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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                                - 25 -


      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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                                   28
                                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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                                     29
                              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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                                   30


     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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                                   31
                              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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                                      32
                                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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                                   33


                              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.

-------
                                                                   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.

-------
                                   36
     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).

-------
                                      37
     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)

-------
                                    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

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O
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tn
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'Wildlife
X

X









] Recreation


X









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I/I
O











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JFisheries. . —

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X

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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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-------
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  -

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(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 -

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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 -

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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 -

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                                 - 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

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                                 - 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.

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              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 
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                     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 -

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                                                 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 -

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                                                  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  -

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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 -

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  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  -

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                                 - 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.

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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  ;

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                                  - 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.

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                  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  -

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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 -

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                                 - 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.

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     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  -

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                                 -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 -

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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 -

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        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
${
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  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

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     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

                                     - 78 -

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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


                           - 82 -

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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.

-------
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 ....

                         - 84 -

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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
                          -  85  -

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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
                           - 86  -

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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.
                           - 88 -

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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.
                                    - 91 -

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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.

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                        - 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
                                JU! t 7
                                        *

-------
                                          - 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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 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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-------
                                 - 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
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'wildlife
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iFloodplain Development
Federal Policy
i Sludge Disposal
j
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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
TONE
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LETTERS RECEIVED IH OPPOSITION
- 127 -
From
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-------









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
w


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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
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! Ruby Jorgenson
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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
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Opposed
Concerned with
EIS inadequacie
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Opposed


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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
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Supports
Opposed
Opposed plan-
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Opposed
Supports
Supports
Opposed
Supports

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TABLE 11
PUBLIC HEARING TESTIMONY
- 133 -
SPEAKERS
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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
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Opposed
Opposed
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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

-------

-------
                                                        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.

-------
          •  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

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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.

-------
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)

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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.

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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

-------
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                                           •<
                                            ^
                                               I
                                                  ROGUE
                                               DRAINAGE BASIN
          •A
     '-"^•< fc'y
      '  " rbX.
               ^\y -A  ^\
        V •' XSx'-^V'^X*"N'• -i- ••)
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                                             . Figure 1 """

                                             w/nfer  steelfiead

                                             spawning  areas
                                                 SCALE or

-------
NISV9 30VNIVHQ
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          \ .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.

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                                          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.

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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

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                                         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.

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                                         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.

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 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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