REDUOOD SANITARY SEWER SERVICE DISTRICT
JOSEPHINE COUNTY, OREGON
The following step by step procedure is one that would occur in order to
provide sewer service to an area that lies outside of the originally created
assessment district of the Redwood Sanitary Sewer Service District*
1. A petition would have to be submitted to the Board Of County
Commissioners requesting that sewer service be extended to a
particular area. This petition would have to be as stipulated
in ORS, Chapters 451 and 198.
2. The Board Of County Commissioners acting as the governing body
of the sewer district would have an initial decision to make
regarding whether or not it was appropriate to provide sewer
service to the area based on such things as treatment plant
capacity, intensity of development, ease of providing service,
etc.
3. Assuming that the sewer was being requested in order to provide
for additional residential development an amendment to the
Josephine County Comprehensive Plan would be required and the
Board Of County Commissioners is the only body with authority
to make an amendment to that plan. The amendment would be
necessary since the Redwood Sanitary Sewer Service District,
outside of the initial assessment district, is designated Farm
Residential which would suggest development on 5-10 acre parcels.
4. The request would initially be referredf,to- the Josephine County
Planning Commission for their review and-recommendation. The
Planning Commission would hold a.public hearing on anysuch
matter after which they would make a recommendation to the Board
Of County Commissioners to either amend the plan or not.
5. The Board Of County Commissioners would then conduct a public
hearing on the request and make the final determination to
either leave the Comprehensive Plan in its present form or
take action to amend the plan to reflect the Urban Low Density
classification which would suggest development on the order of
3-6 units per acre.
6. Once the plan has been amended, a request for a zone change
• . may then be initiated to rezone the area in question from
SR-5 to R-l which would permit lots of approximately % acre,
dependant upon the installation of sewers. The first action
would be by the Planning Commission whereby they would conduct
a public hearing on the question. Public notice would appear
in the newspaper and property owners affected would be notified
by mail. The Planning Commission would take action to either
recommend approval or denial to the Board Of County Commissioners.
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Once the Board Of County Commissioners receives a recommendation
from the Planning Commission a public hearing wil.l be scheduled
by the Board prior to which notices of public hearing will
again have been placed in the paper as well as written notices
to affected property owners. The Board up,,n considering the
recommendation of the Planning Commission and the facts
presented at the public hearing may make the final determination
concerning the Zone Change Request. ' ,
Once the zone change question was resolved, the Board coul'd then
proceed with the sewer project by enacting an ordinance setting
out the proposed project, the method of assessment, creating an
assessment district, and setting up a hearing to hear any re-
monstrance to the proposed assessments.
The remonstrance hearing would be held, after written notice to
all persons to be assessed and general notice in the newspaper
was made. If less than 50% of the property owners and 50% of
the acres involved are not objected to, the Board would issue
an order for the project to proceed.
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EXHIBIT 8
BIBLIOGRAPHY
Engineering Reports
1. Brown and Caldwell, Sewage Treatment and Disposal Study; City of
Grants Pass. 1969.
2. Cornell, Howl and, Hayes and Merryfield, Sewage Collection and Haste
Treatment Facilities for the Redwood Avenue Area, 1966.
3. Stevens, Thompson and Runyon, Inc., Josephine County Comprehensive
Areawide Water and Sewerage Plan, 1972.
Planning Documents
1. Department of Environmental Quality, Draft Development Document for
a Water Quality Management Plan for the Rogue River Basin, 1974.
2. Josephine County Planning Commission, The Comprehensive Plan for
Josephine County, 1970-1990, 1971.
3. Josephine County Planning Commission, Zoning Regulations of Josephine
County. 1973.
Other Reports
1. Battelle-Pacific Northwest Laboratories, An Inventory and Evaluation
of Areas of Environmental Concern in Oregon, 1973.
2. Bonneville Power Administration, Oregon; Population, Employment, and
Housing Units Projected to 1990? 1973.
3. Council on Environmental Quality, Interceptor Sewers and Suburban
Sprawl. 1974.
4. Josephine County Long Range Planning Report.
5. Oregon State Game Commission, Basin Investigations: Rogue River Basin,
1970.
6. Real Estate Research Corporation, The Cost of Sprawl, 1974.
7. Stevens, Thompson and Runyon, Inc., Solid Waste Management Plan--
Josephine County, Oregon. 1974.
•&GPO 699-465
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