v/i

     ll

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   FINAL ENVIRONMENTAL IMPACT STATEMENT
       WASTEWATER TREATMENT SYSTEMS
                  FOR THE
SOUTHWEST LINCOLN COUNTY SANITARY DISTRICT
         EPA-10-OR-Lincoln-WWTS-76
               Prepared By
   U.S. Environmental Protection Agency
                Region X
           Seattle, WA  98101
       With Technical Assistance By
      Jones & Stokes Associates, Inc.
        455 Capitol Mall, Suite 835
           Sacramento, CA  95814
           In association with
          Don Owen & Associates
                   and
        Gruen Gruen + Associates
                                              L:
                                  P. Dufcois
                           'Regional Administrator
                           Date

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                             PREFACE
      On April  30,  1976 the U.S.  Environmental  Protection Agency  (EPA)
 released  for public  review a draft  Environmental  Impact Statement
 (EIS) on  a  proposed action for  the Southwest  Lincoln  County  Sanitary
 District, located  in Lincoln County, Oregon.   The decision  to write
 a  draft and final  EIS by EPA was based on an expected  grant appli-
 cation from the Southwest Lincoln County Sanitary District  for Step  2
 construction grant funding in which EPA would  provide  75% of  the funds
 for  the design of  grant eligible components required to construct a
 sewerage  system.   This grant award would also-provide  reimbursement
 funds for Step 1 planning which  is presently being expended by the
 District.  To  complete the environmental impact evaluation  of the
.proposed  action, 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 alterna-
 tives, and a review of existing state and county documents  dealing
 with  sani.tary  surveys.

      The  Environmental Protection Agency, in this final EIS,  re-
 commends that  a decision to provide sewer service in the District be
 delayed until  such time as a comprehensive sanitary survey  is com-
 pleted within  the  District.   This recommendation is based upon the
 fact  that the  draft EIS was unable to identify significant  waste-
 water problems to warrant construction of a sewerage system as
 proposed by the Southwest Lincoln County Sanitary District.   Also,
 the information contained in the Facilities Plan is not adequate to
 properly evaluate sewage collection systems for a district  wide
 interceptor as proposed.   Once the survey is completed the  Facili-
 ties Plan should be reevaluated to identify a cost effective  alter-
 native which would solve existing wastewater problems.

     EPA's EIS evaluated the environmental  impacts associated with
 the alternatives evaluated in the draft statement; extensive  review
 of the Lincoln County Sanitary survey conducted by the Oregon State
 Health Division dated January 15, 1973; and additional data gathered
 by the Oregon State Department of Environmental Quality.   The following
 discussion summarizes salient points identified in the above  reports.

     Between June 1968 and September 1968,  the-Lincoln County Health
 Department conducted a sanitary survey of the beaches of Lincoln
 County.   Numerous discharges  containing sewage^were noted as a result
of this  survey.

     On  November 13,  1972 a  letter from Governor Tom McCall  to the
Lincoln  County Board of Commissioners  directed the Oregon State
Health Division and the Oregon  Department of Environmental  Quality
to review the water,  sewer and  septic  tank  situation in Lincoln
County.   As  part of that  directive,  the Oregon State Health Divi-
sion set out to re-investigate  the problem  areas pointed  out in

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the 1968 county survey to determine whether any remedial action
had been taken, and to attempt to locate and document any new problems
that had occurred since the 1968 survey was conducted.   The 1972
survey also evaluated'the subdivision applications for septic tank
permits between 1970 and 1972.  The results of the 1972 survey as
presented to Governor McCall  are as follows:

     Dye and bacteriological  tests on twenty point discharges in
S.W. Lincoln Co. S.D. were performed as a result of the 1972 survey.
Ten of the discharges are located immediately south of Waldport,
one (Dean's Oceanside Mote-1)  about 5 miles south of Waldport,
and the remaining nine immediately north of Yachats.  Of the twenty
discharges investigated, six  positive tests were noted south of
Waldport, one at Dean's Oceanside Motel, and one north of Yachats
(Adobe Motel).  A review of the 283 applications for septic tank
permits in 13 subdivisions indicated 46 approvals and 237 disap-
provals (83%) due to water table, impervious soils, slope, and
lot size.

     In addition to these problems, the Oregon Department of
Environmental Quality in March 1975 noted sewage problems at Beach-
side State Park, Seabrook Lane, Yaquina John Point, Wakonda Beach/
Big Creek Area and Sea Shore  Cottages.   Aside from these past,
surveys a Comprehensive Sanitary Survey has not been completed
within the District.  The conduct of one at this time is recommended.

     The survey should be conducted by the Oregon State Department of
Environmental Quality/Lincoln County Health Department.  It should be
conducted on a house to house basis using either dye, bacteriological,
or visual tests, as appropriate.  The survey should note whether
systems are failing and what  if any measures could be taken by
property owners to correct the problem.  Once the survey is completed
and major problem areas have  been identified, the facilities plan should
be completed.  The plan should include a reevaluation of those
alternatives already investigated as they relate to the results of
the survey as well as identify and evaluate other alternatives of
a lesser scope, including the upgrading of existing plants with
staged extension of those systems.  For example, if the major pro-
blem areas are immediately south of Waldport and north of Yachats
as noted in earlier surveys,  these problems could be resolved by
extending sanitary services to these areas from the existing Waldport
and Yachats facilities.  Other problems located within the geographic
center of the District could  possible be resolved by a separate
treatment facility or by corrective measures to-individual septic
tank/drainfield systems.  Such an alternative could result in mini-
mized individual costs.  One  of the limitations on award of EPA
grant funds is that the project must be cost-effective.

     EPA financial assistance for wastewater treatment projects is
primarily intended to eliminate existing water quality problems on
a priority basis.   Interceptor sewers which do not result in the
                                    11

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abatement of major or significant water quality problems but,.in-
stead, are planned to accommodate future development should not
receive priority above those projects designed to solve existing
problems.  The EIS has shown that few known existing and immediate
problems would be solved by construction at the proposed project.

     During the 45 day review period on the draft EIS, EPA received
significant comments from Oregon State's Land Conservation and Develop-
ment Commission (LCDC).  EPA noted in the draft EIS that the relation-
ship between a proposed treatment system and LCDC's planning goals,
guidelines and regulations is a significant issue.  LCDC's comments
about the draft EIS include a recommendation -that EPA delay its
selection of an alternative to provide sewerage service to the Dis-
trict until Lincoln County completes a preliminary comprehensive
plan for the area consistent with the provisions of the Statewide
planning goals.  Lincoln County would be given until July 31, 1977  .
to complete this plan.  LCDC's purpose in proposing the delay is to
insure that the selected alternative is consistent with the revised
comprehensive plan and that further complications and delays in
solving sewage disposal and water pollution problems are avoided.

     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 providing substantive
comments on the draft EIS and has attempted to respond to all ques-
tions and requests for explanation, correction o'r 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
provided illustrating the major concerns raised.   All  letters, along
with the Public Hearing Record, have been considered in EPA's de-
cision making process.

     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 Southwest Lincoln County Sanitary District.
                                 m

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                       TABLE OF  CONTENTS

                                                          Page
  PREFACE

  TABLE OF CONTENTS                                        iv

  SUMMARY                                                  ix

  I.   INTRODUCTION                                          1

      Purpose and Objectives                                1
      Background of Past Events                             2
      Important Issues and Considerations                   4

 II.   ENVIRONMENTAL SETTING                                 7

      Physical and Biological Features                      7
          Location                                          7
          Climate                                           7
          Air Quality                                       7
          Topography and Drainage                          10
          Edaphic Features                                 10
          Mineral Resources                                14
          Geology                                          14
          Geologic Hazards                                 15
          Bio tic Resources                                 18
          Aesthetic Values                                 19
          Water Resources and Water Quality  A              24
          Existing Sewage Disposal Conditions              26
          Archeological-Historical                         28
      Socio-Economic Features                              32
          Population                                       32
          Economy                                          3 6
         . Future Trends in Population Growth               44
          Land Use""'1'        "                              47
          Land Use Planning                                51
          Future Land Use                                  52

III.   ALTERNATIVE WASTEWATER TREATMENT FACILITIES          55

      Introduction                                         55
          Constraints on Alternative Development           56
          Regionalization                                  53
          Flow and Waste Reduction Measures                59
      Wastewater Management Options                        60
          Possible Alternatives                           . 60
          Treatment and Disposal Alternatives              61
          The Activated Sludge Process                     62
          Septic Tank Treatment                            62
                                iv

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           Treatment Plant Site Options                     63
           Implementation Options—Financing and
             Organization                                   64
           Existing Wastewater Treatment Facilities         66
           Proposed Facilities Common to All Treatment
             and Disposal Alternatives                      67
           Population Capacity of Project Facilities        67
       Description of Evaluated Regional Treatment
         and Disposal Alternatives                          68
           Alternative 1 - Waconda Beach-San Marine         68
           Alternative 2 - Waldport-Yachats                 70
           Alternative 3 - Big Creek                        71
           Alternative 4 - Yachats                          75
           Alternative 5 - Waldport                         77
           Alternative 6 - No Action                        79
           Alternative 7 - District Maintenance of
             Septic Tanks                                   80
           Sewage Sludge Handling and Disposal Options      81
       Cost Comparison and Summary                          84

  IV.  ANALYSIS OF THE ENVIRONMENTAL IMPACTS OF
       THE ALTERNATIVES                                     87

       Introduction                                         87
       Impacts Common to All Alternatives                   87
           Short-Term Impacts                               87
           Lonq-Term Direct Impacts                         87
           Physical and Biological Resources                90
           Social Features                                 103
           Financial Impacts                               112

   V.  UNAVOIDABLE ADVERSE IMPACTS                         119

  VI.  LOCAL SHORT-TERM USFS OF THE ENVIRONMENT VS.
       MAINTENANCE AND ENHANCEMENT OF LONG-TERM	
       PRODUCTIVITY                   '	"	            123

 VII.  IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS
       QF RESOURCES                                        125

VIII.  COMMENTS AND RESPONSES TO DRAFT EIS                 127

       BIBLIOGRAPHY                                        295

       PERSONAL COMMUNICATION                              299

       APPENDICES                                          301
                                 V

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                        LIST OF TABLES

Table                                                    Page

  1      Summary Estimates of Emissions in Lincoln
         County                                           11

  2      Characteristics of Soil Associations of
         the Study Area                                   13

  3      Recorded Earthquakes in the Lincoln
         County Area                                      17

  4      Vegetation and Land Use - Southwest Lincoln
         County Sanitary District                         22

  5      Rare, Endangered and Threatened Vertebrate
         Species Whose Distribution Includes the
         Southwest Lincoln Study Area                     23

  6a     Regional Population - 1970 and 1960              33

  6b     Existing and Projected Nontransient Population   33

  7      Historical Average Annual Daily Traffic
         U.S. 101:  Yaquina Bay to Yachats                37

  8      Average Daily Traffic by Month:  1974
         U.S. 101:  Yaquina Bay to Yachats                37

  9      Average Daily Tourist Traffic 1969-1974
         U.S. 101:  Yaquina Bay to Yachats                37

 10      State Park Usage:  1971-1975                     39

 11      Annual Average Unemployment Rate Lincoln
         County, 1960-1971  '                             43

 12      Source of Income - Lincoln County, 1970          43

 13      Real Property Valuation                          46

 14      Subdivisions in Southwest Lincoln Sanitary
         District                                         48

 15      Southwest Lincoln County Sanitary District
         Wastewater Project - 20-Year Comparison of
         Local Costs                                      85
                               VI

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Table                                                   Page

 16     Southwest Lincoln County Sanitary District
        Wastewater Project - EPA Cost-Effectiveness
        Comparison of Costs                              86

 17     Short-Term Impacts - Southwest Lincoln County
        Sanitary District                                88

 18     Emission Factors for Sewage Sludge
        Incinerators                                     95

 19     Energy Requirements                             104

 20     Projected Air Emissions from Local and
        Tourist Traffic - Yachats to Yaquina Bay        108

 21     Comparison of Population Projections            110

 22     Projected Cost to Property Owners for
        Implementation of Alternative 4                 115

 23     Family Incomes in 1970 of Lincoln County
        as Compared to State and Nation                 117

 24     Environmental Summary of Adverse Impacts of
        Project Alternatives for the Southwest
        Lincoln County Sanitary District                120

 25     Comments Received on Draft EIS                  128

 26     General Letters Received Regarding a
        Wastewater Treatment System                     284

 27     Public Hearing Testimony                        228
                              vii

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                      LIST OF FIGURES

Figure                                                  Page
  1     Location of Southwest Lincoln County
        Sanitary District                                 8

  2     Mean Monthly Precipitation and Temperature
        in Newport, Oregon                                9

  3     Soil Associations Present in Southwest
        Lincoln County Sanitary District                 12

  4     Geologic Hazards of the Study Area               16

  5     Vegetation and Land Use                          20

  6     Land Use - Southwest Lincoln County-Waldport
        to Yachats                                       49

  7     Alternative 1 - Waconda Beach-San Marine         69

  8     Alternative 2 - Waldport-Yachats                 72

  9     Alternative 3 - Big Creek                        74

 10     Alternative 4 - Yachats                          76

 11     Alternative 5 - Waldport                         78

 12     Location of Starr Creek Archeological Site       97
                            viii

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                         SUMMARY

   FINAL ENVIRONMENTAL STATEMENT — WASTEWATER TREATMENT
SYSTEMS FOR THE SOUTHWEST LINCOLN COUNTY SANITARY DISTRICT
Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington  98101


1.  Type of Statement;      Draft (  )       Final ( X)

2.  Type of Action:     Administrative (X )      Legislative  (  )

3.  Description of Action:

     The objective of this project is to provide a wastewater
treatment and disposal program for the Southwest Lincoln County
Sanitary District, located between the Cities of Waldport and
Yachats, Lincoln County, Oregon.  This Environmental Impact
Statement identifies alternatives for providing the district
with wastewater facilities designed to meet the needs of the
residents of the district and maintenance of environmental
quality.  The district covers approximately 3,000 acres and
has a population of 815 year-round and 1,225 part-time resi-
dents and approximately 660 seasonal residents.

     Much of the Southwest Lincoln County Sanitary District is
underlain by impermeable soils and a high groundwater table.
Such conditions have created periodic sewage waste disposal
problems causing septic systems to fail and sewage to appear
in surface drainage areas and on beaches.  Surveys conducted
by the Lincoln County Health Department and the Oregon Depart-
ment of Environmental Quality during 1968,  1972 and 1974 docu-
mented several cases of septic system failures and sewage on
surface areas throughout the district.

     During 1973 and 1974, the Southwest Lincoln County Sanitary
District was formed and a facilities plan was developed identi-
fying a variety of alternative means of providing sewage service
to the district.

4.  Summary of Environmental Impacts and Adverse
    Environmental Effects;

     The impacts and magnitude of those impacts will vary
according to the alternatives proposed.  Alternatives 1 through
5 represent alternative treatment facilities while Alternatives
6 and 7 represent no action and septic tank maintenance.
                             IX

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     Short-term impacts such as temporary loss of vegetation,
disruption of wildlife, traffic congestion, utility service
disruption, soil erosion, safety hazard, aerial pollutant,
visual impact, noise, spoil disposal and water quality impair-
ments will occur with Alternatives 1 through 5.  No short-
term impacts will be associated with Alternatives 6 and 7.

     Long-term impacts of Alternatives 1 through 5 will in-
clude protection of groundwater, minor effects on stream water
quality and biota, possible minor geologic hazards, air
quality changes, possible disturbance of archeological sites,
impacts on vegetation, wildlife and marine biota, changes in
visual character, increases in energy consumption, impact on
parks, land use patterns and planning, increased traffic,
changes in population, and the economic ramifications on the
local economy and the private landowner.

     Major impacts associated with Alternatives 6 and 7 are
likely to be the periodic problem of groundwater and ground
surface contamination by sewage, the potential for a health
hazard, and effects on land use patterns and state park
operations.  Alternative 7 will also result in increased
energy consumption.

5.  Alternatives Considered;

     Alternative 1 - Waconda Beach/San Marine treatment
facilities with ocean outfalls.  Both plants would be 350,000
gallons per day capacity  (gpd).  Capital cost - $6,506,100.

     Alternative 2 - Waldport/Yachats.  This alternative would
utilize existing treatment plants but would be upgraded to
handle added sewage flows.  Outfalls would be in the Alsea Bay
channel and off of a rocky shore at Yachats.  Capital cost -
$5,678,600.

     Alternative 3 - Big Creek alternative.   Sewage would be
disposed of at one treatment facility at Big Creek.  The plant
would have a 750,000 gpd capacity.  Capital cost - $5,518,000.

     Alternative 4 - Yachats alternative.  Wastewater would
flow south to a new Yachats plant having a capacity of 750,000
gpd.  Effluent disposal would be to the ocean.  Capital cost -
$5,154,200.

     Alternative 5 - Waldport alternative.  All wastewater in
the district would flow northward to a new 750,000 gpd capa-
city plant in Waldport.  The effluent outfall would be to the
channel in Alsea Bay.  Capital cost - $5,290,400.

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     Alternative  6 - No  action alternative.  This alternative
would involve the continuation of existing conditions of
installing septic tanks  and leach fields to handle individual
home sewage.  Associated with this alternative would be the
continuation of periodic septic system failures and surfacing
sewage wastes.  The present practice of retrofitting or re-
placing failing systems  would continue.

     Alternative  7 - District maintenance of septic tanks.
The district would purchase a septic tank pumping truck,
would periodically inspect all septic systems within the
district, and as  required, pump the tanks and convey pumpage
to an aerobic digester at the Yachats treatment plant.
Capital cost - $310,000.

6.  The following State, Federal and local agencies and interested  groups
were invited to comment on the Environmental  Impact Statement.
                                XI

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                          FEDERAL AGENCIES

 COUNCIL ON  ENVIRONMENTAL QUALITY
 U,S,  DEPARTMENT OF AGRICULTURE
 U.S.  DEPARTMENT OF DEFENSE
 U,S,  DEPARTMENT OF INTERIOR
 U,S,  DEPARTMENT OF HEALTH, EDUCATION AND  WELFARE
 U,S,  DEPARTMENT OF HOUSING AND  URBAN DEVELOPMENT
 U,S,  DEPARTMENT OF TRANSPORTATION
 FEDERAL ENERGY  OFFICE
 NATIONAL MARINE FISHERIES SERVICE
 ADVISORY COUNCIL ON HISTORIC PRESERVATION

                       MEMBERS  OF CONGRESS
MARK 0, HATFIELD                                LES AuCoiN
U,S, SENATE                            U,S, HOUSE OF REPRESENTATIVES
ROBERT W, PACKWOOD
U,S, SENATE
                              STATE
GOVERNOR OF OREGON
MAX C, RIJKEN - REPRESENTATIVE DISTRICT
W, STAN OUDERKIRK - STATE SENATOR
OREGON STATE CLEARINGHOUSE
DEPARTMENT OF ENVIRONMENTAL QUALITY
                                XII

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                        REGIONAL AND LOCAL

LINCOLN COUNTY BOARD OF COMMISSIONERS
LINCOLN COUNTY PLANNING DEPARTMENT
LINCOLN COUNTY PERMITS, UTILITIES & RESOURCES DEPARTMENT
LINCOLN COUNTY HEALTH DEPARTMENT
NEWPORT PUBLIC LIBRARY
SOUTHWEST LINCOLN COUNTY SANITARY DISTRICT
BAY TO BAY SANITARY DISTRICT

                INTERESTED GROUPS AND INDIVIDUALS

ROBERT E, MEYER, ENGINEERS INC,
OREGON WILDLIFE FEDERATION
1000 FRIENDS OF OREGON
NORTHWEST ENVIRONMENTAL DEFENSE CENTER
OSPIRG
OREGON ENVIRONMENTAL COUNCIL
OREGON STATE UNIVERSITY
WILLIAM E, WARE
THOR H, MORK
THOMAS GANATT
JEAN DUCKETT
CHRISTOPHER MINOR
RICHARD BENNER
W, C. ADAMS

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DALE D, KREBS
EGAN O'CONNOR
GARRETT SMITH
ROBERT L, JOHNSON
MR, & MRS, C, ROBERT DAVIDSON
MR, & MRS, C, R, BRUNDAGE
PATRICK E, BALL
LAR ROMOREN
VELLA M, GASKILL
D, V, GASKILL
RICHARD & MARY E, WALKER
MR, & MRS, EARL T, WILKERSON
GLEN A, WILSON
     THIS FINAL ENVIRONMENTAL IMPACT STATEMENT WAS MADE AVAILABLE TO THE
COUNCIL ON ENVIRONMENTAL QUALITY (CEQ) AND THE PUBLIC ON AUGUST 11, 1976,
                               XI V

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I. INTRODUCTION

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                      I.   INTRODUCTION


                   Purpose and Objectives


      The National Environmental Policy Act of 1969  (NEPA)
 requires that all agencies of the  federal  government  prepare
 a detailed Environmental  Impact Statement  (EIS)  on  proposals
 for  projects  that may significantly  affect the quality of  the
 human environment.   NEPA  requires  that agencies (in this case
 the  Environmental Protection  Agency  [EPA])  include  in their
 decision-making  process all considerations of environmental
 aspects  of proposed  actions,  the environmental impacts of  the
 proposed project and its  alternatives,  and a  discussion of
 ways to  avoid or minimize adverse  effects.  The EIS is to  be
 a "full  disclosure"  document  and must follow  specific regula-
 tions of the  EPA as  contained in 40  CFR, part 6,  as published
 in the Federal Register,  Vol.  40,  No.  72,  April 14, 1975.

      Because  the Southwest Lincoln County  Sanitary  District
 project  can be 75 percent funded by  the EPA,  as  a part of
 Construction  Grants  Program authorized by  the Federal Water
 Pollution Control Act amendments of  1972  (PL  92-500),  it
 requires NEPA action.  After  reviewing the  proposed wastewater
 facilities plan  for  the Southwest  Lincoln  County Sanitary
 District,  it  was decided  by the  EPA  that an EIS  was needed.
 This  decision was based on  the  likely changes  in  land use
 patterns  as determined by such  factors as vacant  land subject
 to increased  development  pressure, the increase  in  population
 which may  be  induced, the faster rate of population change,
 changes  in  population density,  the extent to which  landowners
 may benefit from the  areas  subject to increased development
 and the  nature of land use  regulations in the  affected area,
 and their  potential effects on development.  Of  equal  importance
 were  the  likely  effects of  the project on  "parklands,  other
 public lands  or  areas of  recognized  scenic, recreational,
 archeological  or historic value"   (40 CFR,  part  6).

      Data  for  this EIS were compiled from various existing
 studies  of  the southwest  Lincoln County area,  field reconnais-
 sance  and numerous personal contacts with involved  individuals.
 A complete  listing of references appears in the  Bibliography.

     The EIS process encourages public input into the decision-
making process.  This EIS was first prepared in draft form and
widely circulated for public comment.  Announcements were made
 in the local paper and on June 3, 1976 a public hearing was
held to solicit responses.

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     The results of the public hearing and written comments
received during the 45-day public comment period are presented
at the back of this final environmental impact statement.
In this final EIS, the EPA Regional Administrator has selected
the proposed plan of action.  The final action concerning the
grant award for the district will be made following a 30-day
comment period.
                  Background  of Past  Events


      Problems  associated  with sewage and  inadequate  waste  dis-
 posal were  present  in  southwest  Lincoln County  some  time before
 September  1974 when the Southwest  Lincoln County  Sanitary
 District first submitted  a facilities plan  to the State of
 Oregon.

      In 1968 the  Lincoln  County  Health Department conducted  a
 beach survey to determine the extent of sewage  disposal
 problems on the coastal strip of Lincoln  County.   In the
 course of  the  1968  survey, approximately  50 problem  sources  of
 sewage were located and described, eight  of which were within
 the boundaries of the  Southwest  Lincoln County  Sanitary
 District  (Oregon  State Health Division, 1973).

      In April  1970, the Lincoln  County Regional Water and
 Sewerage Plan  was prepared for the County Board of Commissioners.
 The purpose of the  study  was to  determine existing conditions
 and needs  within  the county, sufficient to  serve  as  the basis
 for a comprehensive sewer and water  plan.

      At the request of Governor  Tom  McCall  in late 1972, the
 Oregon State Health Division and the Department of Environmental
 Quality, conducted  a review  of the water, sewer and  septic tank
 problems in Lincoln County.  The general  intent of the study
 was to develop a  comparison  between  1972  sewage conditions and
 the situation  as  it existed  in 1968.  The survey  results indi-
 cated a continuation of sewage problems in  Lincoln County, and a
 compounding of the  problem because of additional  subdividing
 and commercial and  residential development  along  the coast.
 The study  recommended  the formation  of sanitation districts,
 among those communities having sewage problems, to establish a
 means of alleviating sewage  disposal problems.

      In  1973  several residents of  southwest Lincoln  County
 founded  a  group to  create a  sanitary district.  Shortly
 thereafter, the residents voted  and  approved the  formation of
 the Southwest  Lincoln  County Sanitary District  which
 thereafter developed a wastewater  facilities plan for the
 district.

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      In January 1974,  a comprehensive water,  sewerage, and
solid waste management plan  was prepared for  the Lincoln County
Board of Commissioners.  That plan  identified a variety of
alternative means of  providing sewerage service to  the south-
west  Lincoln  County Area.

      By September 1974 the Southwest  Lincoln  County Sanitary
District had  submitted its facilities plan  to the Department
of Environmental Quality.

      The following is a summary of  events from 1974 leading to
this  required EIS.
      Date

      September 1974


      June 27, 1975
     June 28-July 10, 1975



     July 11, 1975



     July 11, 1975




     July 22, 1975


     July 31, 1975
     August 21, 1975
Event

Southwest Lincoln County Sanitary District
(S.W.L.C.S.D.) Facilities Plan submitted to DEQ.

Public Hearing on proposed fiscal year 1976
Priority List.  Southwest Lincoln County
Sanitary District was below the expected
funding level.  Lincoln County and the South-
west Lincoln Sanitary District made presen-
tations challenging the low ranking of the
project.

DEQ revised Priority List, resulting in
the elevation of the project to a fundable
level.

Environmental Quality Commission adopted
Revised Priority List, placing the project
within funding range.

EPA's Oregon Operations Office (Project
Engineer)  recommended to the EPA
Region 10 office of Seattle that an EIS
be prepared on the project

EPA approved Oregon's fiscal year 1976
Priority List.

EPA completed its environmental review of
Southwest Lincoln County proposed project.
Notice of Intent to prepare an EIS was
prepared,  but delayed at request of
S.W.L.C.S.D.

Letter to Henry F. Baldwin, Jr. (President,
Board of Directors, Southwest Lincoln County
Sanitary District) frcm Regional Admini-
strator notifying district of an EIS require-
ment on their proposed project.

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     September 3,  1975
     September 4,  1975
     September 12, 1975
     September 12,  1975
     September 25,  1975
     September 30,  1975

     December 8,  1975
     through
     January 9, 1976

     January 9-April 7,
     1976

     January 20-22, 1976
     April 30, 1976

     June 2, 1976

     April 30-June 14, 1976
Southwest Lincoln County Board requests
further delay of Notice of Intent in order
to appeal EIS decision.

Letter from Environmental Impact Section
to Southwest Lincoln County Board of Commis-
sioners granting extension from September 5
to September 12 before release of Notice of
Intent.  Delay was granted to allow time
for S.W.L.C.S.D.

EPA received letter from S.W.L.C.S.D.
requesting additional 3-week delay of
Notice of Intent.

Regional Administrator grants 2- to 3-week
delay on Notice of Intent

Meeting with S.W.L.C.S.D. officials.  Tour
of district.

EPA's Notice of Intent released.

Headquarters Washington, D.C., awards
contract to Jones & Stokes Associates,
Inc. to assist EPA in preparation of EIS.

Preparation of preliminary draft EIS.
Meeting at project area with EPA's consulting
team and Southwest Lincoln County Sanitary
District Board.

Draft EIS released.

Public hearing on draft EIS.

Review period on draft EIS.
               Important Issues  and Considerations
      In the  course of  preparing this EIS,  it became clear  that
there were several key issues relating to  the proposed sewerage
system.   These issues  became  evident after discussions with
involved Lincoln County residents  and personnel of various
state and federal agencies  having  interest in the  project
and  from reviewing relevant correspondence.

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     The issues listed below are to be identified and evaluated
in the Environmental Setting and Environmental Impact sections
of this report.  Those issues remaining unresolved and/or of
greater scope than covered in this EIS will be discussed in
Chapter V!T - Implementation and Issues to be Resolved.  Of
particular importance are the following questions:

     1.  Present and projected land use and the relationship
         of such use to Lincoln County and Oregon State Land
         Conservation and Development Commission  (LCDC)
         planning goals, guidelines and regulations.

     2.  The rate and distribution of future construction on
         vacant land that can be tied to the sewerage project
         as compared to retention of the present situation.

     3.  Patterns of land ownership and level of monetary
         benefit to be derived by landowners from a sewerage
         project.

     4.  Response of traffic and circulation patterns to growth
         in relation to present and planned roads, streets and
         highways.

     5.  The cumulative impact of district growth and activities
         on surrounding lands and their relationships to
         possible "carrying capacity".

     6.  Possible interrelationships between district develop-
         ment and general tourism.

     7.  Possible direct impacts of projects on parks and
         public use lands, and the impacts of public use on
         residential and commercial uses.

     8.  General level of hazard to public health and
         aesthetics of using septic tanks.

     9.  The financial impact of capital and operating costs
         on present and future residents in the district.

    10.  The purpose and objectives of doing an EIS.

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    II. ENVIRONMENTAL SETTING
«I,Z ^"^^^F'^w'^y^^^^^^c'' ^TO&yiMfriMfe^w^fc.
                                                      . ^
                                             XW««C4—

                                 '3%'

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                 II.  ENVIRONMENTAL  SETTING


             Physical and Biological Features


Location
     The Southwest Lincoln County Sanitary District  study
area is located along a 7-mile  segment of the central Oregon
coast, between the Cities of Yachats and Waldport.   Waldport
is approximately  80 miles northwest of Eugene,  100 miles from
Salem and 135 miles from Portland.  The area is bounded on the
west by the Pacific Ocean and the east by private land holdings
and the Siuslaw National Forest  (Figure 1).  Most residential
and commercial development within the district  is within a one
quarter to one half mile strip bordering U. S.  Highway 101.

     The sanitary district encompasses 3,000 acres of land
along a narrow strip varying in width from a maximum of 1-1/2
miles in the north to less than one half mile in the south.
Climate
     The central coastal region of Oregon has a maritime
climate, with high humidity and moderate temperatures the entire
year.  Average annual precipitation in the Newport area is 66
inches; however, it varies substantially along the Coast Range.
Approximately 86 percent of the precipitation falls during the
months of October through April  (Figure 2).

     Due to the maritime influence, temperatures vary only
slightly between seasons, with a daily average temperature of
58°F in summer and 44°F in winter.

     Fog commonly occurs along the coast during the warmer
summer months, particularly during the morning and evening
hours.  V7inds characteristically blow from the northwest during
the periods of high barometric pressure and from the southwest
during the stormy winter months.


Air Quality


     Coastal Lincoln County area has excellent air quality and
ventilation due to the oceanic influence,  area topography and
favorable wind conditions.   The low population and general lack
of industrial development result in few air quality problems.

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                                              WALDPORT
                         ALSEA
                       WACONDA
                       BEACH
              YACHATS
                                                SOUTHWEST
                                                LINCOLN
                                                STUDrAREA
                                                      PROJECT LOCATION MAP
                  SAN MARINE
                                                 SCALE IN MILES
                                                                    NORTH
FIGURE I. LOCATION OF SOUTHWEST LINCOLN COUNTY SANITARY DISTRICT

                                     8

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12-
10-
    9H

CO
uj



I   8'

^   7H
O  6


1

OL

O
111  4
tt  *»•
Q.


   3-



   2-



    I.
    vJAN FEB MAR APR MW JUN JUL AUG SEPT OCT MOV DEC


                        MONTH
                                                    70
60  S


    T3
    m
                                                   -50
                                                   -40
                                                        m

                                                        o
                                                        m
                                                        o

                                                        m
                                                        m
                                                        m
                                                        m
                                                   -30  H
  X	* TEMPERATURE
                                           PRECIPITATION
 FIGURE 2. MEAN MONTHLY PRECIPITATION AND TEMPERATURE

     IN NEWPORT, OREGON. (STATE OF OREGON, 1973, U.S.

     DEPARTMENT OF COMMERCE, 1974).

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     A few monitoring studies have been done on air quality in
Lincoln County; however, the Department of Environmental Quality
is in the process of preparing profiles for each of the air
quality control regions of the state (Johnson, pers. comm.).

     Estimates of pollutant emissions in Lincoln County show
the Georgia Pacific plant in Toledo to be the major source of
particulate and sulfur dioxide pollutants in the county
{Table 1).  Other major sources include automobiles and trucks,
controlled open burning and forest fires.  However, Federal and
State air quality standards have not been exceeded.


Topography and Drainage


     The southwest Lincoln study area lies along the coastal
margin of the western flank of the Coast Range.  Virtually
all of the sanitary district is located on marine terraces
ranging from 10 to 80 feet above mean sea level.  These
terraces form a narrow shelf which gradates eastward to the
more steeply sloped uplands of the Coast Range.

     The study area is bisected with numerous small coastal
streams originating in the coastal mountains and flowing west-
ward to the Pacific Ocean.  Those creeks include Lint, Patterson,
Little, Reynolds, Big, Vingie, Starr, Michell, and Agency
Creeks and Dicks Fork.  Virtually all of these creeks could
represent flood threats during periods of heavy rain; however,
Big Creek  (drainage area 2.7 square miles) represents the only
creek in the study area having substantial flood hazard (State
of Oregon, 1973).  The U.S. Army Corps of Engineers has not
conducted any flood hazard studies in the area to date (Akre,
pers. comm.).


Edaphic Features


     According to the U. S. Soil Conservation Service study  (1972)
conducted in Lincoln County, much of the southwest Lincoln study
area is underlain by three major soil associations — Nelscott-
Depoe Association, Ferrelo-Lint Association and Netarts-Yaquina
Association.  However, the area is covered predominantly^by  the
Nelscott-Depoe Association  (Figure 3).  The pattern of distri-
bution of the soil association is strongly influenced by parent
material and physiographic location.

     Virtually all of the soils making up the three major asso-
ciations in the sanitary district have severe restrictive
features for septic tank absorption field use  (Table 2).  These
restrictions are due to high water table, cemented sands re-
stricting permeability, or rapid percolation and potential for
groundwater contamination.

                             10

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                          Table 1

        SUMMARY ESTIMATES OF EMISSIONS IN LINCOLN COUNTY


                             Tons/Year Pollutant Emissions
Source	 Particulates      Sulfur Dioxide

Georgia Pacific - Toledo        2,000              389

Motorized vehicles

   Light duty                     149               36

   Heavy duty                      21               30

Slash burning                     374

Forest fires                       64
Source:  Department of Environmental Quality, Johnson, pers.
         comm.
                              11

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                                               WALDPORT
                 ALSEA BAY-
              WACONDA
              BEACH
 YACHATS
        SAN MARINE
                                                                      LEGEND
                                                     AREAS DOMINATED BY WELL TO POORLY DRAINED SOILS OF THE
                                                     NEARLY LEVEL TO STKEP COASTAL TERHPCES AND DUNES:

                                                     2.  Nelscott*-Depoc* association
                                                     3.  Perrelo*-Liiit* association
                                                     4.  Netarts-Yaquina association
                                                               Lincoln County Sanitary District boundaries

                                                     This rap is intended for general planning.  Each
                                                     delineation nay contain soils different fmr\ those
                                                     shewn en the map.  Use detailed soil maps for opera-
                                                     tional planning, and on-sitoe inspection for more
                                                     detailed decisions.

                                                     *  Tentative name subject to change in correlation.
                                                     Source: U. S. Soil Conservation Service, 1972.
                                                                         I
                                                           SCALE IN MILES
                                                                                  NORTH
FIGURE 3.  SOIL ASSOCIATIONS PRESENT IN SOUTHWEST LINCOLN COUNTY
                                  SANITARY DISTRICT
                                    12

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                            Table 2

CHARACTERISTICS  OF SOIL ASSOCIATIONS OF THE  STUDY  AREA


* 2  Nelscott-Depoe Association

     Nelscott Soils - Deep loam over clay loam, soils formed on
     water deposited or stabilized dune material.  These soils
     occur on marine terraces above the ocean beaches.  Perme-
     ability is moderately slow.  There is a severe limitation
     in septic tank and absorption field use of the soil because
     of the moderately slow permeability.

     Depoe Soils -  Poorly drained clay loam soils formed in
     water deposited materials.   The soil has 0 to 3 percent
     slopes and a slightly concave position on marine terraces.
     Subsoil layers contain alternating layers of clay loam and
     hard cemented  iron pans.   Permeability is slow and there
     are severe limitations for dwellings,  septic tanks and
     absorption fields and numerous other uses.   Water table is
     seasonally high — from 4 to 12 inches below the surface.


  3  Ferrelo-Lint Association

     Ferrelo Soils  - This loamy soil phase is generally found on
     5 to 30 percent slopes.   There are generally severe restric-
     tions for septic fields,  sewage lagoons  and moderate limi-
     tations for building construction.   The  soil is found  on
     marine terrace deposits.

     Lint Soils - This soil phase is a silty  clay loam usually
     found on 3 to  25 percent  slopes in the study area.   There
     are moderate limitations  for building sites and severe
     restrictions for septic fields and sewage lagoons because
     of contamination to groundwater.


  4  Netarts-Yaquina Association

     Netarts Soils  - Well drained soils formed on old stabilized
     sand dunes.  Slopes are 7 to 30 percent.   The surface  layer
     is fine sandy  loam and the  subsoil is  fine  sand about
     40 inches thick.   Permeability is moderately rapid.  There
     is a slight to severe limitation of use  of  this soil for
     septic tanks,  absorption  fields and sewage  lagoons  due to
     the rapid percolation and potential for  pollution of
     groundwater.  Depth to water table usually  greater  than
     G feet.

     Yaquina Soils  - This soil series is poorly  drained  and
     formed on an interdune position and old  stabilized  dunes.
     Slopes are 0 to 3  percent.   Permeability is moderately
     rapid.  Elevation is 10 to  50 feet.  Water  table is
     seasonally high (November through April)  and at the  surface
     or to 2 feet below it.  There are severe  limitations to
     septic tank, absorption field and dwelling  use.
  *  Represents raajor soil association within  the study  area.

  Source:  U.  S.   Soil Conservation  Service, 1972;
            Rigdon,  pers. coiran.


                               13

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     High water  tables and poor drainage are  common throughout
the area since most of the soils are old dune sand, overlying
marine terrace deposits and are at low elevation (less than 80
feet above sea level).

         "Septic tanks are often ineffective, and without proper
     storm drainage and sewer installations even low-density
     development is impractical.  When terrace soils  become
     permeated by solutions containing soaps, detergents, water
     softeners and other  substances found in septic tank effluent,
     oxidation ponds, sanitary landfills, or other waste dis-
     posal facilities, the result is an increased soil sensitivity
     and reduction of strength" (State of Oregon, 1973).

However, there are locations where septic  tank disposal systems
may be used  efficiently, but these locations  must be determined
by case study.


Mineral Resources

     Construction  aggregate, nepheline syenite,  jettystone and
riprap represent the major mineral resources  in  Lincoln County.
All of the sources of  these mineral resources are outside of
the Southwest Lincoln  County study area —  nearby rock quarries
are located  at Yaquina Head, Agate Beach and  near Waldport
(State of Oregon,  1973).
Geology


     The  geologic composition of the  southwest Lincoln study
area is relatively uniform.  Virtually  the entire area consists
of Quaternary marine terrace deposits and old dune sands.
Marine terrace deposits are "predominantly massive, fine- to
medium-grained, friable sandstone of  beach origin" (State of
Oregon, 1973).  Most of the terrace deposits are 20 feet or
less in depth in the Waldport area, with surface elevations
from sea  level to 80 feet.  The semiconsolidated and old
stabilized dunes overlying these marine terraces deposits range
in thickness from a few feet to more  than 20 feet.

     Small portions of the study area near Big Creek are uncon-
solidated surficial deposits — both  floodplain alluvium  (Qal)
and beach sand and primary dunes  (S)  (Figure 3).  The flood-
plain alluvium is a mixture of sand,  silt, clay and organic
matter, underlain by gravel.  Lower floodplain areas around
Big Creek are of sandy silt, clayey silt and silty clay
composition.  The thickness of the deposits ranges from 10 to
40 feet.
                               14

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     The beach sand and primary dunes are unconsolidated and
susceptible to wave and wind erosion.  These dune deposits
occur west of Highway 101 and south of Big Creek State Park.

     Areas of Alsea siltstone  (Toa) are scattered throughout
the study area.  This geologic unit is predominant to the east
of the marine terrace deposits.
Geologic Hazards


     Geologic hazards in the study area consist of coastal
erosion of marine terraces and sand areas, fault zones, high
groundwater tables, flooding, and landslides and slumping.

     Erosion.  Erosion of marine terraces, sediments, sand
spits and dune areas is a critical concern along all of the
coastal portion of the study area.  The State of Oregon (1973)
in its report entitled the Environmenta1 Geology of Lincoln
County, Oregon, identified the entire coastal region of sand
dunes and marine terraces from Waldport to Yachats as having
critical erosion potential.  Changes in the profile of the
shore occur constantly as a combination of natural forces act
to erode and deposit sand and sediments.  In general, the
terrace margins are retreating at the rate of one foot per
year due to wave erosion and sloughing of sand on steep cuts
(State of Oregon, 1973).  Human alterations of the beachline
greatly affect these natural erosions sometimes in an unpre-
dictable manner.

     Earthquake faults.  The southwest Lincoln study area is
intersected by six concealed earthquake faults, all trending in
a northwest or northeast direction.  Each fault is concealed in
the semiconsolidated dune sands on the marine terrace deposits
indicating that fault movement is at least 0.5 million years
old.  Figure 4 shows the estimated locations of those faults.
Historical earthquake data show that seven seismic events have
occurred in Lincoln County since 1897 (Table 3).  All were of
a III or IV Mercalli intensity (approximately 3.5 to 4 on the
Richter scale).  During an earthquake event, ground motion is
generally magnified in areas of unconsolidated or semiconsoli-
dated deposits.  Saturated lowland soils may result in landslides
and liquefaction.

     High groundwater.   High groundwater tables underlie
virtually "the entire study area.   Such a condition is due to
the thin layers of cemented sands in the marine terraces which
restrict the downward percolation of water.  The problem of
high groundwater in the area from Yachats to Waldport appears
due to a downwarping, hillside seepage and saturated soils from
high rainfall.


                             15

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                                         WALDPORT
YACHATS
                                                                  LEGEND
                                                      ••••	Fault(Dotted where concealed)
                                                        £b Flood area
                                                      \\\Y High ground-water fable
                                                            Coastal Erosion:
                                                      • • • • Erosion of thin marine terraces
                                                            over basalt
                                                      •     Critical erosion of marine terraces
                                                            and sediments
                                                            Critical erosion of sand spits and
                                                            dune areas
                                                            Data from: State of Oregon (1973)
                                                                I
                                                     GALE IN MILES
                                                                              NORTH
                                        16
               FIGURE 4. GEOLOGIC HAZARDS OF THE STUDY AREA

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                                          Table 3



                    RECORDED EARTHQUAKES IN THE LINCOLN COUNTY AREA






                                                      Intensity
Year
1897
1902
1916
1928
1940
1941
1957
Date
January 26
June 14
January 4
September 4
May 25
October 19
March 22
Location
Newport
Newport
Newport
Newport
(44.7° N-124.1°W)
Waldport
Seal Rock
Alsea
(Modified Mercalli)
IV
IV
IV
IV
IV
III
III
Remarks



Felt for radius
of 10 miles
Felt at Toledo and
Depoe Bay; small
objects were moved
at Waldport


Source:  State of Oregon, 1973.

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     Flooding.  Flooding can be caused by heavy rainfall,
melting snow, high ocean tides and strong winds and a number of
other factors.  Stream flooding is a potential hazard along
virtually all streams in the study area and particularly along
Big Creek — the largest stream within the study area.  Flood
damage from high tides and/or storms is possible along the
entire coast of the study area (State of Oregon, 1973).  Such
an event occurred during December 1967 when the entire Lincoln
County coastline was battered by high storm waves.


     Landslides and slumping.  The hazard of landslides and
land slumping is generally slight within the study area.
Areas of hazard occur just to the north of Alsea Bay in the
upper Buckley Creek watershed and in slope areas greater
than 50 percent.

     The hazard of landslides along the shoreline is slight
since most of the shoreline of the study area consists of
low terrace deposits.  The erosion hazard is generally high,
however.
Biotic Resources
     The coastal location of the study area provides for a
variety of habitats and biotic life forms.  The biotic resources
consist of three major groups — marine, freshwater and
terrestrial.  Each has its own characteristic flora and fauna.

     Marine environment.  Marine life occurs along the entire
beach shoreline of the study area and in Alsea Bay to the north
of Waldport.  By far the most abundant marine habitat within
the study area is the open-coast sandy beach which extends from
Waldport to just north of Yachats.  Sandy beaches are sparsely
populated in comparison with rocky shores and mudflats of
estuaries and bays.  Appendix A-3 lists the life forms most
commonly found in the marine environment — in the bays, on the
beaches and immediately offshore.  The marine environment repre-
sents an important economic feature of the central Oregon coast.

     Freshwater environment.  A majority of the streams within
the study area originate in the nearby coastal mountains and
enter directly into the Pacific Ocean.  As a result, most
streams support anadromous fish populations and few resident
species.  Small coastal ponds and marshes are scattered through-
out the district.  Appendix A-4 lists those fish species most
common to the streams of the study area.
                             18

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     Terrestrial  environment.   The  flora of  coastal south-
west Lincoln County  is  characterized  by  vegetative forms
varying  from the  prostrate  pioneering sand binders (such as Poa
macrantha  and Festuca rubra)  to the later successional species
such as  beach pine  (Pinus contorta),  Sitka spruce  (Picea
sitchensis) and red  cedar  (Thuja plicata).  The beach pine is
the most common vegetative  species  of the stabilized sand dune
and strand communities.

     Appendix A-l identifies  the more common vegetation of the
study  area, while Figure 5   and Table 4  show the present
vegetative cover  types  of the study area.

     A wide variety  of  wildlife species  are  associated with the
coastal  dune and  strand communities.   Common birds, reptiles,
amphibians and mammals  are  identified in Appendix  A--2.

     The black-tailed deer  (Odocoileus hemionus columbianus) is
the most common of the  big  game mammals  in southwest Lincoln
County.  Roosevelt elk  (Cervus canadensis),  black  bear (Ursus
americanus) and mountain lion (Felis  conc'olor)  occur in the
more remote portions of Lincoln County.

     Band-tailed  pigeon (Columba fasciata),  mountain quail
 (Oreortyx  picta)  and blue grouse (Dendra"gapus obscurus)  are
found  in varying  numbers throughout the  region.  The band-
tailed pigeon is  the most common game bird and nests in the
coastal  Sitka spruce zone  (Smith and  Lauman,  1972).

     Rare  and endangered wildlife.  Six  species  of  wildlife
identified by the U. S. Department  of Interior (1973)  and
the Oregon State  Game Commission (1973)  as rare, endangered
or possibly threatened  with extinction could occur within
the project area. Those animals are  listed  in Table 5.

     Among the six species,  the northern spotted owl is
likely to  be found in the study area.  The other listed
species  could occur  in  the  study area for  at least part of
the year.  One amphibian —  the tailed frog  (Ascaphus truei),
is deemed  a rare  species in part of its  range (Wailowa
Mountains), yet is a common  species within the study area
 (Storm,  pers. comm.).
Aesthetic Values


     Much of the ocean, beach and forest lands surrounding the
sanitary district are in their natural status, thus providing
a scenic environment encompassing exposed rocky coast, sandy
beaches, coastal sand dunes, shore pine vegetation and spruce-
cedar forests on the higher inland slopes.
                             19

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           WALDPORT
WACONDA
  BEACH
                                                             LEGEND

                                                     R    Residential or Commercial
                                                     SM   Salt Marsh
                                                     B    Barren
                                                     W    Water
                                                     SB   Sandy Beach
                                                     RC   Rocky Coast
                                                     P    Park
                                                     G    Grasslands
                                                     BP   Beach Pine
                                                     SS   Sitka Spruce
                                                     S    Scrub
                                                     BP/SS Beach Pine/Sitka Spruce
                                              SCALE IN MILES
                                                                          NORTH
          FIGURE 5  VEGETION AND LAND USE-SOUTHWEST LINCOLN COUNTY
                       SANITARY DISTRICT (SECTION I)
                                     20

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   SAN MARINE
YACHATS
         LEGEND
 M    Fresh Water Marsh
 R    Residential or Commercial
 SM   Salt Marsh
 B    Barren
 W    Water
 SB    Sandy Beach
 RC    Rocky Coast
 P    Park
 G    Grasslands
 BP    Beech Pine
 SS    Sitka Spruce
S     Scrub
BP/SS Beach Pine/Sitka Spruce
                                          SCALE IN MILES
                                                                      NORTH
        RC
      FIGURE 5 VEGETATION AND LAND USE-SOUTHWEST LINCOLN COUNTY
                     SANITARY DISTRICT(SECTION2)
                                 21

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                          Table 4

            VEGETATION AND LAND USE - SOUTHWEST
             LINCOLN COUNTY SANITARY DISTRICT
                                       Approximate
Land Use or Vegetative Type
Residential
Beach Pine and Sitka Spruce
Sandy Beach
Rocky Coast
Parks*
Total Acreage
Acres
1,286
1,441
352
17
43
3,139
Percent
41
46
11
1
1
100
* Represents only developed areas - natural vegetation on
  parklands is included in other categories.
                             22

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                             Table 5

     RARE, ENDANGERED AND THREATENED VERTEBRATE SPECIES WHOSE
      DISTRIBUTION INCLUDES THE SOUTHWEST LINCOLN STUDY AREA
                                                     Present Status1
Common
Name
Scientific
Name
Federal
FR T
State2
R E
Brown pelican
Northern bald eagle
                              BIRDS
               Pelecanus occidentalis
               Haliaeetus  leucocephalus
                 alascans
Aleutian Canada goose  Branta canadensis
Peregrine falcon
Northern spotted owl
                 leucopareia
               Falco peregrinus
               Strix occidentalis
                 caurina
x
x
Western snowy plover   Charadrius alexandrinus
                         nivosus
                                                 SU
Tailed frog
                            AMPHIBIANS
               Ascaphus truei*
                                                                  x
             x
         x


         X




         X
   Status
   FR
   SU
   R

   E
Federal Register - Species is on the official endangered
species list, Federal Register, June 4, 1973.

Those species identified by U. S. Fish and Wildlife Service,
1973.  Threatened Wildlife of the United States.

Status Undetermined - A status undetermined species or
subspecies is one that has been suggested as possibly
threatened with extinction, but about which there is not
enough information to determine its status.  More infor-
mation is needed.

Rare

Endangered
   State of Oregon - Information from the Oregon State Game Commission
   Bulletin, January 1973,  Vol.  29,  No.  I,  and from the Threatened or
   Endangered Oregon Wildlife List,  January 1975.
   Tailed frog population not considered rare within study area
   (Storm, pers. comm.).
                                 23

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     Alsea Bay directly to the north of the study area provides
additional natural scenic values.  Although the coastal region
often has periods of rain, clouds and fog, the area is nonethe-
less highly attractive to tourists and seasonal residents.

     When traveling Highway 101 from Yachats to Waldport, the
landscape is dominated by beach pine vegetation and scattered
residential-commercial development.  Many structures throughout
the district are in a state of disrepair and probably detract
from the scenic beauty.  However, the aesthetic qualities of
the area attract large numbers of summer residents and
vacationers.  The beauty of the coastline and associated
recreational facilities represent positive aesthetic values in
the Yachats/Waldport area.


Water Resources and Water Quality


     Surface water.  Surface water resources are plentiful
within the study area.  Nine streams originating in the coastal
mountains flow through the study area to the ocean.  The Alsea
and Yachats River represent major surface water sources to the
north and south of the study area.  The Alsea River, with a
watershed covering 743 square miles  (234 square miles in Lincoln
County), is one of the largest river systems in Lincoln County.
The Yachats River has a watershed of approximately 61 square
miles  (Clark and Groff Engineers, Inc., 1970).

     With the abundant rainfall and runoff in Lincoln County,
surface water supply is maintained in most streams throughout
the entire year.

     Big Creek,  Vingie and Starr Creeks have been classified
by the State Water Resources Board of Oregon for use only for
domestic, livestock, municipal, noncommercial irrigation,
minor power development and instream uses for recreation,
wildlife and fish life.

     The water quality of most surface streams is generally
good.  The water quality standards for surface waters of the
State of Oregon are located in Appendix C-l.

     Groundwater.  Virtually all of the southwest Lincoln
County study area between Waldport and Yachats has been identi-
fied as an area having a high groundwater table.  Much of the
problem with high groundwater in the area is due to perched
water tables created by impermeable soils and lateral and down-
slope movement of water from upland areas.
                             24

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     The marine terrace area  (Qmt) and some dune areas  (S)
offer the greatest potential  for providing large quantities
of water for domestic purposes.  Existing wells in marine
terrace deposits have the highest average yield  (19 gallons
per minute) of any of the geologic formations in Lincoln
County.

     Contamination from septic tanks and leach fields constitutes
the major problem associated  with use of dune and marine terrace
groundwater resources for domestic supply.

     The quality of groundwater in areas free of contamination
is usually good and suitable  for most purposes.  Some wells  in
dune or marine terrace deposits have iron and manganese content
in excess of 0.3 ppm  (parts per million).


     Water use and supply.  The Southwest Lincoln County
Sanitary District boundaries  are essentially the same as the
boundaries for the Southwest  Lincoln County Water District.
Existing water facilities consist of two diversion dams on
Big Creek and Starr Creek.  The combined low summer flows of
the two sources range between 0.6 and 1.1 million gallons per
day.  Two 200,000-gallon storage tanks are located at the
north end of the district near Waldport.  An intake and
settling basin were constructed on Dick's Fork in 1974-1975.

     According to a Lincoln County Regional Water and Sewerage
plan prepared by Clark & Groff Engineers, Inc. (1970), the
present system at a maximum daily demand of 300 gallons per
capita per day would be sufficient to support a population of
2,000.  The use of 300 gallons of water per capita per day
(gpcd) appears unnecessarily  high as the national average rate
of consumption is estimated to be 150 gpcd.  According to
Robert E. Meyer Engineers, Inc. (1974), the annual average rate
of water consumption in the Southwest Lincoln County Sani-
tary District is 150 gpcd.  At such an average rate of con-
sumption, the existing water  system would be sufficient to
support a population of 4,000.

     The water district has considered Vingie Creek as a future
source of water.   It has water rights for 0.3 cubic feet per
second (0.19 mgd)  of flow.   It is  projected that  an additional
320,000 gallons of reservoir storage will be needed in the
district to meet  1990 population needs.   The combined water
supply from the three creeks would supply a summer  population
of 3,000 people.   The quantity of  water available to the dis-
trict is sufficient to meet the needs of all projected growth
in the area, assuming that storage and transfer  facilities are
constructed as necessary.
                            25

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     The physical and chemical water quality standards and
recommendations of the Public Health Service and the Oregon
Board of Health appear in Appendix C-2.
Existing Sewage Disposal Conditions


     Septic tanks with subsurface leach fields are the major
means of treating and disposing of sewage in the Southwest
Lincoln County Sanitary District.  Virtually all residences
and commercial buildings have horizontal leachfields or
vertical seepage pit disposal systems, although seepage pits
are no longer allowable under Department of Environmental
Quality requirements.  The Camp Angell Job Corps Center and
Tillicum Beach maintain a small  (0.02 mgd capacity)  sewage
treatment plant which discharges secondary treated waste-
water to Big Creek.

     Portions of coastal Lincoln County have sewage disposal
problems.  During 1968 and again in 1972, these problems
along county beaches were surveyed by the Lincoln County
Sanitation Department, the Oregon State Health Division and
the Department of Environmental Quality  (Oregon State Health
Division, 1973).  In southwest Lincoln County, eight problem
sources of sewage were conclusively identified during the
1972 survey.  Tests  on eight other dwellings were inconclusive
and two dwellings were found to have satisfactory disposal
systems.  Those problem sources appeared clustered in two
major areas — from Yaquina John Point south to Waconda Beach
and at San Marine.
     Soil conditions within Southwest Lincoln County Sanitary
District greatly influence the performance of septic tank
systems.  The sedimentary substratum is often overlain by
layers of impervious sandstone, blue clays or silt which
appear as alternating bands.  These impervious layers cause
water to accumulate  and form a perched water table which
typically flows laterally westward, breaking to the surface
on cliffs, cut banks and beaches.  Under Lincoln County regu-
lations, septic systems cannot be installed wherever the depth
to this perched water table is less than two feet from the
surface during any season of the year.

     The problems of impervious soils and high groundwater
are compounded by the fact that many dwellings are located in
dense clusters and on small lots (sometimes as small as 3,750
square fset).  Such small lots are of inadequate size to support
a saptic tank, leachfield plus full replacement area in case
the existing saptic system fails.  While many homes in the past
were constructed on small lots, in the future  (after July 1,
                             26

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1976) septic system approvals must be based on a minimum lot
size of 7,500 square feet.  It is quite possible that 7,500
square feet may not be adequate for proper sewage disposal,
and that a lot size on the order of 15,000 square feet would be
more suitable (Oregon State Health Division, 1973; Dobey, pers.
comm.; Osborne, pers. comm.).  According to the subdivision
evaluation in the Oregon State Health Division report (1973) ,
"on all lots examined the biggest limiting factor for the proper
installation of a subsurface sewage disposal system is the lot
size.  The average size of the 1,005 lots examined was approxi-
mately 85 by 100 feet.  Even in ideal situations, it is impossible
to place a house, driveway, garage and septic tank drainfield
with full repair area on this sized lot".  Even with larger lot
sizes, approval of a septic system may not be possible if the
groundwater is too close to the surface, the slope is great
or percolation is inadequate.  Septic systems on large lots
have been disapproved in the past in southwest Lincoln County
(Lincoln County Health Department, individual site evaluations
for subsurface sewage, 1971-1974).

     The presence of a possible health hazard in southwest
Lincoln County has been documented in the 1968 and 1972
beach surveys and during a 1974 Department of Environmental
Quality field survey in the Yaquina John Point area.   Those
septic systems found in violation during the 1972 survey have
been for the most part corrected by pumping out the septic
wastes and/or relocating seepage pits or adequate leachfields.
However, because of the inherent soils and groundwater problems,
most corrections have been considered as "stop-gap" measures
(Dobey,  pers. comm.;  Osborne, pers.  comm.).

     In March 1975 the Oregon Department of Environmental
Quality prepared an Area Review Report - Waldport to  Yachats.
This report reviewed past surveys  done in southwest Lincoln
County and summarized the documented septic system problems
and possible health hazards in the area.  Examples of sewage
problems from the report are as follows:

     "1.   Beachside State Park has had problems continually.
          Systems have failed in the past and 12 dry  wells
          were installed in 1972 and these failed within
          two weeks.

     "2.   The Special Services Division conducted a house-
          to-house survey in July  1974 on Seabrook Lane  and
          found  many  sewage system failures.   One man inter-
          viewed said that 'most of  the septic tanks  run into
          the streams mostly through springs  which erupt along
          the canyon...'.
                             27

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     "3.  Twenty unit trailer park at Yaquina John Point has
          had sewage in ditches.

     "4.  Wakonda Beach - Center Street - some sewage problems
          but low use homes.

     "5.  Big Creek area - homes south of Big Creek have
          failed because of high water table sewage.

     "6.  Failures have occurred at Sea Shore Cottages."
          (Department of Environmental Quality, 1975)

     Although most of the documented septic system failures
and problems in southwest Lincoln County have been in the area
west of Highway 101, septic system denials have been spread
throughout the district, indicating that the problem of high
groundwater and impermeable soils is general to the study area
rather than of a localized nature.  This is verified by
Figure 4, Geologic Hazards of the Study Area.

     In all likelihood, high groundwater in some parts of the
southwest Lincoln County study area is in contact with sewage
effluent from septic systems.  During the rainy winter months
and in very wet years, sewage and groundwater contact probably
becomes more prevalent.  Since a majority of the residences
of the Southwest Lincoln County Sanitary District are on a
district water supply, the documentation of well contamination
is nonexistent  (Dobey, pers.  comm.).
Archeological - Historical

     Cultural background.  When the first Europeans arrived
on the Oregon coast, two groups of people, the Alsea and the
Yaquina, occupied the coast between the present Towns of
Newport and Yachats.  Historically the Yaquina were restricted
to Yaquina Bay and the lower 30 miles of the Yaquina River
(Dorsey, 1890).  The majority of known Alsea sites were situated
on Alsea Bay and the Alsea River.  Unlike the Yaquina, several
coastal sites were reported for the Alsea.  The northernment
village, Ku-tau-wa, was situated at Seal Rock.  The southern-
most village, Ya-qai-yak, underlies the modern Town of Yachats
(Dorsey, 1890).

     The Yaquina and Alsea were linguistically classified as
Ponutian-speaking people (Schaeffer, 1959) and, along with the
Siuslaw, further subdivided into the Yakonan stock  (Swanton,
1952).  Dorsey (1890) noted that the Yaquina and the Alsea
spoke the same dialect but could be "distinguished by a few
provincialisms".  Lacking any other distinction, the Yaquina
are often lumped with the Alsea and discussed as a single group
(Backham, 1973).

                              28

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     Mooney  (1928)  estimated  the pre-contact  (1780) Alsea,
 Yaquina, and  Siuslaw population to be around  6,000  individuals.
 The  1910 census  lists  29 Alsea and 19 Yaquina (Department of
 Commerce, Bureau of the Census, 1915).  By  1930 only  nine Alsea
 remained  (Swanton,  1952).  Numerous  diseases  introduced by
 Europeans were responsible for most  of  the  population decline.
 Displacement  of  native groups by Euro-Americans and the resultant
 increased pressure  on  limited natural resources accelerated the
 rate of decline.

     With the establishment of the reservation system in 1856,
 the  Yaquina-Alsea were placed under  the jurisdiction  of the
 Alsea  subagency.  Coos, Lower Umpqua, and Alsea populations
 were concentrated in several villages,  the  largest at Yachats,
 and  encouraged to become agriculturalists.  Most attempts at
 agriculture failed.

     The Alsea subagency was opened  for Euro-American settlement
 in 1876.  Those  Yaquina-Alsea who had not already done so were
 moved  to the  Siletz or Grande Ronde  reservations  (Beckham, 1973).

     Our knowledge  of  the native cultures of  the central Oregon
 coast  is tragically deficient.  The  more affluent and colorful
 peoples to the north and south monopolized  the interest of
 early  coastal observers.  The coastal peoples of Oregon, re-
 moved  from the main line of communication,  were viewed as "an
 eddy in the swirling current of North Pacific culture"
 (Drucker, 1939).  When the deficiency was recognized,  it was
 too late.  All that remained were a  few scattered elderly
 individuals, several generations removed from a now extinct
 cultural system.  From these informant's vague images  were re-
 surrected of several lesser-known coastal cultures, included
 among  them the Alsea (Drucker, 1939).  Unless otherwise cited,
 the following brief outline of Alsea culture was gleaned from
 Drucker"s 1939 monograph.

     The Alsea (including the Yaquina) had  developed an
 adaptive strategy designed to exploit four  generalized habitat
 types:   (1)  intertidal zones;  (2)  estuaries;  (3)  coastal streams;
 and  (4) upland meadows.  East-west flowing  river systems bound
 these exploitative  zones together.   The importance of  the river
 systems in Alsea-Yaquina sites were located on the Yaquina River
or the estuary near its mouth.  Seventeen of 20 Alsea  sites were
 similarly located on the other Alsea River  system (Dorsey,  1090).

     The river systems supplied the Alsea-Yaquina with their
primary resource, salmon.   From midsummer to late fall the
rivers were  choked with runs  of chinook, silver and dog salmon.
Salmon were  netted,  speared,  or caught in weirs.   Some meat
                              29

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was eaten fresh, but most was dried or smoked and stored for
winter consumption.  Other economically important fish included
smelt, herring, flounder, perch, and lamprey eels.  Fishing was
confined to rivers, estuaries, and intertidal pools.  The Alsea
were not known to have fished offshore.

     Land mammals were rarely exploited.  Deer were taken in
the summer and elk in the fall.  Fur-bearing mammals, such as
beaver and sea otter, were frequently killed.  Very little
information exists on how these mammals were procured.

     The only consistently hunted sea mammals were seals and
sea lions which were clubbed or harpooned on offshore rocks.
Sea mammals were not pursued on the open ocean.  Whaling was
not practiced although beached whales were utilized.

     Birds were occasionally exploited.  Quail, grouse, sea
gulls, and various waterfowl were the most actively pursued.

     While the above resources were collected by males, females
added molluscs, tide-pool species of plants and animals, roots,
berries, and other vegetable foods to the diet.  One of the more
important root crops was camas collected in upland meadows.
Acorns were also commonly collected in the uplands.

     Permanent winter villages were usually established in a
protected location near  the forest-littoral ecotone and salt-
freshwater ecotone.  These criteria generally fit only one
habitat, an estuary.

     Winter dwellings were large, rectangular, semisubterranean
plank houses with gabled roofs and vertical plank walls.
Smaller rectangular, gabled roof structures were erected at
temporary summer camps.  The covering was grass thatch instead
of planks.

     Transportation was by foot or canoe.  Three kinds of
canoes wero employed historically.  Ocean-going Nootka canoes
were highly prized and occasionally purchased from northern
groups.  A similar but smaller Chinookan canoe was manufactured
locally, and a shovel-nosed river canoe was also of local
origin.  The lack of locally manufactured ocean-going canoes
emphasizes the relative unimportance of the open ocean in Alsea-
Yaquina culture.

     The Alsea-Yaquina were patrilineal and patrilocal.  They
did not have a ranked, hereditary social system.  A man rose
to prominence by accumulating wealth and gained prestige by
distributing his wealth.  The wealthiest man in a village was
generally the headman, but several lineage heads could jointly
                              30

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assume this role.  Villages were politically autonomous.  The
only bonds between villages were kinship and a shared language.
Polygamy was allowed although rarely practiced.  Slaves were
often purchased, but slave raids were not undertaken.

     Archeological background.  Since 1951 three systematic
surveys and one major excavation have occurred on the Oregon
coast between Newport and Yachats.  The pioneering survey was
accomplished by Lloyd Collins in 1951.  He recorded three
sites within the confines of the proposed impact area.  These
sites were 35LNC14, 35LNC15, and 35LNC16 (site files, Museum
of Natural History, University of Oregon).

     In 1968 Wilbur Davis identified 78 sites along the central
Oregon coast.  Only one new site, at the mouth of Deer Creek,
was added to the inventory in our study area (field notes on
file, Oregon State University).   Many of these sites have yet
to be recorded on the state inventory.

     Extensive excavation of the Seal Rock midden (35LNC14)
was begun by Oregon State University under the direction of
Richard Ross in 1972.  A second field season at the same site
was completed in 1974.  Analysis of the Seal Rock data is still
in progress.


     The Oregon State Parks and Recreation Department, Oregon
State Highway Division, authorized an archeological survey of
state parks along the coast beginning in 1975.  The survey is
being accomplished by Oregon State University under the direc-
tion of Richard Ross.  Although sites have been found between
Newport and Yachats, they are well beyond the impact area for
the sewage lines (field notes on file, Oregon State University),

     Federal and state inventory of historic sites.   According
to the latest published version of the National Register of_
Historic Places (February, 19, 1976), only one site is listed
in Lincoln County -- the old Yaquina Bay lighthouse, Yaquina
Bay State Park.

     The Statewide Inventory of Historic Sites maintained at
the Historic Preservation Office, Parks and Recreation Depart-
ment, Oregon State Highway Division, lists two historic prop-
erties within the impact area which may be eligible for in-
clusion in the National Register — the Oregon Coast Highway
and the Seal Rock midden.
                             31

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                  Socio-Economic Features


Population


     Existing conditions.  The Southwest Lincoln County Sanitary
District population fits into three distinct analytical cate-
gories:   (1) permanent year-round residents;  (2) vacation summer
home occupants; and (3) transient tourist population.  Both the
vacation and transient population components have contributed
most to recent population increases, while the permanent
component has increased very slowly and, in various surrounding
cities, actually declined between the last two census periods.
During the period between 1960 and 1970, Lincoln County
population increased much more slowly than the State of Oregon,
while the population in Waldport City, north of the district
increased only slightly faster than the County of Lincoln.
These data are presented in Table 6a.

     The median age of residents of Lincoln County in 1970
was 38 years, while the median for the Waldport Statistical
Division was 42.7 years.  This indicates a greater concentra-
tion of retirement age residents in the project area.  Lincoln
County as a whole contains the largest concentration of retired
persons among all Oregon counties.  In 1970, 18.7% of its total
population were age 65 or older.


     Permanent residents.  The lack of a stable employment and
economic base has inhibited the formation and growth of a
population base in the typical labor force participation age
range.  The approximate permanent population in the District
based on Lincoln County Water, Sewerage and Solid Waste
Management population studies and EPA surveys, is currently
over 816 persons.

     The rate of population growth, 4.9% from 1960 to 1970, as
indicated in Table 6a, may be considered an accurate reflection
of the population growth in the study area, but a more impor-
tant aspect of the district's population characteristics is the
age distribution mentioned above.  During the early 1960's,
several small wood-processing and logging operations in the
area ceased operations, adversely affecting the employment
possibilities for local residents.  A concentration of timber-
related industry formed in and around the City of Toledo,
approximately 35 miles to the northeast.   Hence, an out-
migration of permanent resident labor force participants,
couplad with an in-migration of permanent retiree, residents,
has tended to result in a nearly stable population level.
Although growth in numbers of permanent residents has been very
slow,  the age composition of the population has been changing.

                             32

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                                Table 6a

                  REGIONAL POPULATION - 1970 AND 1960
                                       1970
                                I960
                                      % Chg,
Waldport City

Lincoln County

Oregon
                       700        667

                    25,755     24,635

                 2,091,385  1,768,687
                                        4.9

                                        4.5

                                       18.2
Source:  U. S. Bureau of the Census.
                                Table 6b

             EXISTING AND PROJECTED NONTRANSIENT POPULATION
                  Year-Round
                    Part-Time
                                  Total
               Persons
       Rousing
       Units
        Persons
         Housing
         Units
        Persons
         Housing
         Units
Present (1975)
  population
Historical
  annual
  absorption
Projected
815
340
1,225
510
                              14
2,040
850
                                          23
1985
1995
2025
1,030
1,260
1,920
430
520
790
1,560
1,385
2,880
650
790
1,210
2,590
3,145
4,800
1,080
1,310
2,000
Sources:  Present housing unit count from Southwest Lincoln Water  District
(Campbell); the district has about 900 current users of which  50 are  non-
residential.  Present population from County Sewerage and  Solid Waste
Management Study via Robert E. Meyer.  The total estimate  was  about  2,700,
from which was deducted 660 as the peak transient population.  Absorption
          bv Gruen Gruen + Associates bas^rl nn T.inr^ir, rvMi~4-,»  ~——j~

-------
     Vacation summer home occupants.   In 1970,  12,521 housing
units existed in Lincoln County,  of which 3,014 were vacant yet
not for sale; 94%, or 2,386 of these units,  were located along
the coastal strip of Lincoln County from Lincoln City to
Yachats.  The actual number of these coastal units located
within the Southwest Lincoln County Sanitary District has not
been tabulated.

     Using Southwest Lincoln County Water District connections
of approximately 850 residential service units, and assuming
a persons-per-unit factor of 2.4, a district population esti-
mate of 2,040 persons is obtained.  A survey of subdivisions
within the district indicated a housing ownership pattern of
approximately 40 percent permanent residents and 60 percent
seasonal residents.  Assuming a 60 percent seasonal occupancy
of structures served by the water district,  a seasonal popu-
lation of 1,225 persons is estimated.  This  added to the 815
estimated permanent residents yields a total of 2,040 non-
transient residents  (i.e., permanents plus part-time residents).


     Transient Population.  The firm of Robert E. Meyer Engi-
neers, Inc., estimated the current peak Southwest Lincoln
County population at 2,700 persons, 660 of which are designated
tourist.  A tourist is generally one who stays overnight in
the project area in other than a permanent or seasonal residence.

The tourist industry is very widely discussed and little
understood; no attempt was made to arrive at an alternative
projection.  Extensive data were reviewed on the use of area
tourist facilities such as motels, state parks and campsites.
It appears that steady increases in tourist traffic are
occurring especially during the peak season and that esti-
mates of 660 tourists may be too low.  Tourist estimates for
future years  (HGE, January 1974) would be 760 in 1980, 914
in 1990 and 1,063 in 2000.


     Population projections.  Some units in the Southwest
Lincoln County Sanitary District appear to pre-date 1920,
the year in which the district's first six subdivision recordings
took place.  By using an estimate of 850 housing units within
the district, it appears that the annual absorption of housing
units has been around 23 since 1920.  Between 1920 and 1959,
only three additional subdivision maps were filed; the bulk
of subdividing has taken place since 1960.  Construction activity
in the district appears to have been more active from the 1950's
to the present than  at any time since the 1920's.  Records on
building permits go  back only to 1972.  However, field inspec-
tions, independent estimates of buildout by subdivision
and cf recent and current second-home ownership in Lincoln County
                            34

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 suggest that a range of 20-24  units/year is appropriate for pro-
 jection purposes.   In Table 6b,  an annual increase  of 23 housing
 units is applied  to the estimate of the  current housing stock
 to result in projection of future housing in 1985,  1995 and 2024
 (10,  20 and 50 year projections).  These have been  broken down
 into  two components,  year-round  and part-time,  to reflect the
 addresses of the  present owners  of existing units  (about 60
 percent out-of-town and 40 percent local owners, based on a
 sample compiled by GG+A).

      The population increases  implied  by the figures  presented
 in Table 6b represent a more rapid rate  of growth than has been
 experienced by Waldport recently (Table  6a).   This  would not be
 unexpected,  since  there is more  vacant land available in the
 more  open and rural areas  outside the  towns.

      The population projections  presented in Table  6b corre-
 spond closely to  those provided  by HGE Engineers and  Planners
 in Volume 1 of the Lincoln County Comprehensive Water,  Sewerage
 and Solid Waste Management Plan.   HGE  projects  a 1995 peak popu-
 lation of 4,118 which includes transients who would amount to
 about 24 percent of the total peak season population.   Deducting
 24 percent from the 1995  total estimate  of 4,118 for  the
 district leaves 3,130 year-round and part-time  residents as the
 1995  HGE estimate,  as compared with the  projection  of 3,145
 presented in Table 6b based on historic  absorption  of 20-25
 housing units per  year.

      The projections  in Table  6b are somewhat lower than those
 presented in the Southwest Lincoln County Sanitary  District
 Sewerage Study (Meyer,  1974).  The peak  population  in 1995
 would be 4,300 compared with 3,145 in  Table  6b, while by 2025
 the difference would  be 6,000  (Meyer,  1974)  vs. 4,800  (Table  6b).
 The_Meyer report takes  into consideration  what  the  project
 engineer believes  to  be the stimulating  effect  of provision of
 sewerage in  the area  on growth, while  the  figures in  Table  6b
 represent simply a  continuation of existing  trends.   Table  6b
 figures  also  assume a  household  size of  2.4  (from 2,040  year-
 round  plus part-time  residents divided by  850 housing units)
 which  is  slightly  lower than Meyer's 2.5 persons-per-household
 (drawn  from census  data reflecting only  the permanent population)

     In  evaluating  the projections,  the reader  should keep in
mind the  distinction between a projection and a forecast.  A
projection is  an extrapolation into  the  future of existing
 trends.  A forecast involves the application of additional
 information and judgment to adjust a projection with a view
toward making  it more accurate.

     The  figures presented in Table 6b have not been adjusted.
Although many variables may well  alter over time,  there is not
enough information available to translate the projection into
an informed, forecast.  For example, the housing recession of

                             35

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recent years may be protracted and projected new construction
in the project area may therefore be overstated.  The historic
division between local, permanent residents and out-of-town,
second-home owners may not persist into the future and the
growth rate for one group may turn out to be faster (or slower)
than for the other.  A full market study would be necessary
to pin down this variable more accurately.  Demographic var-
iables may also alter:  average household size can change over
time; the exodus of the permanent population in the older
teenage and young adult years could slow down  (or speed up);
the second home market could be reduced by saturation or by
the prior absorption of the most desirable building sites;
changes in preference among consumers affecting the disposition
of recreational expenditures; or decelerating advances in real
income.  While these and other contingencies have not been
taken into account, it is hoped that the figures presented will
suffice for the purpose of considering environmental impacts.
Economy


     The economy of Lincoln County is driven by three primary
activities:   (1) tourism,  (2) fishing and fish processing, and
 (3) forest products.  All three basic industries are highly
seasonal and susceptible to cyclical variations generated by
the state and national economy and natural phenomena.  This
economic instability is a major contributing factor to the slow
population growth in the Southwest Lincoln County Sanitary
District.

     Tourism.  Tourism appears to be the fastest growing
economic benefit within the study area and the second largest
source of revenue for the county as a whole.  A good index of
tourist activity in the project area is the average daily
traffic flow on Highway 101.  This flow is tabulated and pre-
sented in Table 7.  A substantial 22 percent increase in traffic
volume is shown for the five-year period between 1969 and 1974.
The decrease shown between 1973 and 1975 is considered a
reflection of both the temporary gasoline shortage and the
generally depressed economic condition at that time, which
resulted in fewer vacation trips to the Oregon coast.  The
recession years of 1970 and 1971 are also reflected in the
traffic volume data by a smaller than usual increase in traffic
flow.


     Tourism  in the county,  however, is not only susceptible
 to cyclical movements, but is characterized by wide  seasonal
 variations in level of activity.  Table 8 lists the monthly
 average daily traffic in the study area by percentage of 1974
 annual average daily traffic.

                             36

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                         TABLE 7
         Historical Average Annual Daily Traffic
         	U.S. 101; Yaquina Bay to Yachats
                                             Average Daily
Year                                            Traffic
1969                                             4,188
1970                                             4,615
1971                                             4,870
1972                                             5,303
1973                                             5,409
1974                                             5,106
% Increase
1969-1974                                         22%
          Source: Oregon State Highway Division
                  Traffic Volume Tables, 1974
                         TABLE 8
           Average Daily Traffic by Month:  1974
             U.S. 101; Yaquina Bay to Yachats
                      % of 1974 ADT          Volume of Traffic
Month               (5106) Experienced           per Month

January                     56.7                  2,895
February                    62.4                  3,188
March                       82.8                  4,227
April                       92.7                  4,734
May                        107.4                  5,486 ~
June                       124.4                  6,350
July                       147.2                  7,516
August                     162.8                  8,315
September                  122.2                  6,241
October                     90.1                  4,599
November                    78.9                  4,031
December                    72.2                  3,687

          Source:  Oregon State Highway Division
                   Traffic Volume Tables,  1974

                       TABLE 9
         Average Daily Tourist Traffic 1969-1974
             U.S. 101:  Yaquina Bay to Yachats
Tourist
Season
                                               Average Daily
                                              Tourist Traffic
1969                                              1,379
1970                                              1,532
1971                                              1,603
1972                                              1,745
1973                                              1,800
1974                                              1,680
% Increase                                         22%
1969-1974
         Source:  Grucn Gruen + Associates;  compiled from
                  Oregon State Highway Division
                  Traffic Volume Tables,  1974
                       37

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    The tourist season for Oregon extends between the months
of May through August and is most intense during the month of
August, dropping sharply after the Labor Day weekend.  This
pattern is clearly demonstrated by the Average Daily Traffic
(ADT) data in Table 8 which shows traffic flows well in excess
of 100 percent of the annual average during these months.
Examination of the distribution of traffic flow from 1969 to
1974 indicates that 1974 was a typical year.

     Estimates of the number of tourist vehicles passing through
the study area on a yearly basis from 1969 to 1974 were also
calculated and are presented in Table 9.

     A comparison of percentage increases in Table 7 and 9,
indicates that tourism is most responsible for overall increases
in traffic flow throughout the study area.  Although tourism is
not significant during the winter months, local residents and
business operators in the area, when questioned, all indicated
that weekend traffic throughout the year had increased substan-
tially in recent years.  The relationship between weather in the
Willamette Valley and along the coast during the winter can
greatly influence a winter tourism.  The percentage increase in
average daily tourist traffic increased by 30% between the
1969 through 1973 period.

     The many coastal state parks and campsites which are
located along Highway 101 have, no doubt, had a salubrious
effect on the travel industry in recent years.  Table 10
contains data on the usage of these facilities during recent
years as compared with that of all similar state facilities.
Some interesting comparisons result from this data which seem
to set this area apart from the rest of Oregon in terms of its
tourist industry.  Between the years of 1971 and 1975, a 33.3%
increase in campernights spent in the study area was observed,
while only a 2.4% increase in usage was observed for all state
facilities.

     The divergence between state-wide and study area use is
explained by the accessibility advantages which the facilities
in the study area have over the majority of the facilities in
the state.  Campsites in the study area are located adjacent
to U.S. 101 which is a major Oregon coast tourist route, but
many of the camping facilities throughout the state are located
off lesser traveled roads.  Coastal campsites and particularly
those in the project area therefore tend to capture a larger
amount of the tourist traffic than the less accessible inland
facilities.  It is significant to note that these data were
compiled from counts of incoming vehicles to the project area
facilities, and many of the parks in Oregon do not have traffic
counters.  Where they are lacking, park attendants usually
estimate usage on a weekly or monthly basis.  Thus, the project
area usage data will generally be more accurate than that of
the state as a whole.

                            38

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Fiscal Year

1970-1971

1974-1975

% Increase
1970-1971

1974-1975

% Increase
                          TABLE 10
                State Park Usage; 1971-1975
Project Area Campsites

       69,639

       92,831

        33.3


    Day Use Facilities


Project Area Parks

    1,277,124

    1,462,905

        14.5
All State Campsites

    1,578,173

    1,616,645

        2.4
All State Parks

   22,325,353

   27,160,202

       21.6
Source:  Gruen Gruen + Associates;  compiled from
         Oregon State Highway Dept.,  Parks &
         Recreation Division raw park usage data
                             39

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      When compared with similar facilities throughout the state,
 day use facilities in the area showed a smaller increase in
 usage.   Again,  accessibility differences may be responsible
 for this divergence.   Day use sites tend to be visited more
 steadily on a year-round basis by local residents than by
 seasonal visitors.  The permanent population of the area is,
 of course, very small compared to that of more developed areas
 within the county and state and,  therefore, local day use
 facilities received less usage than those in heavily populated
 areas.   The day use and overnight camper data seems consistent
 with a slow permanent population growth rate and a relatively
 fast increase in tourist population.

     The travel industry is a difficult one to analyze statis-
tically; however, the tourism data indicate a strong growth
potential for the area.  In order to gauge its importance, a
motel survey of seven establishments in and around the study
area from Yaquina Bay to the northern border of Yachats was
conducted.  The results of that survey follow:   (1) motels
ranged in size from seven to ninety-two units and tended
to average between 16 to 20 units;  (2) all motels were open
year-round;  (3) occupancy varied seasonally and August was
cited as the busiest month, with 90% to 100% occupancy.  All
noted December and January as the slowest months when occupancy
ranged from  25% to 40%;  (4) all motels indicated that their
occupants were almost exclusively tourist, except for one
near Waldport which reported only a 75% tourist market, the
remainder being business, government and forest services
occupancy;  (5) rates varied between summer and winter for all
except one of the motels;  (6) owners and operators reported
that their visitors came from all over the United States and
Canada.  Those visitors from Oregon come primarily from the
Willamette Valley Region;  (7) six of the seven owner/operators
indicated that they felt tourist activity in the vicinity was
increasing;  (8) four of the seven outlined plans for upgrading
and improving their facilities within the next two years; and
 (9) three owner/operators said they considered a new motel in
the area would be a good investment.  Two said they wouldn't
build a new motel, one said motels tie you down too much, and
one talked about high taxes and minimum wage laws.

     No projections were attempted as to the magnitude of
future employment or sales resulting from this industry.  But
in  1973, over 1,200 persons were employed in various jobs
related to the travel industry in Lincoln County  (1974 OCCDC,
p.  B20).   In 1972, about 465 persons were employed in hotels
and other  lodging places in Lincoln County  (Census, County
Business Patterns, 1972), a tripling of the 1962 persons so
employed.
                              40

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      Seasonal vacationers.   A second component of the tourist
 industry is the seasonal resident population which increases
 substantially during the summer months.   The bulk of this
 population owns property in the area on  which they may have
 constructed summer homes or set mobile homes.  The District
 seasonal resident population consists of approximately 1,225
 persons and real estate activities point to a steady future
 growth of this component.

      A survey of the  study  area residential  ownership.patterns
 was  conducted.   The  study was  conducted  by  randomly selecting
 127  lots from various subdivisions  within the Sanitary District,
 of which 100  had dwelling units.   The  incidence of  nonresident
 ownership of  all property sampled was  61.1%,  while  residents
 owned 38.9%.   It was  further discovered  that approximately
 60%  of dwelling units (not  including  trailers) were owned by
 non-residents,  while  40% were  owned and  occupied by residents.
 Lincoln County  building permit records further indicate that
 of all building permits granted for housing  construction
 within the  Sanitary District boundaries  (since 1972 when
 permits became  mandatory),  over 70% of new home construction
 was  by non-residents.  The  residence addresses of these new
 builders ranged throughout  the United  States  and Canada,  but
 the  bulk of them were  in the Willamette  Valley fifty to
 eighty miles  east of  the study area.  Present trends  indicate
 that future building  in the area will be mostly second homes
 for  persons having permanent residences  in other parts of
 Oregon.   This growth will add  further to the  seasonal  popu-
 lation and retirement  economy  base  that  typifies the  Sanitary
 District.

     Forest products.  Forest products, as a major  component of
 the  Lincoln County economy,  still play an important role in
 providing employment income to the area.   Peak employment was
 reached  in 1960, with a level of 2,019 forest product-related
 jobs.  That number has been steadily decreasing, and in 1973,
 forest products accounted for only 809 jobs in Lincoln County.
 Forest products in the project area appears to have diminished
 more quickly since 1960 than for the County of Lincoln in
 general.  A number of small  mills closed  because of their
 inability to compete with larger scale operations based in
 Toledo and other areas.  The Siuslaw National Forest is the
 largest potential timber resource near the project area, but
 it holds little potential for bolstering  the local forest
 product economy.  Much of the timber harvested is shipped to
 larger processing plants in  surrounding Lincoln County and
other communities.
                              41

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     Fishing.  In 1973, Lincoln County accounted for approxi-
mately 20% of the Oregon coast total fish catch.  About 475
persons in Lincoln County were employed in the fishing industry
in 1967 (Clark and Groff,  1970).   Newport, north of the study
area, is the major fishing and fish-processing center in
Lincoln County, but its growth potential is inhibited by the
lack of adequate port and processing facilities.  Recent
estimates indicate that over 90%  of the Newport salmon and
albacore catch and 30% of the crab catch is shipped elsewhere
for processing.  This catch constitutes the bulk of the Yaquina
Bay fishery.  Experimental work in aqua culture and clam
harvesting in the Yaquina Bay area may eventually enhance the
commercial fishery.  Although an important component of the
overall Lincoln County economic base, fishing and fish proces-
sing offer little potential for economic growth in the project
area.


     Employment.  Although study area specific data on employ-
ment were not available, existing county-wide data and exten-
sive tours of the area enable one to make some general conclu-
sions about its employment characteristics.  The relatively
high proportion of population over the age of 65 serves to
support the assumption that self-employment and retirement
benefits constitute a major source of income for district
residents.  U.S. 101, which runs the length of the district,
is dotted with a number of small gift shops, garden and flower
shops, and small item grocery stores, not to mention the motels
discussed earlier.  Real estate is also to be an important
employment category with employment in that sector showing
an increase of 70 percent between 1962 and 1972  (Census,
County Business Patterns).  Over half of the buildable area
in the district has been subdivided since 1960  (County Assessor's
records).  Additionally, Lincoln County had a rate of self-
employment in 1970 of 16.6% of its labor force, while the national
average is about 9% self-employed.  Nearly 6% of those in the
labor force were past the normal retirement age of 65 and 40%
of this group was self-employed  (Lincoln County Planning Depart-
ment, 1973).  In 1973, Lincoln County had 5,050 recipients of
Social Security retirement benefits  (of the coastal counties,
only Coos County had a greater number) or 18% of total popu-
lation, which was the largest percentage of all coastal counties
in Oregon.

     The three major employment sources for Lincoln County
constitute a relatively unstable and seasonal economic base.
This fact is reflected in the unemployment rates experienced
in Lincoln County since 1960, as presented in Table 11.
                              42

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                          TABLE 11

              Annual Average Unemployment Rate
                 Lincoln County, 1960-1971

Year
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
Labor
Force
8,100
7,740
7,640
7,470
7,850
8,400
8,550
8,950
9,100
9,140
9,400
9,420

Unemployed
560
800
590
510
530
530
560
630
520
570
740
740
% of Labor Force
Unemployed
6.9
10.3
7.7
6.8
6.8
6.2
6.5
7.0
5.7
6.2
7.9
7.8
       Source:   Research &  Statistics,  State  of  Oregon,
                Employment  Division,  Corvallis;  January,
                1972.   In:  Lincoln  County  Planning  Depart-
                ment,  1972;  overall economic  development
                plan,  Lincoln County.. Oregon.
                       TABLE  12


                   Source of Income
                 Lincoln County:  1970
Source

Wage and Salary

Non-Farm, Self-Employed

Social Security
Mean Income

 $7,868

  6,585

  1,793
          Source:  1970 U.S. Census of Population
                               43

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     Income.  In 1970, the annual family income for the majority
of Lincoln County families was between $5,000 and $10,000
(1970 U.S. Census).  The average family income was $9,031.00
per annum which was lower than that of all the surrounding
counties as well as that of the state.

     Given the importance of self-employment and retirement
benefits as a source of income in this district, the mean
income levels by source in Table 12 are illuminating in terms
of the study area income level.

     Because of the higher-than-average concentration of
retired and self-employed residents in the district it appears
likely that income in the area is well below that of the
county and the state for the bulk of the permanent population.


Future Trends in Population Growth


     Factors affecting future population growth.  The popula-
tion growth of the project area is at best difficult to predict
because of the changing character of the community.  Generally,
increased employment prospects tend to result in population
growth within a given area.

     Since the Southwest Lincoln County Sanitary District
population consists of such a large proportion of individuals
who are non-participants in the labor force, other factors such
as property values, availability of tourist accommodations and
natural environmental amenities may become more important
forces in shaping the future character and size of the South-
west Lincoln County community.


     Future employment prospects.   The forest products indus-
try arid the fishing and the fish-processing industry are not
likely to result in significantly increased future employment
opportunities for residents of the community.  To the contrary,
increased mechanization in both of these industries could
appreciably diminish already existing opportunities.

     The tourist industry appears to hold the greatest potential
for the area in terms of employment prospects.  Presently, the
privately owned and operated motels, gift shops, restaurants
and small grocery stores cater to this market.  It is the
largest source of self-employment presently in the community.
Because of the seasonal character of this market, it appears
that additional proprietor participation will take the form of
expansion of existing facilities before new entries of a signi-
ficant level are realized.  This industry also furnishes a
source of seasonal employment for the retirement aged residents.

                            44

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     Retirement and vacation population growth.  This has been
the largest source of population growth in recent years.  It
is of course highly dependent on land availability and prices.
Assessed valuation trends of the Southwest Lincoln County
Sanitary District are presented in Table 13 and provide a
comparison with trends in property valuation at the county
and state level.  The present total property tax rate in the
Waldport-Tidewater section of Lincoln County is $19.73 per
$1,000 of assessed valuation.

     Table 13 indicates that property values within the South-
west Lincoln County Sanitary District have not been increasing
as fast as all property within the State of Oregon, and an
increase at a rate well below that of the rest of Lincoln
County.  The relatively slow growth in Southwest Lincoln
County District property values may be explained in part by
restrictions placed on property owners in the area during
recent years.  In an effort to preserve the environmental
quality of the area and comply with State Department of
Environmental Quality regulations and directives, Lincoln
County Sanitary officials have disallowed a number of requests
for building permits on the basis of inadequate soil conditions
for septic tanks.  The bulk of property in the district is
zoned for residential usage and held by individuals with
intentions to build retirement or second homes.  Many of the
building lots, however, are smaller than the minimum size
eligible for septic tank usage and therefore cannot be
developed for their intended purpose.   This has probably been
a factor in holding property values down within the district
and may account for some of the divergence between district
and county assessed value trends.

     Future growth of the retirement population will depend
not only on the level of land prices in the district but on
the tax and service rates resulting from providing the necessary
sewerage facility and other utilities which will enable the
building of retirement and second homes.  Large increases in
property values may discourage newcomers to the area and
inhibit anticipated buildout while excessive sewer district
costs may actually depress property values and thus discourage
future growth.


     Tourist population.   The management of state parks and
recreation facilities within the district will be a key ele-
ment determining future growth of the area transient popula-
tion.  Further acquisitions of beach property are not presently
planned by the State of Oregon.  However, the development of
an additional coastal park in Southwest Lincoln is planned.
San Marine will be developed for tourist usage within the
coming years and should therefore accommodate a larger peak
tourist population.  Any expansion of motel facilities or
additional entries to the industry will surely result in an
increased peak population during the summer months.

                              45

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                         TABLE 13
                  Real Property Valuation
                                            Southwest Lincoln County
Year   State of Oregon     Lincoln County     Sanitation District
1969   13,215,725,797      281,526,299           9,374,690
1975   26,190,390,714      568,637,940          17,521,722
% Increase   98%               102%                87%

                Source:   Gruen, Gruen + Associates
                               46

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 Land Use
      The  Southwest Lincoln County Sanitation District extends
 south along  the  Oregon coast  from Yaquina  John Point to Mitchell
 Creek north  of Yachats.   Existing development in  the District
 has  tended to hug  the  coastal strip  and  concentrate  itself  on
 embayments and on  either  side of  U.S.  Highway 101.   The devel-
 oped areas to the  west of the highway  provide easy access to
 the  sandy beaches  and  rocky coastal  sites  which abound in the
 project area.  Because of steep and  rugged terrain to the east
 of and in places along Highway 101,  development has  tended  to
 occur in  clusters  which afford the greatest highway  access  and
 ocean view.  General land use in  the area  is shown in Figure 5.

      The  inland  boundary  of the district lies one to two miles
 east of the  coast.  Approximately 3,000  acres of  land are
 contained within the district boundaries,  the distribution  of
 which is  indicated in  Table 4.


      Residential.   The Sanitary District contains 20 legal  sub-
 divisions.   However, it is not known how many lots within these
 subdivisions are actually buildable.   A  substantial  portion
 date back to the early 1900"s when streets in some instances
 were dedicated yet no  rights-of-way  have been granted,  only
 from 20 to 30 feet has been set aside  for  roads.  Many of these
 dedicated streets  end  at  the  beach front and provide public
 access to the beach.   The topography and soil conditions of
 some areas make  it very unlikely  that  streets or utilities  will
 ever be installed  in some of  the  platted subdivisions.

      The  newer subdivisions (those established since 1950)
 are  more  likely  to have streets which  have been designed in
 conformance  with the physical conditions of the land.   An
 examination  of the actual sites and  subdivision area maps,  as
 well as county assessment records, indicates  that approximately
 30%  of the subdivision lots have  been  built upon.  Table 14
 lists the district subdivisions and  indicates  the age and level
 of present development, as  well as the percentage of buildings
 owned by  local residents.   These  dates and percentages  are
 rough estimates  compiled  from extensive  tours  of the area and
 conversations with  county assessor's office  officials.


      Recreation.   There are four state and federal campgrounds
and recreation facilities in the district.   The state has plans
to develop one other,  San Marine,  as  indicated on  the land use
map,  Figure 6.   In addition to the state park, the U   S
Department of Agriculture maintains the Siuslaw National Forest
                            47

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                          Table  14

    SUBDIVISIONS IN SOUTHWEST LINCOLN SANITARY DISTRICT


                                        Assessor's  Records -
Subdivision
Yaguina John Point
Seawood Parks
Rolling Hills
Pine Crest
Big Stump
Edgewater Shores
Edgewater
Pacific Sands
Wakeetum Green
Surf Pines
Wakonda Beach
Big Creek Estates
Tillicum Beach
San Marine
Shore Pine Crest
Crab Apple Hill
Reynolds
Aqua Vista
Ocean Crest
Fairway Heights
Sunset View
Year
Subdivided
1930
1945
1964
1960
1968
1970

1960
1970
1970
1920
1971
1920
1920
1969
1965

1920
1920
1970
1970
Actual Number of
Platted lots
61
28
9
18
10
9
8
12
64
10
148
16
151
439
8
129
38
45
144
32
10
Source:  Gruen Gruen + Associates from estimates by Miller,
         pers. comm. and from the Lincoln County Planning
         Department.  Acreage figures not available.  It
         should be noted that the number of lots given is
         only for the plotted sections of subdivisions, some
         of the subdivisions can expand to adjacent lands,
         thereby increasing the number of lots.
                             48

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                         WALDPORT
PACIFIC OCEAN
       WACONDA BEACH
       SAN MARINE
                                                    'C
                                                  LEGEND


                                                  R  RESIDENTIAL

                                                  RR RECREATION RESIDENTIAL

                                                  I   INDUSTRIAL

                                                  P  PARK OR PUBLIC OPEN SPACE
                                 FIGURE 6  LAND USE-SOUTHWEST LINCOLN
                                           COUNTY-WALDPORT TO YACHATS
                                             (FROM: LINCOLN COUNTY, LAND USE PLAN, 1970)
                                                  SCALE IN MILES
                                                                     NORTH
                                   49

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and the Tillicum Campgrounds for vacation  use.   These federal
and state parks and recreation areas offer beach access and
wilderness areas for many users each year  and  demand for these
facilities is expected to increase during  the  coming years.

     A golf course is also  located in  the  district which serves
the seasonal and vacation population of  the  area and receives
its heaviest usage during the months of  May  through September.


     Highways and roadways.  U.S. Highway  101  is the major
arterial which links the town Yachats  in the south to Waldport
in the north.  Currently, Highway 101  receives its heaviest
usage between May and August.  Most other  roadways are not
surfaced and not maintained by any governmental authority;
consequently, their conditions range from  fair to poor.


     Commercial.  Tourism is the largest category of commercial
activity in the southwest Lincoln County district.  A number
of motels and cottages located along Highway 101 provide easy
access to the sandy beaches along the  coast.

     A number of small grocery stores  and  gift shops, located
along the coast highway, capture the bulk  of their business
from the seasonal tourist traffic.  Also located within the
district are a few small greenhouse and  bedding plant businesses
which serve the local as well as the tourist population.


     Airport.  The Wakonda Beach Air Strip is  located south of
Waldport between U.S. 101 and the western  boundary of the
Siuslaw National Forest.  Currently, the facility serves
resident private aircraft and a number of  vacation aircraft.
During the last few years, the airport has received increased
usage by seasonal residents and tourists.


    E/i uca t iona I _f a c i I i Li e s .  School-age  children residirxu in
tr.hr- Sanitary '".' is trier attenr schools in  Yachats  (r.r-.'z elenentsry
school with a 197C. enrollment of 63),  Walriport (one high school,
O"0^ junior hicjh school and one- elementary  school;  1975 enroll. --
noir.  it the thr ••.;.•;• schools totc»lad 067),  and  Newport: (one high
school , one junior hir-h school and throe elementary schools;
l'V7". enrollment at 7*13  five totaled 1,A63).  The future enroll-
,~^i-.<: r-,f tv.fi crjbools is orp^ctod to decline,  but. not as sharply
' ^ \, ( ' Jo •.; L: a < i o r ,  pe r i . co rn . ) .
     Other uses.  In conjunction with  the  operation of Siuslaw
National Forest, a Federal Job Corps center,  maintained within
the study area at Big Creek,  accommodates  150 students on a
year-round basis.

                            50

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Land Use Planning


     Land use planning in the southwest Lincoln County Sanitary
District is undertaken by the county level planning authority.
The local planning authorities in the State of Oregon are
established by the 1973 Land Use Act.  By the provisions of
this act, all local city or county planning jurisdictions are
required to develop and maintain comprehensive land use plans
which conform with adopted statewide planning goals.


     State authority.  The 1973 Land Use Act established the
Oregon Land Conservation and Development Commission (LCDC).
The commission consists of seven members appointed by the
Governor and subject to approval by the legislature.  Each
commissioner is appointed to a four-year term of office but
may be removed for cause by directive of the Governor.  No
member is allowed to serve on the commission for more than two
full terms (SB 100, 1973, ORS, Ch. 197.5).

     Following its creation in 1973, LCDC began the task of
formulating a series of comprehensive statewide planning goals
to be used in coordinating local planning efforts throughout
Oregon.  After conducting a series of public hearings and
reviewing existing state land use planning goals, a series of
14 goals with accompanying guidelines for compliance were
adopted by the commission on January 1, 1975.  All local
planning authorities were then directed to produce comprehen-
sive land use plans and to submit them to LCDC by January 1,
1976, for commission review.  By law, local planning authori-
ties who fail to meet the required deadline can have their
planning responsibilities carried out for them, at local expense,
by the LCDC planning staff.  Those local authorities unable
to meet LCDC's deadline may be allowed extensions, provided
that evidence of satisfactory progress in completing their
comprehensive plans is provided.  By January 1, 1976,  only five
planning jurisdictions in the State of Oregon had submitted
complete comprehensive plans to LCDC for their review.  Lincoln
County was not among them.

     The extent to which LCDC will be effective in centralizing
and directing land use in Oregon is a subject which has
received wide discussion in recent months.  Many argue that the
powers intended for LCDC are merely to insure a coordinated
statewide planning effort through adherence to its adopted
goals.  But a second authority of LCDC's is to grant planning
and siting permits to individuals or public agencies for land
use activities of statewide significance.  Activities  which may
be of statewide significance are defined in the 1973 Land Use
                             51

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Act as follows:  1) the planning and siting of public transpor-
tation facilities; 2) the planning and siting of public sewerage
systems, water supply systems and solid waste disposal sites and
facilities; and 3) the planning and siting of public schools
(Oregon statutes related to comprehensive land use planning,
ORS, Chapter 197.4).

     It would appear that this permit authority broadens the
powers of LCDC considerably beyond the coordinating level.
By controlling the planning and siting of public services,
such as sewerage systems, LCDC in effect could become the
authority in determining community growth policy.  This
authority could have significant effect on the SWL County
Sanitary District.


     Local planning authority.  A planning commission consist-
ing of nine members from various geographic locations in
Lincoln County is appointed by the County Board of Commissioners,
each to serve a four-year term.  The Planning Commission has
authority to recommend adoption of plans and zoning ordinances
in the county, while the County Board of Commissioners has the
sole responsibility to adopt comprehensive land use plans and
zoning ordinances for its jurisdiction.  A County Planning
Director is designated by the commission to oversee the opera-
tions of the Planning Department and serve as the chief admini-
strative arm of the County Planning Commission.

     A series of land use plans have been formulated for the
areas within Lincoln County including the Alsea Bay Planning
Area, which includes part of the Southwest Lincoln County
Sanitary District.  A comprehensive land use plan, as defined
by SB 100, for Lincoln County has yet to be completed and an
extension has been applied for to allow additional time to
comply with LCDC goals.  Zoning will have to conform to the
comprehensive land use plan and this may require zoning changes
for some properties.  The current schedule for completion of
the comprehensive plan is June 1980.
Future Land Use
     Residential.  The present acreage distribution among
various uses is not expected to alter appreciably in the future.
The bulk of acreage in the district is currently zoned for
residential-commercial use and very little property remains
which would be suitable for subdivision into building lots.
Currently, the district subdivisions are approximately 40%
built-out.
                              52

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      The land  which is  currently zoned  for residential use on
 the western side  of Highway  101  is  likely to receive pressure
 in the future  to  accommodate additional multi-family,  condomin-
 ium or motel usage.  This  land has  direct access  to  the highway
 routes and beach  frontage  and is generally more sought after
 for intense public  and  private usage  than parcels to the east
 of Highway 101.   Substantial changes, however, in land use and
 zone classification of  the area  are not expected  to  occur in
 the future.  An intensification  of  almost all present uses is
 to be expected, particularly the development of additional
 seasonal and retirement homes.


      Land ownership.  Land absorption in the study area has
 been taking place faster by  non-residents than by residents.
 This trend is  unlikely  to  continue  at its present rate.   Many
 people have  purchased a lot  or two  with  future expectations
 of constructing a vacation or retirement home on  the property
 and eventually becoming residents of  the area.  They tend to
 seek rural coastal  locations,  such  as the project area, which
 afford them  easy  beach  access and relatively low  density  use.
 Thus,  as  the area becomes  further developed, beach access will,
 to some degree, diminish and open space  will be used up.   The
 result will  be fewer non-resident purchases.  The economic base
 of the area  is not  adequate  to support large scale in-migration
 of a working population.


      Commercial.  Commercial  land use in  the study area is
 concentrated mainly along U.S. Highway 101 at the Waldport and
 Yachats ends of the district.  Although  some additional popula-
 tion-serving commercial  facilities may be expected to enter the
 area  as population growth proceeds,  expanded land use of this
 type will develop very  slowly.  The seasonal nature of the
market makes locations  closer to the population centers of
Newport and Waldport more attractive.


     Public.  The Parks and Recreation Division of the State of
Oregon is a  significant  land owner in the study area.  In
addition to  the three parks and waysides, encompassing about
 34 acres, currently being operated,  plans exist to develop
one additional  site — the San Marine property.   The development
of this facility will result in additional summer  time tourist
population and  could encourage the expansion of existing
commercial usage.
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III. ALTERNATIVE WASTEWATER
    TREATMENT FACILITIES
              ^ix \-\. '* -

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     III.  ALTERNATIVE WASTEWATER TREATMENT FACILITIES


                       Introduction
     Environmental Protection Agency rules and regulations for
the preparation of an EIS (CFR 40, part 6) require that alter-
natives to a proposed project be developed, described, and
objectively weighed when significant resource trade-offs are
involved.  In a project report prepared for SWCC by Robert E.
Meyer Engineers, Inc. (1974) a project was prepared for the
district which is included as an alternative among alternatives
treated in this chapter.  In this draft Environmental Impact
statement analyses are performed to allow an independent
comparison of the environmental and financial cost differences
among the available alternatives without nominating one alter-
native for implementation.  The reasons why a proposed alter-
native is selected as the best must be objectively determined
and stated in detail.

     At the present time, construction within the District is
somewhat restricted by the inability of many property owners
to obtain permits for utilization of septic tanks.  The denial
of permits has been based upon high groundwater conditions,
unsuitable soil characteristics, small lot sizes, steepness
of land slopes, or a combination of these factors.  In December
of 1972, the Oregon State Health Division conducted a survey
of existing septic tanks in Lincoln County, using both dye
and bacteriological testing.  This study also summarized the
denial of new permits in the District between 1970 and 1972.
Within the District, out of 18 septic tank systems tested for
contribution of raw sewage to the beach, eight were found in
violation, two were found to be performing satisfactorily, and
the remaining systems showed inconclusive results.  Based on
the Health Division survey, an evaluation of subdivision appli-
cations for septic tank permits between 1970 and 1972 showed
that out of 211 parcels applying for permits, 173, or 82%,
were denied permits.  The primary, if not sole, cause for these
denials was either a high groundwater level or unacceptable
soils.  Although detailed information is not available, some
applications by single lot property owners have also been denied
in the past years because of high groundwater and poor soils.

     Problems have also been experienced at Beachside State Park,
where septic tanks were pumped daily during part of the summer
of 1974.  After a threatened shutdown by DEQ, the park considered
installing a small package plant, with disposal of effluent
by spraying in a fenced area of the Siuslaw National Forest.
However, this project was never carried out because of objectives
from the sanitary district.  This interim system would have been
utilized only until sewer service could have been supplied by
the sanitary district.
                             55

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     Until this draft EIS, the alternatives for wastewater
management in the Southwest Lincoln County Sanitary District
were described in "Sewerage Study, Southwest Lincoln County
Sanitary District, Lincoln County, Oregon", prepared by Robert
E. Meyer Engineers, Inc., and dated September 1974 (hereafter
referred to as the Sewerage Study).  Prior to this detailed
Sewerage Study, the principal planning efforts had centered
around the "Sewerage Facilities Development Plan" prepared as
a portion of the Comprehensive Water, Sewerage, and Solid Waste
Management Plan for Lincoln County, dated March 1, 1974.

     The conclusion of the September 1974 Sewerage Study was
that all sewage within the District should be conveyed to the
existing Yachats treatment facility, which would be expanded
accordingly.  To transport sewage to the Yachats plant, a
single interceptor would be constructed northward, terminating
at the Yaguina John Point area.  This interceptor would be over
seven and one-half miles in length and require twelve separate
pumping stations.  This Statement includes as alternative 4
the project recommended in the September 1974 report.


Constraints on Alternative Development


     In the development of project alternatives, there are
certain institutional constraints imposed upon facility selec-
tion and cost of implementation.  The principal constraints
influencing the development of alternatives within the Southwest
Lincoln County Sanitary District are:

     1.  PL 92-500 - Federal Water Pollution Control Act
         Amendments of 1972.

     2.  EPA Secondary Treatment Information, Federal Register,
         Vol. 38, No. 159, August 17, 1973.

     3.  EPA Cost-Effectiveness Analysis Guidelines, Federal
         Register, Vol. 39, No. 29, February 11, 1974.

     4.  Oregon State Department of Environmental Quality,
         Water Quality Standards.

     5.  Oregon State Department of Environmental Quality and
         EPA, National Pollutant Discharge Elimination System
          (NPDES) Permit.

     6.  Oregon Administrative Rules, Chapter 340, Division 7 -
         Subsurface and Alternative Sewage Disposal, Subdivision
         1 - Standards for Subsurface and Alternative Sewage
         and Nonwater Carried Waste Disposal.
                              56

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     Public Law  92-500, the Federal Water Pollution Control
Act Amendments of 1972, give EPA the responsibility for estab-
lishment of waste discharge criteria for all federally-funded
wastewater treatment facilities.  In addition, PL 92-500
provides three dates by which wastewater treatment facilities
must meet certain effluent quality criteria.  By July 1, 1977,
all municipal treatment facilities should be capable of pro-
ducing an effluent which meets EPA secondary treatment require-
ments.  By July  1, 1983, all municipal treatment facilities
should be providing treatment to a level referred to as "Best
Practicable Waste Treatment Technology"  (BPWTT).  By July 1,
1985, municipal  wastewater treatment facilities should have
reached a condition of zero discharge of pollutants.  Although
this latter requirement is generally undefined and the nature
of any future actions uncertain, the general definition of
pollutant should be considered as any material in a discharge
which adversely  affects the beneficial uses of receiving body
of water.

     The EPA "Secondary Treatment Information" defines effluent
quality requirements for achieving secondary treatment and thus
compliance with  PL 92-500.  The requirements for secondary
treatment stipulate concentration limits for effluent biologi-
cal oxygen demand, suspended solids, fecal coliform bacteria,
and pH.

     The EPA "Cost-Effectiveness Analysis Guidelines" provide a
uniform method for calculating cost of wastewater treatment
projects, and they have been used as a portion of 'the cost
evaluation in this EIS.  These guidelines delineate the planning
period to be utilized in alternative evaluation, the elements
of cost which must be included, the method of handling prices
for various components of the system, the interest rate which
must be utilized, the service life of various facilities,  and
salvage value to be utilized for the proposed works.  The
guidelines provide a uniform method for comparing the cost of
various alternatives for a given project, as well as the cost
of any given project in the State.   Therefore,  while the
monetary costs developed in the Cost-Effectiveness Guidelines
may not always represent the "true cost" of a project,  they do
approximate the  cost and present a uniform method for compari-
son of alternative projects.

     The Oregon  State Department of Environmental Quality
(DEQ)  has established minimum water quality requirements for
receiving waters in this portion of the Oregon Coast.   These
criteria are contained in Section 11—010 of OAR Chapter 334,
and they state,   in general, that the highest and best waste-
water treatment  should be provided and that the control of
waste discharge  shall in every case be the best practical
method.  In 1973, the DEQ completed a "Draft Development
Document for Water Quality Management for the Mid-Coast of Oregon",
                              57

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to comply with EPA requirements (PL 92-500, 303)  for performing
comprehensive basin planning for all river basins in the State.
This document summarized and discussed existing water quality
data, water quality standards, and nutrient problems, among
other subjects.  The document did not, however, discuss alter-
natives for wastewater management nor recommend a wastewater
management plan.  Because of this, the EPA rejected the docu-
ment, and the document is presently being revised by DEQ to
fully comply with EPA requirements.

     The Oregon State Department of Environmental Quality and
the EPA must review and certify all National Pollution -Elimina-
tion System  (NPDES) permits for wastewater discharge.  The
purpose of an NPDES permit is to establish specific effluent
and receiving water quality requirements which must be met by a
treatment plant.  In formulating alternatives, only those that
will meet the probable NPDES requirements are considered
feasible.  It should be noted that each wastewater discharger
must possess an NPDES permit prior to discharge, and each
permit is prepared to respond to the particular discharge
situation.

     The Oregon Administrative Rules, Chapter 340, Division 7
prescribe requirements for construction and operation/mainten-
ance of septic tank systems.  Any alternatives which do not
provide 100% sewering of the District would permit new develop-
ment in unsewered areas only in conformance with these state
requirements for septic tanks.


Regionalization


     The objective of a regionalized  system is to provide the
most cost-effective method for collection, treatment, and
disposal of  wastewater.  It should be understood that regional-
ization does not imply or require that only one treatment
facility be  utilized, or that an entire area must be sewered,
but rather that planning must be done for  an entire region
and not on a piece-meal basis.  The term  "cost-effectiveness"
is comprised of three very important  costs: monetary or dollar
costs, environmental costs, and social costs.  Within this
chapter, only monetary costs  are considered, since  subsequent
chapters describe  the environmental and social impacts of the
project alternatives.  Typically environmental and  social costs
are  not monetary but judgmental.  The cost-effective project
is that project which is judged to have the lowest  overall
monetary,  social and environmental cost.
                              58

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     Several advantages can be attained by regionalization —
economy of scale in construction, operation and maintenance,
wider distribution of costs, one operating authority for treat-
ment facilities, treatment process efficiency control, easier
inclusion of new residential and commercial developments into
the system, and ability to plan for a basin or area as a whole.
The principal disadvantage of regionalization is that local
governments or agencies often must enter into joint powers
agreements that extend local responsibilities beyond indivi-
dual member control.
Flow and Waste Reduction Measures


     At the present time, water consumption within the South-
west Lincoln County Water District (which has the same boundary
as the Southwest Lincoln County Sanitary District) is about
150 gallons per capita per day (gpcd),  as compared to a national
average of about 200 gpcd.  In most areas of the United States,
roughly one-half of the water served to consumers is utilized
indoors, and ultimately results in production of about 90-100
gpcd of sewage.  In the study area, due to small amount of
outdoor lawn irrigation, a higher percentage of delivered water
is probably utilized indoors, and a sewage production of 110
gpcd (as utilized in the Sewerage Study) is considered a good
estimate for planning purposes.  In addition to sewage, community
sewerage systems also pick up additional water by infiltration/
inflow.  Infiltration is groundwater which seeps into pipes
due to poor joint construction, and inflow enters through man-
hole covers, ground drains and house roof drains connected to
the sewer.  Infiltration/inflow is usually highest during rainy
seasons and/or when the groundwater level is high.  In areas of
a perched water table infiltration problems can be burdensome.
The quantity of infiltration/inflow depends to a large extent
on the "tightness" of the collection system, and whether house
drains and other water drains are connected to the sanitary
sewer system.  The amount of infiltration/inflow will probably
be less than 10 gpcd initially, and will gradually increase
through the years, as coupling materials deteriorate, perhaps
ultimately reaching 30 gpcd.  Because infiltration and inflow
will not occur during the peak tourist season, which is the
period of projected peak flow, the Sewerage Study estimate of
30 gpcd for infiltration/inflow seems high and should be docu-
mented prior to EPA approval by comparing the proposed system
with existing systems having similar tourist peaking problems.
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     Reducing the quantity of sewage produced would be one
method of reducing the existing septic tank problems, the size
of major interceptors, and the construction and operation/
maintenance costs of sewage treatment facilities.  One method
of reducing wastewater production within sewage systems is the
installation of water meters on all water connections, and
making a portion of the monthly sewer service charge a function
of water usage; however, the installation of water meters is an
expensive action.  There should be no major problems with infiltra-
tion of groundwater into the collection system and interceptors,
as proper engineering design and materials selection coupled
with proper inspection during pipeline construction should
keep infiltration to a minimum.  No further flow reduction
measures are proposed.
               Wastewater Management Options


Possible Alternatives
     'During the preliminary analysis of wastewater treatment/
disposal alternatives, a number of wastewater facilities
alternatives were considered and some were not considered
viable for the District.  The alternatives that were screened
out, and the reasons for doing so, are discussed:


     1.  Land disposal of effluent.  A requirement of EPA's
Construction Grants Program is that land application of effluent
must be considered as a means of meeting the 1983 and 1985
goals of PL 92-500.  Possible means of land disposal include
percolation ponds and spray application to the land.  Percola-
tion ponds are not considered feasible because of the relative
impermeability of the soil and the localized high groundwater
conditions.  Spray application to the land surface was also
dropped from additional consideration because of the above
two reasons, as well as the extremely high cost of storing
effluent during the winter rainy months and/or the cost of
containing surface runoff within a spray disposal area.


     2.  Reuse of effluent for industry and/or agriculture.
Another requirement of the Construction Grants Program is that
reuse of the treated effluent must be considered in the formula-
tion and screening of alternatives.  Reuse of effluent, as a
combined means of effluent disposal and water resource
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 conservation, was  dropped because  there  is presently  no  signifi-
 cant  water  using agricultural  or industrial  operations within
 or  adjacent to  the District.   The  more than  ample  supplies of
 water within the District make effluent  reuse unnecessary and
 inappropriate at the present time.


      3.  Trickling filter and  aerated lagoon treatment.  These
 two methods of  wastewater treatment were dropped from further
 consideration either because of high construction  costs  or
 because they are not capable of consistently producing an
 effluent in  compliance with the probable NPDES requirements
 unless land  disposal of the final effluent is used, at which
 time  no NPDES requirements would be needed.  A more satisfactory
 effluent could be produced with this method  if filters were
 added for algae control; however, such additional treatment
 requirements would substantially increase the cost of facilities
 and treatment.
     4.  Joint district and city sewerage systems.  This
alternative would include combining the facilitie's and sewerage
needs of the City of Newport, Bay to Bay Sanitary District,
City of Waldport, Southwest Lincoln County Sanitary District
and the City of Yachats.  This alternative was not considered
further because of the difficulties of coordinating such an
alternative and hurdling the political obstacles while at the
same time meeting the sewerage needs of each of the cities and
districts.  Virtually all of the cities and districts have
sewage problems and needs specific to their own situations —
Newport, Waldport and Yachats represent high density development
clusters (cities) while the Bay to Bay and Southwest Lincoln
County Sanitary Districts are more lightly populated areas with
problems not paralleling those of the cities.
Treatment and Disposal Alternatives


     Each of the treatment and disposal alternatives selected
as feasible is described to acquaint the reader with their
general characteristics.  The two treatment alternatives being
considered are activated sludge treatment and individual septic
tank systems, or a combination of the two.  Three separate
disposal alternatives are considered feasible — discharge to
the ocean, discharge to Alsea Bay, or subsurface discharge to
the ground in the case of septic tanks.
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The Activated Sludge Process
     This treatment process uses bacteria to decompose the
organic matter in sewage.  During this process, the bacteria
convert sewage into more bacteria, i.e., multiply in number
and mass, and some mass must be removed from the process in a
form called sludge.  Following removal from the liquid portion
of the process, sludge is first treated by maintaining it for
a lengthy period without a food supply in order to reduce its
volume; it is then dewatered using a filter press and trans-
ported to disposal.  Disposal can be either through utilization
as a soil conditioner or by sanitary landfill.


Septic Tank Treatment


     This type of treatment consists of two components:   (1)
the septic tank and  (2) the leach field or other subsurface
land disposal method.  Both components must operate satisfac-
torily, or they will adversely affect the operation of each
other.  In the septic tank, solid materials settle and grease
and oil rise and the organic matter is then biologically broken
down by bacteria.  Following settling of solid matter and
biological breakdown, the liquid portion passes out of the
septic tank to a subsurface ground disposal system.  This
disposal system may consist of  (1) absorption trenches—
perforated drain tiles laid in a trench on top of about one
foot of gravel;  (2) seepage beds—wide trenches  (greater than
three  feet across) filled with gravel; and  (3) seepage pits—
large  circular holes that are drilled or dug into the ground,
often  to depths of 20 feet or greater.  This third method is
often  used where downward percolation is retarded or prevented
by layers of clay or cemented aggregate.  The purpose of the
disposal system is to spread treated sewage and to allow  it to
percolate downward into the soil.

     The reasons why septic tank treatment systems generally
fail are:

     1.  Inadequate maintenance of septic tank - The tank
         must  be pumped  every few years to remove inert
         material  and sludge that accumulates  at the bottom and
         sometimes top of the tank.  If this  is not done, much
         of the volume of the septic tank becomes useless, and
         sewage passes through  the septic tank untreated,
         carrying  solid material  into the ground disposal
         system.   These  solids  clog the soil,  and treated
         liquids can no  longer  percolate.
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     2.  Poor soil - Soils which contain large amounts of clay
         or are underlain by clay, will percolate water very
         slowly.  Such soils generally require large drainfields
         because of this slow percolating capability.

     3.  High groundwater - If the groundwater is less than
         several feet below a tile drainfield, the amount of
         unsaturated soil available for percolation is too
         small, and the rate of percolation is either slowed
         or stopped.

     Regardless of the cause of failure, partially treated sewage
begins to rise to the ground surface, and/or back up into the
home, necessitating pumping of the tank.  In both cases, a
public health hazard results.  Assuming adequate or nearly
adequate soils and proper system design and construction, the
most important factor in maintaining satisfactory performance
is routine pumping of accumulated sludge from the septic tank.


Treatment Plant Site Options


     Five locations were considered feasible for the location
of sewage treatment facilities.  Two of these sites are presently
used for sewage treatment.

     Site A - The City of Waldport treatment plant.  This
site, bordered by Alsea Highway, Lint Slough, and the Waldport
High School, is too small for the needed plant expansion, and
some land would have to be acquired from the adjacent high
school athletic grounds.  The new facilities would be con-
structed to the west of the existing facilities.  The athletic
fields of the school are between the proposed expansion and
the school, thus acting as somewhat of a buffer.  It may be that
future growth and sewering of the City of Waldport (i.e., east
of Waldport to Eckman Lake and Waldport Heights) will require a
relocation of the treatment facilities because of the lack of
developable land.

     Site B - Waconda Beach.  This plant would be located
on the inland side of the Highway, but a specific location
has not been selected.

     Site C - Big Creek.  The plant would be located on
the inland side of the Highway and the south side of the
creek, but a specific location has not been selected.

     Site D - San Marine.  The plant would be located on
the inland side of the Highway, but a specific location has not
been selected.
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     Site E - The City of Yachats treatment plant.  No new
land area will be required for the treatment processes, and the
new facilities will be located on the southwest portion of the
property.  The purchase of two lots on the northeast corner of
the site has been recommended by the engineer as a means of
keeping residential development from encroaching further on
the plant site.


Implementation Options — Financing and Organization


     A variety of facilities are required for project implemen-
tation:  treatment plant(s), Ocean or Bay outfalls, intercep-
tors, and local collection sewers.  The questions listed below
are as important to District residents as the technical and
environmental aspects of the project.

     1.  How will the facilities be paid for?

     2.  How will the cost of required facilities be allo-
         cated to residents within the District?

     3.  How will the facilities be operated?

     Various methods of accomplishing the above actions are
available, and they must be dealt with before a project becomes
operational.  Consequently, these subjects are discussed in the
following text and should be kept in mind while reviewing the
alternatives and their environmental and social impacts.

     First, how will the facilities be paid for?  This project,
as a part of EPA's Construction Grants Program, is eligible for
75% Federal funding of treatment facilities, pumping stations,
and interceptor pipelines.  The remaining 25% is the local share
and would have to be paid for by the District.  Collection
systems  are not eligible for Federal Grants and must be
financed 100% with local dollars.  It should also be noted that
land and right-of-way purchase is not an eligible cost and would
not be paid for with EPA grant funds.

     The 25% local share of treatment, interceptor, and pumping
facilities will probably be financed by general obligation
bonds  sold by the District, bonds which would be repaid by
money  collected from ad  valorem  (property) taxes, and  a monthly
sewer  service charge.  Oftentimes, however, a lower interest
rate can be obtained if  the bonds are repaid by only ad valorem
taxation.  General obligation bonds must be approved by voters
                             64

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within the District and are limited by Oregon State Statute
to 13 percent of the assessed valuation of the District.
Because state and federal agencies within the District are
exempt from property tax, they will pay an initial, one-time
cash payment to help offset facilities construction.

    The collection system nust be financed by District resi-
dents and governmental agencies holding land within the District,
The Engineer has recommended that the District form one Local
Improvement District (LID), encompassing the entire District,
be formed to finance the necessary collection system.  A 2/3
remonstrance of affected property owners is required before a
LID can be stopped.  The purpose of the LID is to collect
money from those who could benefit from the proposed facilities.
Assessments can be paid either in cash or through a process
known as Bancroft Bonding, which allows assessments to be re-
paid in semi-annual payments at an interest rate of seven
percent over periods of 10 and 20 years.

     Secondly, how will the cost of required facilities be
allocated?  As discussed, the 25% local share of treatment,
outfall, interceptor, and pumping facilities is allocated
according to the assessed valuation of in the District
properties.  Allocation of the cost of the collection system to
benefitting property will probably be accomplished using a
procedure referred to as the area/benefit method.  This method
assesses a percentage of the cost over the entire District
area that is sewered, and the remainder only to property that
receives a direct benefit from sewer facilities.  Normally,
all benefitted property is assessed equally whether developed
or undeveloped.  A draft financial Plan for the District has
proposed that 50% of the cost be allocated to area and 50%
to benefitted property.  Typically a connection fee and
inspection fee are also charged when a property owner connects
to the sewer.  The possible charges to individual property
owners is discussed further in a latter section of this report.

     Thirdly, how will the District's proposed facilities be
operated?  The basic question is whether the District should
have fulltime operation/maintenance personnel, or should they
have only one or two employees and issue contracts for other
work.  The District will probably begin with only a Superin-
tendent and a bookkeeper because the number of connections will
be relatively small and the system will be relatively new.
All services required, beyond the capabilities of these people,
would probably be done by contract.  This approach could only be
utilized if treatment is done at Waldport and/or Yachats.  If
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Waconda Beach, Big Creek, or San Marine are locations selected
for treatment, the District would likely have to hire two
operators for the treatment facilities.  The money to operate
and maintain the District will come primarily from a monthly
sewer service charge, which will probably be between three and
six dollars per month per connection.


Existing Wastewater Treatment Facilities


     The only existing treatment facility within the District
is located at the Camp Angell Job Corps Camp.  Constructed in
1966, it is operated by the U. S. Forest Service and serves
both Camp Angell and the Tillicum Beach campground.  Treatment
is provided by a 20,000 gallon per day package treatment plant,
followed by sand filtration and effluent discharge to Big Creek.
Present plans are to shut down this plant when the District's
proposed regional system becomes available.

     There are two treatment facilities outside of, but rela-
tively close to, the District boundaries.  The facilities are
owned by the City of Waldport and the City of Yachats.   The
Waldport plant was constructed in 1953 as a primary treatment
plant and converted in 1973 to a secondary treatment plant with
a rated capacity of 300,000 gallons per day (gpd).  This contact
stabilization plant, a modification of the activated sludge
process, discharges through an outfall in to Lint Slough.  One
full-time operator is required, although other City Maintenance
personnel occasionally work on the system.  The plant was
financed by local residents, with the help of an EPA grant.

     The City of Yachats plant, constructed in 1974, has a
treatment capacity of 150,000 gpd and uses a process called
extended aeration which is also modification of the activated
sludge process.  Discharge is to the ocean.  Sludge produced
is dried on sand beds and/or applied to farm land for disposal.
This method of sludge drying has not proven entirely satis-
factory due to the climate of this portion of the Oregon Coast.
One full-time operator is required.  The plant was financed
by local residents, with the help of an EPA construction grant.

     Because both the Waldport and Yachats plants were partially
financed by EPA, they have been designated as "regional plants"
by DEQ.  This designation means that logically related drainage
areas, or adjacent areas, should consider contributing their
flow to these plants.  There was not, however, any require-
ment imposed by EPA during the grant funding of these plants
that would require either the City of Yachats or Waldport to
accept sewage from the District.  If an agreement is reached
between the District and either City, EPA has regulations
which require that all costs arising from facility construction
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and operation/maintenance be distributed among participants
on a "fair and equitable basis".  Thus, if Southwest Lincoln
County Sanitary District sewage is contributed to either plant,
the District would be responsible for all capital costs incur-
red due to their contribution, and would be required to pay a
"fair and equitable" percentage of total plant operation.  The
EPA would approve the District's user charge system prior to
the final step 3 grant payment.
Proposed Facilities Common to All Treatment and Disposal
Alternatives
     With the exception of two alternatives, Alternatives 6 and
7, a sewage collection system is common to all alternatives.
Although there are some minor deviations between alternatives,
the pipe length and total collection system cost are almost
identical in Alternatives 1 to 5, and are roughly approximated
by the collection system described in the Sewerage Study,
pages IV-10 to IV-13.  The system would consist of about 89,750
feet of pipe and three small pumping stations, with an esti-
mated total 1974 cost of $2,001,000, which would probably
escalate to about $2,401,000 by early 1977, the earliest
anticipated date that construction could start.
Population Capacity of Project Facilities
     All treatment facility alternatives have essentially
equivalent capacities, which would handle flow from a popu-
lation substantially greater than the present population.
Within each alternative, various facilities are sized for
various capacities, the sizing depending principally on the
case of facility expansion.

     The following tabulation shows the year various project
facilities are proposed to be sized for.
     Facility
Capacity Provided for
Population to Year
     Collection system
     Interceptors
     Pumping stations --
       Wet well
       Pumps
     Sewage treatment plant
      2025
      2025

      2025
      1990
      2000
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     Based upon the year these facilities are planned to, the
population each could accommodate can be calculated.  For the
collection system, interceptor, and pumping stations (excluding
pumps)  a total population, including tourists, of 6,700 could
be accommodated.  The pumps in the pumping stations could
accommodate a total population of 3,900.  In the case of the
treatment facility, it is best to start with the proposed size,
as treatment facilities are normally constructed in only
certain sizes, and a certain amount of capacity increase is
often required as a result.  In Alternative 4, a capacity of
750,000 gallons has been recommended by the Sewerage Study.
The Sewerage Study also utilized a per capita sewage generation
rate of 140 gallons per capita per day  (gpcd), which consists
of 30 gpcd infiltration/inflow and 110 gpcd sewage generated
within the home.  This results in a proposed treatment capacity
capable of handling 5,357 people, a population which is expected
to be reached in approximately 2005.
        Description of Evaluated Regional Treatment
                 and Disposal Alternatives
Alternative 1 - Waconda Beach - San Marine Alternative
     In this alternative, all flow north of Big Creek would be
transported to a new treatment plant at Waconda Beach, and all
flow south of Big Creek would be transported to a new treat-
ment plant at San Marine.  The Waconda Beach treatment plant
would be a package activated sludge plant with a capacity of
350,000 gallons per day  (gpd) and the plant at San Marine would
be identical, with a 350,000 gpd capacity.  Both treatment
plants would dispose of effluent to the Ocean, using new ocean
outfalls, approximately 1000 feet long.  Each treatment plant
would require approximately one acre of land.

     Interceptor sewers would contribute flow to these treat-
ment plants as show on Figure 7.  The interceptors contributing
flow to the Waconda Beach plant would have a total length of
about 20,100 feet and would vary in diameter from four and 12
inches.  Five pumping stations would be required for the Waconda
Beach interceptor.  The interceptors which would transport
sewage to the San Marine plant would total about 16,000 feet
in length, varying in diameter from four to 12 inches.  Five
pumping stations would be required for the San Marine inter-
ceptor.

     The costs of implementing Alternative 1, assuming that
construction begins in early 1977, are estimated to be:
                              68

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                                   WALDPORT
              ALSEA BAY.
             WACONDA
             BEACH
        SAfTMSR
    YACHATS
          LEGEND
 ®  SBVAGE TREATMENT PLANT
 A  SEWAGE PUMPING STATION
 V  CHANGE IN POSITION INDICATES
     DIRECTION OF FLOW
—  INTERCEPTOR
	NEW OCEAN OUTFALL
                                                           I
                                                 SCALE IN MILES
                                                                           NOR!
FIGURE 7. ALTERNATIVE I-WACONDA BEACH-SAN MARINE ALTERNATIVE
                                     69

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     Capital Costs

          Collection System                   $ 2,401,000
          Interceptors and Pump Stations      $ 1,497,100
          Treatment Plant and Outfall         $ 2,538,000
          District Headquarters and Vehicles  j>	70,000

                                              $ 6,506,100

                          Local Share*        $ 3,479,800

     Annual Costs

          Capital Recovery of Local Share**    $   306,500/year
          Interceptor System                   $     8,000/year
          Treatment Plants                     $    30,800/year
          District Administration & Operation  $	33,OOP/year

                                               $   378,300/year


      * Local Share taken as 25% of interceptor, pump station,
        treatment plant, and outfall costs plus 100% of
        collection system and District Headquarters and
        vehicle cost.
     ** Interest rate — Bonds at 6-1/8% for 20 years.


Alternative 2 - Waldport-Yachats Alternative


     In this alternative, all flow north of Big Creek would be
transported to a treatment facility to be constructed on the
present site of the City of Waldport treatment plant.  All flow
south of Big Creek would be transported southwards to a new
treatment facility to be constructed on the present site of
the City of Yachats treatment plant.  The plant on the City of
Waldport site would be a package activated sludge plant with a
capacity of 350,000 gpd and the plant at the City of Yachats
site would be identical with a 350,000 gpd capacity.  Discharge
from the plant at Waldport would be through a new outfall into
the main channel of Alsea Bay.  This new outfall would be about
2,200 feet lonq, running through the city to the north and into
the main channel.  Discharge from the nev; plant at Yachats would
bo through the existing City of Yachats ocean outfall.  Addi-
tional land requirements would be minimal, a small amount of
]and would be required from the high school athletic field at
Waldport, and the additional facilities at Yachats could be
located on the existing plant: site.  The Sewerage Study has
recommended that two lots be purchased on the northeast corner
of the existing Yachats plant site to avoid further encroach-
ment- o£ residential dwellings.
                            70

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     Interceptor sewers would contribute flow to these treat-
ment plants as shown on Figure 8.  The interceptor contri-
buting flow to the Waldport Plant would have a total length of
about 26/600 feet and would vary between four and 12 inches in
diameter.  Six pumping stations would be required for the
Waldport interceptor.  The interceptor which would transport
sewage to the Yachats plant would total approximately 20,500
feet in length, vary in diameter from four to 12 inches.  Six
pumping stations would also be required for the Yachats inter-
captor .

     The costs of implementing Alternative 2, assuming that
construction begins in early 1977, are estimated to be:
     Capital Costs
          Collection System
          Interceptors and Pump Stations
          Treatment Plants and Outfalls
          District Headquarters and Vehicles
                          Local Share*
     Annual Costs
          Capital Recovery of Local Share**
          Intercerceptor System
          Treatment Plants
          District Administration & Operation
$ 2,401,000
$ 1,725,600
$ 1,482,000
$    70,000

$ 5,678,600

$ 3,272,900
$   288,200/year
$     8,000/year
$    30,800/year
$    33,OOP/year

$   360,000/year
      * Local Share taken as 25% of interceptor, pump station,
        treatment plant, and outfall costs plus 100% of
        collection system and District Headquarters and
        Vehicles costs.
     ** Interest rate — Bonds at 6-1/8% for 20 years.
Alternative 3 - Big Creek Alternative
     In this alternative, all flow north of Big Creek would be
transported southwards towards a new treatment plant to be
located at Big Creek, and all flow south of Big Creek would be
transported northwards to the same plant.  The plant at Big
Creek would be a package activated sludge plant with a capacity
                              71

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                                WALDPORT
           ALSEA
         WACONDA
         BEACH.
YACHATS
    SAN MARINE
          LEGEND
 ® SEWAGE TREATMENT PLANT
 A SEWAGE PUMPING STATION
 V CHANGE IN POSITION INDICATES
    DIRECTION OF FLOW
	 INTERCEPTOR
                                          SCALE IN MILES
                      NORTH
      FIGURE 8.  ALTERNATIVE 2-WALDPORT-YACHATS ALTERNATIVE
                              72

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of 750,000 gpd.  The treatment plant would dispose of effluent
to the ocean, using a new outfall approximately 1,000 feet
long.  Land area required for the treatment plant would be
approximately one acre.  The interceptor sewers required to
convey flow to the Big Creek treatment plant are shown on
Figure 9.  The interceptor running from the north District
boundary to the treatment plant would have a total length of
about 20,100 feet and would vary in diameter from four to 12
inches.  Five pumping stations would be required on the north
interceptor.  The south interceptor which would transport
sewage from the south District boundary to the new treatment
plant would have a length of about 16,000 feet and would vary
in diameter from four to 12 inches.  Five pumping stations
would also be required for the south interceptor.

     The costs of implementing Alternative 3, assuming that
construction begins in early 1977, are estimated to be:
     Capital Costs
          Collection System
          Interceptors and Pumping Stations
          Treatment Plants and Outfall
          District Headquarters and Vehicles
                          Local Share*
     Annual Costs
          Capital Recovery of Local Share**
          Interceptor System
          Treatment Plant
          District Administration & Operation
$ 2,401,000
$ 1,497,100
$ 1,550,000
$    70,000

$ 5,518,100

$ 3,232,800
$   284,700/year
$     8,000/year
$    24,000/year
$    33, OOP/year

$   349,700/year
      * Local Share taken as 25% of interceptor, pump stations,
        treatment plant, and outfall costs plus 100% of
        collection system and District Headquarters and
        Vehicle costs.
     ** Interest rate — Bonds at 6-1/8% for 20 years.
                             73

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                              WALDPCRT
         ALSEA
        WACONDA
        BEACH
YACHATS
    SAN MARINE
           LEGEND
     SEWAGE TREATMENT PLANT
 A  SEWAGE PUMPING STATION
 V  CHANGE IN POSITION INDICATES
     DIRECTION OF FLOW
	 INTERCEPTOR
	NEW OCEAN OUTFfcLL
                                         0	1
                                         SCALEINMILES
                                                                    NORTH
          RGURE 9.  ALTERNATIVE 3-BIG CREEK ALTERNATIVE
                              74

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Alternative 4 - Yachats Alternative

     In Alternative 4, all flow from the north District
boundary would be conveyed south to a new treatment plant to
be constructed on the existing City of Yachats treatment plant
site.  The plant would be a package activated sludge plant
with a capacity of 750,000 gpd.  Effluent disposal would be to
the ocean, using the existing City of Yachats outfall.
Although no new land is required, as previously discussed, any
expansion on the City of Yachats site should also consider
acquisition of the two lots at the northeast corner of the
existing site.

     The interceptor sewer which would contribute flow to the
treatment plant is shown on Figure 10.  This interceptor would
have a total length of about 41,050 feet and would vary in
diameter from four to 18 inches.  It would require a total of
12 pumping stations.

     The costs of implementing Alternative 4, assuming that
construction begins in early 1977, are estimated to be:
     Capital Costs
          Collection System
          Interceptor and Pump Stations
          Treatment Plant
          District Headquarters and Vehicles
                          Local Share*
     Annual Costs
          Capital Recovery of Local Share**
          Interceptor System
          Treatment Plant
          District Administration & Operation
$ 2,401,000
$ 1,765,200
$   918,000
$    70,000

$ 5,154,200

$ 3,141,800
$   276,700/year
$     8,000/year
$    24,000/year
$    33,OOP/year

$   341,700/year
      * Local Share taken as 25% of interceptor, pump stations,
        and treatment plant, plus 100% of collection system
        and District Headquarters and Vehicle costs.
     ** Interest rate — Bonds at 6-1/8% for 20 years.
                             75

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                               WALDPORT
          ALSEA BAY.
         WACONDA
         BEACH
YACHATS
    SAN MARINE
          LEGEND
 Q SEWAGE TREATMENT PLANT
 A SEWAGE PUMPING STATION
 V CHANGE IN POSITION INDICATES
    DIRECTION OF FLOW
	INTERCEPTOR
                                           SCALE IN MILES
                      NORTH
          FIGURE 10. ALTERNATIVE 4-YACHATS ALTERNATIVE
                                76

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Alternative 5 - Waldport Alternative

     In Alternative 5, all flow from the south portion of the
District would be transported northward to a new treatment
facility to be constructed on the present site of the City of
Waldport treatment plant.  The new treatment plant would be a
package activated sludge plant with a capacity of 750,000 gpd.
Discharge would be through a new outfall approximately 2,200
feet long, into the main channel of Alsea Bay.

     The interceptor sewer and locations of the pumping stations
which would be required are shown on Figure 11.  The inter-
ceptor sewer would have a total length of 42,600 feet and
would vary in diameter from six inches to 15 inches.  For the
entire interceptor, a total of 12 pumping stations would be
required, to locations as shown on Figure

     The costs of implementing Alternative 5, assuming that
construction begins in early 1977, are estimated to be:
     Capital Costs
          Collection System
          Interceptors and Pump Stations
          Treatment Plant and Outfall
          District Headquarters and Vehicles
                          Local Share*
     Annual Costs
          Capital Recovery of Local Share**
          Interceptor System
          Treatment Plant
          District Administration & Operation
$ 2,401,000
$ 1,793,400
$ 1,026,000
$    70,000

$ 5,290,400

$ 3,175,900
$   279,700/year
$     8,000/year
$    24,000/year
$    33,OOP/year

$   344,700/year
      *  Local share taken as 25%  of  interceptor,  pump stations,
        treatment plant and outfall,  plus 100%  of collection
        system and District Headquarters and Vehicle costs.
     **  Interest rate — Bonds  at 6-1/8% for 20 years.
                             77

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                               WALDPORT
          ALSEA BAY.
        WACONDA
        BEACH
YACHATS
    SAN MARINE
           LEGEND

 Q  SEWAGE TREATMENT PLANT

 A  SEWAGE PUMPING STATION

 V  CHANGE IN POSITION INDICATES
     DIRECTION OF FLOW

	 INTERCEPTOR
                                                    I
                                          SCALE IN MILES
                      NORTH
        FIGURE II. ALTERNATIVE 5-WALDPORTALTERNATIVE
                              78

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Alternative 6 - No Action Alternative
     In this alternative, no action would be taken to change
the present county controlled program for using septic tanks
for wastewater treatment and disposal.  No treatment plants,
sewers, interceptors, or pumping stations would be construc-
ted within the Southwest Lincoln County Sanitary District.

     The general condition of sewage treatment and disposal
using septic tanks was described in Chapter II (ENVIRONMENTAL
SETTING).  As discussed, numerous applications for permits to
utilize septic tanks have been denied, amounting to a denial
of 23 percent out of 293 applications.  It is understood that
almost all those existing systems found to be in violation of
county requirements have been modified and upgraded, either
by the addition of new leach lines, by the expansion of septic
tank capacity, or by a combination of the two (Dobey, pers.
comm.).

     The ability to modify and upgrade existing septic tank
systems, as well as to construct a new system in some situations,
is the principal reason that the No Action Alternative must be
considered.  Many existing systems were constructed prior to
the adoption of existing Oregon state standards for subsurface
sewage disposal, resulting in some cases in installation of
systems with inadequate leach line and/or septic tank capacity.
Thus, many systems failed as they grew older and their capa-
city decreased at the same time that the quantity of sewage
increased due to a greater domestic use of water.  Although a
potential public health hazard can exist when septic tank
systems fail and sewage rises to the surface of the ground,
the situation can often be eliminated by repositioning or
expanding the leach line length and/or expanding septic tank
capacity.   This has been adequately demonstrated by the up-
grading of existing systems that have failed in the past.

     The principal impediments to the use of septic tanks have
been inadequate lot size, too steep a lot slope,  too high a
groundwater table, impervious soil, or a combination of these
conditions.  The adequacy of any lot greater than 7,500 square
feet must be determined on a case-by-case basis.   However, in
cases where permits were denied, approval may have been
obtained if the lot size was larger, a condition which could
in many cases be solved during the subdivision of acreages.
The compilation of two or more lots into one of a size permit-
ting the use of a septic tank is possible.  While these actions
represent an economic impact, they could allow the continued
utilization of septic tanks within the District.   It should be
recognized, however, that some properties would still be denied
septic tank permits, even if adjacent lots were purchased or
property were subdivided into larger lots.
                             79

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     Another factor which should be considered is the presently
used percolation test which is designed to test the lot for
the use of horizontal leach line fields and not vertical
seepage pits.  While there are a number of restrictions on the
utilization of seepage pits, and they are discouraged by the
County Health Department and usually disallowed by the State,
they nonetheless should be considered for subsurface disposal
if County and State regulatory conditions can be met.  In areas
where there are impervious layers interspersed among aquifers
and where there is no present or foreseeable use of the
regional groundwater for domestic supply, septic tank disposal
using vertical seepage pits should be given consideration.
Any evaluation of the continued or expanded use of septic tanks,
as previously described, requires considerable investigation of
each parcel of land to determine the cost impacts on individual
landowners.

     In summary, based upon the above discussion, relating to
both existing systems and proposed new systems, the No Action
Alternative is described, and one may conclude that some
existing systems can be upgraded to avoid public health
problems, and adequate new systems can probably be built on
many of the larger lots.  Quantification of the situation
would require an extensive evaluation of lots.  Thus, while
the No Action Alternative may have direct adverse economic
impacts on some lot owners, it would allow continued growth
within the District.
Alternative 7 - District Maintenance of Septic Tanks


     In Alternative 7, no sewers, interceptors, or pumping
stations would be constructed.  The District would purchase a
septic tank pumping truck and be responsible to maintain all
septic tanks in satisfactory operating condition.  To accomplish
this, the District would periodically inspect all septic
tanks within the District, and as required, pump the tanks and
convey the pumpage to aerobic digestion facilities to be con-
structed at the existing City of Yachats treatment plant.
The new treatment facilities would consist of aerobic digestion
facilities and sludge dewatering facilities.  The liquid portion
from aerobic digestion of the sludge would be pumped to the
City of Yachats plant for additional treatment.  The digested
sludge would be dewatered and hauled to a sanitary landfill.

     This alternative is considered less satisfactory than
sewering of the District.  The basic problem with the alterna-
tive lies not with the maintenance of existing septic tanks,
but primarily with the maintenance of tanks which could be
constructed in areas presently prohibited for septic tank use
                              80

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by the County Health Department.  In those areas which are
presently denied septic tank permits, it has normally been
found that a combination of high groundwater and poor soil
conditions have led to the rejection.  In essence, this condi-
tion indicates that operational problems will not be with the
septic tank design or with poor maintenance of the septic tank,
but rather lie with effluent disposal (percolation).  Tanks
under such conditions would be operated as storage vaults.  It
should be noted that Alternative 7 only solves a septic tank
maintenance problem, not present a solution for effluent
disposal problems.  Alternative 7, to some extent, represents
the cost that could be borne by local residents for maintenance
of their septic tanks.  The alternative in this context can be
compared to the other alternatives,  and therefrom District
residents can achieve an estimate for how much their present
sewerage is costing as compared to a complete sewer system.
     Capital Costs
          Collection System
          Interceptors & Pump Stations
          Treatment Facilities
          District Headquarters and Vehicles
                          Local Share*
     Annual Costs
          Capital Recovery of Local Share**
          Interceptor System
          Treatment Facilities
          District Administration & Operation
$   0.00
$   0.00
$ 220,000
$  90,000

$ 310,000

$ 145,000
$  12,800/year
$    0.00/year
$  15,000/year
$  53,OOP/year

$  60,800/year
      * 25% of treatment facility plus 100% of District
        Headquarters and Vehicle cost.
     ** Interest rate — Bonds at 6-1/8% for 20 years.
Sewage Sludge Handling and Disposal Options
     In all of the alternatives described except no action,
sewage sludge from the treatment processes or septic tank
maintenance must be disposed of.  The existing Waldport and
                              81

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Yachats sewage plants have aerobic digesters and sludge drying
beds to dewater the sludge prior to disposal at a land site.
The drying bed method of sludge dewatering has not been particu-
larly effective in Lincoln County because of the inherent high
humidity, rainfall and cool temperatures of the coastal region
(Peer, pers. comm.).

     A number of disposal options are possible for the various
project alternatives.

     • Direct land disposal of sewage sludge.  This option
       would involve disposing of a large volume of sludge
       directly onto a land area.  Such a disposal method
       would require a large amount of land having proper
       topographic, soils and water quality aspects.  The
       sludge is usually plowed under when dried.  Land
       disposal would only be suitable for Alternatives 1
       through 5.  The wastes from Alternative 7 (septic
       tank maintenance) would be partially digested and
       unsuitable for direct land disposal.  Dewatering
       sludge can be easily applied to farmlands and plowed
       under periodically.  This method is now used at the
       Yachats treatment plant; however, there is no established
       disposal site.

     • Incineration.  Sludge incineration is a means of
       reducing the volume of sewage sludge to an ash or
       small volume of sludge.  The residue must ultimately
       be disposed of in a landfill or onto farmland.  There
       are several methods of incineration — multiple hearth,
       flash-drying and fluidized bed.  With adequate dewater-
       ing  (to approximately 30 percent solids) the process
       can be self-sustaining, without the need for supple-
       mental fuel except for warmup and heat control  (Metcalf
       and Eddy, Inc., 1972).  Vlhen using raw sludge in a
       multiple hearth or fluidized bed system, the heat
       necessary for incineration can be obtained from com-
       bustion of volatile matter in the sludge.

     • Sludge dewatering and drying.

       1) Drying beds.  This dewatering method is presently
          utilized at Waldport and Yachats treatment facilities.
          The dried sludge is transported to a farmland dis-
          posal site and spread on the surface.  As mentioned
          earlier, this method of drying has proved unsatis-
          factory in the past.

       2) Vacuum fi11ration.  With this method the  sludge must
          be conditioned before filtering.  A dewatered sludge
          cake is produced which must be hauled to  a sanitary
                              82

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   landfill, disposed of on farmland or sold or given
   away.  The sludge yield is typically 4-5 pounds
   per square foot of filter per hour  (Metcalf and
   Eddy, Inc., 1972).

3) Centrifugation.  This dewatering method requires
   a significant amount of electricity and noise
   control.  A major problem is that the liquid
   residues are high in nonsettling suspended solids
   which could affect effluent quality.

4) Pressure filtration.  With this dewatering method,
   a chemically conditioned sludge is pumped between
   rectangular plates and 60-180 pounds per square
   inch of pressure applied.  The end product is a
   sludge cake with a moisture content from 55-70
   percent.  The sludge can then transported to a
   suitable disposal site.

Lagooning.  Raw sludge or digested sludge may be
deposited in lagoons where aerobic and anaerobic decom-
position takes place.  This method of disposal could be
satisfactorily used for Alternative 7  (septic tank
maintenance).  A major problem is the lack of adequate
land for a lagoon system.  Lincoln County is presently
faced with a problem of finding a suitable site for the
disposal of pumped septic tank wastes as the city treat-
ment facilities can no longer handle septic system
wastes (Dobey, pers. comm.).

The quality of septic tank pumpage is such that it
cannot be disposed of on farmland without further
aerobic or anaerobic decomposition.  The sludge may,
however, be disposed of at a sanitary landfill site
so long as groundwater or surface water quality are
not adversely impacted.  Adequate sites for a sanitary
landfill in Lincoln County are scarce,  and the county
is in the process of implementing a regional resource
recovery program at Agate Beach which is designed to
significantly reduce the volume of solid waste requiring
landfill disposal.

Landfill disposal.   A sanitary landfill can be used for
the disposal of stabilized or unstabilized sludge.  The
future county landfill site will be located at Agate
Beach, approximately 27 miles from Yachats and 19 miles
from Waldport.  The costs of hauling such a distance
would dictate that the sludge be dewatered for volume
reduction.
                       83

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                Cost Comparison and Summary


     Three separate methods can be utilized to compare the
overall costs of the proposed alternatives:

     1.  Total cost to construct and operate over 20 years

     2.  Local cost to construct and operate over 20 years

     3.  Total cost using EPA Cost-Effectiveness Guidelines

     Table 15 summarizes the first two of these methods and
shows that Alternatives 3, 4, and 5 are the least costly of
the viable alternatives, from both local cost and total cost
standpoints, and all have essentially equal costs.  It should
be noted that in each of these three alternatives, only one
treatment facility would be constructed, whereas in Alternatives
1 and 2, there are two separate treatment facilities.

     The third method of comparing costs utilizes the EPA
Cost-Effectiveness Guidelines.  Briefly, these guidelines
establish a number of criteria, such as interest rate, planning
period, service life, and a number of other factors, which
allow EPA to compare all projects in Oregon and in the United
States on essentially a uniform cost basis.  In evaluating the
Southwest Lincoln County Sanitary District project according
to Guidelines, the following deviations from all previous cost
estimates should be noted:

     1.  EPA requires a 20-year period for comparison, rather
         than the 25 year period utilized in the Sewerage Study
         and the previously discussed cost estimates.  The
         EPA does not require that facilities actually be
         sized for a 20-year capacity, but leaves the decision
         of actual cost-effective sizing to the Regional
         Administrator.

     2.  EPA does not allow annual costs to be escalated with
         time.

     3.  EPA requires that salvage values at the end of 20
         years must be subtracted from the total cost.
                             84

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                                          Table 15


                  SOUTHWEST LINCOLN COUNTY SANITARY DISTRICT WASTEWATER PROJECT
                               20-YEAR COMPARISON OF LOCAL COSTS*
                                     (THOUSANDS OF DOLLARS)
COSTS ELIGIBLE FOR
75% FEDERAL GRANT **
PUMP STA. & TREATMENT
ALTERNATIVE INTERCEPTOR PLANT OUTFALL
1
00
" 2
3
4
5
6
7
1,497.1
1,725.6
1,497.1
1,765.2
1,793.4
.-
«.
1,638.0 900.0
1,374.0 108.0
1,100.0 450.0
918.0
918.0 108.0
-
'220.0
25% LOCAL
SHARE OF
GRANT
ELIGIBLE
COSTS
1,008.8
801.9
761.8
670.8
704.9
-
55.0
SEWAGE
COLLECTION
SYSTEM, DIST.
HEADQUARTERS
VEHICLES
2,471.0
2,471.0
2,471.0
2,471.0
2,471.0
-
90.0
LOCAL
OPERATION &
MAINTENANCE
COSTS FOR A
20-YR PERIOD*
815.1
815.1
737.9
737.9
737.9
-
510.9
TOTAL LOCAL
PRESENT WORTH
COST FOR A
** 20-YR PERIOD
4,294.9
4,088.0
3.910.7
3,879.7
3,913.8
-
655.9
TOTAL
PRESENT WORTH
COST FOR A
20-YR PERIOD
7,321.3
6,493.7
6,256.1
5,892.1
6,028.3

820.9
  *  Assuming construction  begins  in early 1977.

 **  75% of estimated  grant eligible costs will be funded by EPA.

***  Assumes interest  rate  of  6-1/8% and  inflation rate of 6-1/8%.  Includes operation of interceptor
     system, treatment plant,  and  district administration and operation.

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     Based upon these differences,  costs derived using  the
EPA Guidelines  are lower than the previous costs estimates for
this project.   Contained in Appendix D is an explanation of
facility sizing and an analysis of  the Southwest Lincoln County
Sanitary District using the EPA Guidelines.  Costs determined
using the EPA Guideline , are summarized in Table 16.  It should
be noted that these costs are only  for interceptor, treatment,
and outfall  facilities and do not include collection  system
costs or costs  of normal District operation.  As shown,  Alter-
natives 3, 4, and 5 again are the lowest cost alternatives.
                           Table  16

    SOUTHWEST LINCOLN COUNTY SANITARY DISTRICT WASTEWATER PROJECT
            EPA COST-EFFECTIVENESS COMPARISON OF COSTS*
                                      1977 PRESENT WORTH
        ALTERNATIVE                 OF CAPITAL & ANNUAL COSTS

             1                           $ 3,943,800

             2                           $ 3,208,100

             3                           $ 2,971,700

             4                           $ 2,654,900

             5                           $ 2,793,200

             6

             7                           $  705,800
       * Costs are for interceptors, pumping stations, treatment

         plants, and outfalls only.
                               86

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IV. ANALYSIS OF THE
   ENVIRONMENTAL IMPACTS
   OF THE ALTERNATIVES

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        IV.  ANALYSIS OF THE ENVIRONMENTAL IMPACTS
                    OF THE ALTERNATIVES
                       Introduction
     Central to the evaluation of the proposed viable alterna-
tives are the varying environmental impacts that result.  In
this chapter, both beneficial and adverse impacts are identi-
fied.  Primary attention is given to those factors most evi-
dently affected by the proposed actions.

     The Environmental Protection Agency guidelines for the
preparation of environmental impact statements (40 CFR, Part 6,
I 6.304(C) require that primary and secondary environmental
impacts, of short and long term duration, be evaluated.  This
draft EIS identifies the short-term, long-term direct and long-
term secondary impacts related to all project alternatives.


            Impacts Common to All Alternatives


     Many of the impacts of the wastewater treatment and
disposal project occur regardless of choice of any particular
alternative plan.  These common impacts come about as the result
of general construction and development activities and opera-
tion of the system.


Short-Term Impacts


     Short-term impacts are, as the name implies, a short and
definite period of impact, usually from the start of construc-
tion until completion of the project.  Such impacts can
usually be effectively mitigated.  Common short-term impacts
and mitigation measures are presented in Table 17.


Long-Term Direct Impacts


     Long-term direct impacts result from the construction,
location and/or operation of the facilities and generally
remain in force for the life of the project or longer.  The
time span may be 20 to over 50 years.  These impacts tend to
be on or near a facilities site or pipeline route or in the
area of wastewater disposal.  Some are generally common to all
alternatives in that the magnitude of variation in degree of
impact among alternatives is small.  These impacts do not
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                                                  Table 17

                       SHORT-TERM IMPACTS — SOUTHWEST LINCOLN COUNTY SANITARY DISTRICT
              The direct short-term impacts of this project are related to construction activities.
         These impacts are relatively minor in effect and magnitude and in most cases the adverse
         impact can be effectively mitigated.   The impacts considered,  their mitigation and our
         judgment of the relative positive or  negative merit are given  in the following matrix.
Short-Term Impacts
                                  Alternatives
                                 2
             Recommended Mitigation Measures
Temporary loss of
vegetation
               Replant after construction or allow for
               natural regrowth of shrubs and trees.
               Vegetation adjacent to pipelines should be
               flagged or fenced to keep vegetative
               destruction to a minimum.
Disruption of
wildlife
0   0
               Vegetation stripping for the pipelines should
               occur during the late summer or fall months
               when nesting birds are not present.
Construction-related
traffic
0   0
               Construction should occur, if possible,
               during the fall periods when traffic volume
               is lower.
Utility service
disruption
0   0
               Advance notice of anticipated utility dis-
               ruption should be given.
               If a lengthy period of disruption is neces-
               sary, utility bypasses should be provided.
Disruption of
through and local
traffic
00        • Barricades and flagmen should be posted as
               necessary to guide traffic through construc-
               tion zones, residents in area should be
               notified as to location, nature and duration
               of construction.
Dust
                                                 0    0
                                                                Keep  soil wetted  down in construction area.
Increased potential
soil erosion
00        • If possible,  construction should be done
               during the drier months of the year.
             • After construction, exposed soil areas should
               be reseeded using grasses native to the area.
Employment
                                                 00
                                                                None necessary.
Economic activity
                                     +   +   +   00
               None necessary.
Safety hazard
0   0
All open trenches should be covered or fenced
at the end of each work aay.
All construction equipment should be secured
aciainst unauthorized use.
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Short-Term Impacts
 Alternatives
2   3   3   5   6    T
                             Recommended  Mitigation Measures
Aerial pollutants
                0   0
All vehicles and equipment should be fitted
with appropriate pollution control devices
that are properly maintained.
Visual impact of
construction equipment
and construction site
                                                 0   0
                               Equipment should be stored in a designated
                               area.   All litter should be picked up.
                               Fence  or otherwise screen construction
                               maintenance area.
Spoil disposal
                0   0
                               Disposal  of  spoil  material from the pipeline
                               should  be coordinated with other ongoing
                               projects  needing fill material.
Stockpiling and storage
of spoil
                0    0
                               All  spoil material  not needed for backfilling
                               should  be removed from the pipeline route  or
                               spread  over  the  surface and seeded.
Increased noise
                                                 0   0
                              All  equipment  should  have mufflers,  properly
                              installed  and  maintained.
                              Construction activities should be limited  to
                              daylight hours.
Water quality (streams)
                00        • Construction  activities  in streamways  should
                              be  limited  to low  flow periods.
                            • Care  should be taken  not to discharge
                              petroleum or  other pollutants  into  stream.
Bay and ocean
water quality (outfall
construction)
                0    0
                              Care  should be taken not  to  discharge
                              petroleum products or  other  pollutants  into
                              the bay or ocean.
Temporary blockage of
streamways, increased
turbidity and distur-
bance of fish life.
                                                 0    0
                              Construction should occur during  low flow
                              periods  (late summer) and when anadromous fish
                              populations would be  least  affected.
Disruption of benthic
habitat
                00        • Locate outfall  so as  to  avoid  finfish,  shell-
                              fish areas.
                            • Avoid identifiable critical  spring and
                              summer use periods.
              +  Beneficial impact
            -  Adverse  impact
          0  No impact
                                                   89

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greatly influence the selection of a recommended plan from
among the alternatives even though the impact may be signfi-
cantly adverse.  For ease of understanding, the following
long-term impacts have been divided according to major areas
of concern — physical and biological resources, social features
and financial considerations.
Physical and Biological Resources


     The following list indicates those physical and biological
resource impacts to be discussed in the subsequent text.

     - Water resources - quality and quantity
     - Geologic and flood hazards
     - Air quality
     - Archeological and historical
     - Vegetation and terrestrial wildlife
     - Marine biota
     - Aesthetics
     - Energy


     Water resources - quality and quantity.


          o  The construction and hookup of a sewerage system
             will protect the groundwater from sewage con-
             tamination.

     Under present conditions, septic tank systems periodically
fail in southwest Lincoln County due to high groundwater levels,
impermeable soils, poor tank design, construction and mainte-
nance and inadequate lot size.  Under such conditions, ground-
water resources and sewage often come in contact, and may move
laterally along a cemented soil layer until surfacing in down-
slope areas.  Even though most of the residents of the sanitary
district are not dependent on groundwater as a potable source,
any contamination of the water table by sewage would be unaccept-
able and a violation of Oregon Revised Statutes  (ORS) (Sections
449.105 and 449.150).

     The construction and operation of a sewerage system would
generally alleviate potential groundwater pollution and prevent
its occurrence as the area is more densely populated in the
future.  This protection of the local groundwater resources
would represent a beneficial impact.
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          o  The elimination of sewage effluent on the
             beaches3 drainways and other ground surfaces
             and a reduction in potential public health
             hazards and nuisances.

     The presence of sewage wastewater was clearly evident at
locations on the beach and on some other ground surfaces of
southwest Lincoln County during 1968, 1972 and 1974 surveys.
Such conditions were in violation of ORS Sections 449.105 and
449.150 and Oregon Administrative Rules  (OAR) Section 41-015.

     The treatment facility and interceptor system (assuming
mandatory hookup as required by Southwest Lincoln County
Sanitary District ordinances) will greatly reduce and eventually
eliminate the discharge of sewage wastewater to beaches and
ground surfaces.  This action will reduce the likelihood of
public exposure to direct contact with raw sewage, and greatly
improve the aesthetic quality of use of the beaches and drain-
ages in southwest Lincoln County.


          o  Impact on stream biota and water quality.

     Since none of the alternatives would discharge wastewater
to streams in the project area, there will be no direct long-
term impact on stream biota or water quality.  A beneficial
impact will be realized from eliminating the present discharge
of 0.02 mgd of wastewater to Big Creek from the Camp Angell
sewage treatment facilities.

     The impacts on streams instead relate to secondary effects
to be brought about by increased development in the southwest
Lincoln County area.  The conversion of land from natural vege-
tative to impermeable surfaces will affect runoff patterns and
rates.  Human activity in the area will change the quality
characteristics of the receiving waters and thus affect stream
biota.  Residential or commercial development in poorly drained
or flood hazard areas often times results in the need or desire
for flood protection and control resulting in stream channeli-
zation projects.
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          o Operational reliability of pumping and treatment
            facilities in protection of the environment.

     The alternatives proposed for this project include between
10 and 12 pumping stations, depending upon the alternative
implemented.  Each pumping station would be equipped with a
backup pump-motor combination which would be utilized in the
event of pump-motor failure.  Each pump and motor combination
would be capable of pumping the entire flow through the pumping
station by itself.  There will be no standby electrical power
provided at the pumping stations, although each will be
equipped with an alarm system that will signal to an operator
either a mechanical or electrical malfunction.  In the event
of a sustained electrical outage, a portable electric generator(s)
would be utilized to provide power for pumping the raw sewage
through the various pumping stations.

     With the exception of the no-action alternative, all of
the six viable alternatives would have sufficient operational
reliability to meet anticipated waste water treatment and
disposal requirements.  The activated sludge process is a
well-proven process, one which has worked more than adequately
in this general area along the Coast and one which would pro-
vide sufficient operational reliability to protect the
environment.  No mitigation measures are proposed.


     Geologic and Flood Hazards.


          o  Damage to facilities and disruption of operations
             due to geologic and flood hazards.

     The waste treatment facilities, interceptors, pump
stations and treatment plant may be subject to disruption of
operations or physical damage from earthquakes, high ground-
water and occasional surface flooding.  Catastrophic coastal
erosion also represents a physical hazard in some locations.

     Although earthquakes have occurred in central and south-
west Lincoln County, the known fault lines transecting the
study area are concealed and reported to be inactive.  Based on
the history of seismic activity in the area, the probability
of a major earthquake  (Mercalli magnitude VII or larger) is
judged to be low.  However, if such an event did occur, the
rupture of lines and tanks could cause raw sewage to enter
drainageways and affect the surrounding environment.
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     The problems of high groundwater and flooding seem more
likely to occur than seismic events.  For example, high
groundwater and heavy rains have caused problems with infiltra-
tion in the Waldport sewerage system (Seaman, letter of Decem-
ber 28, 1972).   Such problems cause substantial increases in
the volume of sewage entering a treatment facility.

     Potential flood hazards exist at all streams within the
study area.  Unusually high stream discharge could cause
damage to sewage lines crossing creeks, particularly from such
things as streambed scour or heavy log flotsam.

     In order to reduce the potential for such damage, the
facilities would be designed to minimize catastrophic physical
damage.  Creek crossings should be designed so as to withstand
the consequences of at least 100 year storm flooding.  Since
virtually the entire interceptor system will be constructed
in areas subject to high groundwater, it will be necessary
for sewers to meet the strongest leakage tests following con-
struction to help ensure against groundwater infiltration.


     Air quality.


          o  Implications of air quality.

     Present air quality in Lincoln County is excellent.  None
of the project alternatives will create adverse effects on
regional air quality, although treatment facilities may at
times cause unpleasant odors of a localized nature.  Nuisance
odors can be produced from abnormal decomposition processes
associated with an imbalance in the treatment process or other
improper plant operation.  Odors resulting from treatment
imbalance sometimes occur with drastic changes in sewage quality
caused by such things as shockloading, high or low pH, toxic
substances or high temperature.  Because of the seasonal nature
of waste production in the area, shockloading is a potential
problem.  The sewage in the Southwest Lincoln County Sanitary
District is of domestic origin, and therefore unlikely to
have problems with pH or toxicity.

     According to Robert E. Meyer Engineers, Inc.  (1974) odors
at the existing Waldport and Yachats plants have not been a
significant problem.  The proper operation of equipment will
reduce the likelihood of offensive odors at any new  facilities.

     A normal condition in any treatment plant is the produc-
tion of a musty or earthy smell, characteristic of a well-
operating plant.  While this may not be offensive to most
people, there doubtless are some people who would consider this
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an odor-producing situation.   Thus, the proximity of the plant
to residential or commercial  developments will influence the
degree to which complaints may be received.  Expansion of
facilities at the City of Waldport site could represent an
adverse impact due to the proximity of commercial developments
and a school.  Also potentially adverse, would be the expansion
of the City of Yachats plant  due to the close proximity of
residences.  There should be  no overall impact of odor produc-
tion from treatment plants at Waconda Beach, Big Creek, or
San Marine because sufficient land could be purchased to pre-
vent the encroachment of residential development.

     The alternative of sewage sludge incineration could cause
the emission of air pollutants.  The primary end products of
sludge combusion are carbon dioxide, sulfur dioxide and ash.
The particulates are potentially the major emission problem
because of the violent upwards movement of combustion gases.
However, particulate control  can be achieved using wet
scrubbers.  Table 18 shows the likely emission factors from
sewage sludge incinerators.

     One means of reducing the likelihood of odors resulting
from sewage treatment, is to  utilize air injection in all
force mains conveying raw sewage to the treatment plant.
This air injection should guarantee that sewage influent will
not be in a septic condition  and therefore will not release
odors upon entering the treatment plant.

     A secondary impact on air quality, associated with pro-
viding sewerage facilities, will result from increased socio-
economic development in the sanitary district.  Added popula-
tion growth will increase highway vehicular emissions, off-
highway sources  (utility engine and construction equipment
emissions) and open burning of such things as wood and land-
scape refuse  (some of this growth will occur without a project
but at a slower rate).  While such development will increase
virtually all forms of pollutants  (particulates, sulfur oxides,
carbon monoxide, hydrocarbons and nitrogen oxides) the natural
ventilating capabilities of the coastal area are expected to
limit the degree of impact to an acceptable level.


     Archeological-historical.

          o Impact on federally or state recognized
            historic places.
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                          TABLE 18
      EMISSION FACTORS FOR SEWAGE SLUDGE INCINERATORS

Emissions9
Uncontrol led*5
Pollutant
Particulate
Sulfur dioxide
Carbon monoxide
Nitrogen oxides (as NO )
Hydrocarbons
Hydrogen chloride gas
Ib/ton
100
1
Neg
6
1.5
1.5
kg/MT
50
0.5
Neg
3
0.75
0.75
After scrubber
Ib/ton
3
0.8
Neg
5
1
0.3
kg/MT
1.5
0.4
Neg
2.5
0.5
0.15
a Unit weights in terms of dried sludge.



k Estimated from emission factors after scrubbers.





From:  U.S. Environmental Protection Agency, 1975.
                            95

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     Only two sites in Lincoln County are listed in the
National Register of Historic Places.  They are the old
Yaquina Bay light house and the Siletz Agency site.  Neither
will be impacted by any of the alternative sewage systems.

     One historic property of statewide value, the Oregon
Coast Highway, is within the study area.  Although much of
the construction would parallel the highway, the road would
not be destroyed nor would its historic integrity be harmed.

          o Impact on archeological resources.

     Only one archeological site is threatened by the construc-
tion of alternatives 1 through 5.  That site is located near
the mouth of Starr Creek.

     Starr Creek (site designation pending) (Figure 12).  This
is a midden site situated near Starr Creek at its confluence
with the Pacific Ocean.  A pumping station is proposed on
this site as well as a sewer line which would transect the site.
If the pumping station were located north of the gravel road
and beach access, it will not impact the site.  The sewer line
running south from this pumping station, unless relocated
approximately 100 feet east of its proposed location, will cut
through the site requiring salvage excavation.

     Although an initial field reconnaissance has been conduc-
ted, buried cultural materials may well be encountered during
the construction of facilities for alternatives 1 through 5.
In order to reduce the likelihood of cultural resource distur-
bance, the consulting archeologist should be sent copies of
final construction plans and the professional archeologist
should be "on call" in the event a buried site is encountered
during construction.  This will require an open line of communi-
cation between the archeologist and the principal contractor.
The end result will be the potential salvage of invaluable
information and the least possible delay in construction.


     Vegetation and terrestrial wildlife.


        o  The construction of sewage facilities will impact
           vegetation and attendant wildlife.

     Sewage facilities require land and the removal of some
native vegetation and wildlife.   This removal of habitat will
affect wildlife, both directly and indirectly.  Subsurface
dwelling and sedentary mammals,  amphibians and reptiles at
facilities locatons will be destroyed by construction activities.
Some birds, mammals and reptiles that periodically use facilities
sites might be excluded from this use.
                              96

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                                         ^^^^/CC^Uff^tf^rvifl'
                                            ^WP7^^*>^cU • «V^T]
Figure 12.
Location of  Starr Creek Archeological
  Site  (site  designation pending)
                         97

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     The proposed interceptor system will, for the most part,
parallel existing roadways — U. S. Highway 101 and the numerous
streets connecting to the main highway.

     The construction of the pipeline in other than roadways
will eliminate vegetation, wildlife habitat and some local
populations of animals.  Some ground-dwelling mammals such as
moles and shrews will be destroyed and populations of above-
ground fauna reduced from loss of habitat.  Birds, mammals,
reptiles and amphibians utilizing the habitat will be indirectly
affected.  Since most pipeline construction will be in roadways
this impact is expected to be intermittent.

     Under the no action alternative (no. 6), there will be no
impact on terrestrial vegetation and wildlife resources re-
sulting from project implementation.  The population growth
and home development secondary impacts would be of a lesser
magnitude with no action than those secondary impacts resulting
from alternatives 1 through 5 and 7.  Home development is
expected to continue with all alternatives however at a slower
rate with no action.  That continued development will result
in the loss of vegetation and many associated wildlife species.


          o  Rare, endangered and threatened species.

     Several vertebrate species deemed rare, endangered or
possibly threatened occur within the study area.  Pour of
the species — the northern bald eagle, Aleutian Canada goose,
peregrine falcon and western snowy plover — are seasonal
visitors to the study area and may occur in the study area at
least part of the year.  Neither the sewage treatment plant nor
the interceptor system will adversely affect those species.

     The northern spotted owl is a species of the higher ele-
vations and dense sitka spruce, western red cedar and western
hemlock forest.  The spotted owl may forage throughout the
study area and would be indirectly affected by the project.

     The greatest impact on rare or endangered wildlife is most
likely to result from the future residential development in
the sanitary district.  Residential and commercial structures
with their attendant roadways, service rights-of-way and other
facilities, will cause a greater loss of wildlife habitats
than will occur from the sewage treatment plant, pumps and
the interceptor system.  Beach pine-sitka spruce habitat that
                             98

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now supports spotted owls will be reduced as development increases,
The more substantial impact on rare and endangered wildlife will
be most likely to occur with full sewering of the sanitary
district as provided for in Alternatives 1 through 5.

     The impacts on rare and endangered species can be
mitigated by 1) constructing the interceptor system and sewage
treatment facilities on previously disturbed sites and 2)
regulating the density and distribution of residential and
commercial buildings within the District.  The implementation
of the latter mitigation measure would be dependent on Lincoln
Countv and LCDC decisions on land use.
     Marine biota.
          o  Impact on marine biota.

     Of the seven possible project alternatives, five would
discharge wastewater into an estuarine or marine receiving
water.
     Estuavine outfall.  Alternatives 2 and 5 would involve
the Waldport sewerage treatment plant and the discharge of
treated wastewater into Alsea Bay.  Under Alternative 2, 0.19
mgd of wastewater flow  (1975 population) would be added to the
existing 0.1 mgd discharge, while Alternative 5 would add
0.38 mgd to the 0.1 mgd discharge.  Presently the Waldport
sewerage treatment plant discharges into Lint Slough; however,
expansion of these facilities would necessitate an extension
of the outfall into the main Alsea Bay channel.  The present
dispersion and dilution qualities of Lint Slouah were determined
by DEQ to be insufficient to handle the additional treated waste-
water without causing degradation of the receiving water quality,

     To take advantage of the bay's natural ability to assimi-
late wastewater, the location of an outfall in the Alsea
estuary is important to the maintenance of estuarine biota
and water quality.  Improper placement of an outfall could
result in a number of adverse affects; for example, a reduction
of dissolved oxygen, the deaths of some biota, an accumulation
of heavy metals in the substrate or shellfish, increased
turbidity and biostimulation (leading to growth of algae).
The placement of an outfall in an area having a good exchange
of water and good dispersion greatly reduces the likelihood of
adverse effects such as those previously mentioned.  As a
general rule, the nearer the main channel and the closer to
the ocean one places the outfall the less the risk to water
                               99

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quality and biota.  Any outfall construction will require permit
authority from the U. S. Army Corps of Engineers, as will any
discharge of dredged or fill material into navigable waters.

     Under existing conditions, the Waldport treatment facility
cannot exceed a monthly average of 25 pounds per day BOD or a
daily maximum of 56 pounds.  The anticipated NPDES requirements
for Alternatives 2 and 5 discharge to Alsea Bay would vary
depending upon the season of the year.  Between June 1 and
October 31, a 20 milligram per liter biological oxygen demand
and 20 milligram per liter suspended solids limitation are
expected.  Between November 1 and May 31, it is expected that
these limits would be increased to 30 milligrams per liter
for each.

     With stringent NPDES  (National Pollutant Discharge
Elimination System) requirements for fecal coliform bacteria
(presently 70 MPN for 100 ml) there should not be a health
hazard through shellfish harvesting associated with sewage
discharge to the estuary.

     The malfunction of the sewerage facilities or accidental
discharge of untreated waste into Alsea Bay would constitute
a threat to estuarine biota and to public health.

     One additional adverse impact may result from the addi-
tion of phosphates to Alsea Bay.  Phosphates may create
localized algae growth problems.

     Any decision to discharge to Alsea Bay will necessitate
that a comprehensive dispersion study be conducted relating
to both physical and biological characteristics of the estuary.


     Ocean outfall.  Alternatives 1, 2, 3, and 4 would discharge
to the ocean with Alternatives 1 and 3 requiring outfalls off
open sandy beaches.  Alternatives 2 and 4 located at Yachats
would discharge through an existing outfall off the rocky
shore.  As with any wastewater discharge, the important con-
cerns for ocean wastewater discharge are the quality of the
effluent, the dispersion capacity of the receiving water and
the sensitivity of the receiving environment to wastewater
discharge.

     The location and length of a beach outfall are important
factors relative to the impact on water quality, the marine
biota and beach recreation.  The combination of tidal currents,
on-shore winds, water depth and volume of discharge usually
determine the location and the length of the outfall needed
to prevent adverse effects.
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     Alternative 1  (Waconda Beach/San Marine sewerage treatment
plants) would each support half of the district population, or
1,350 people in 1975 and 2,350 for the year 2000.  Discharge
volume at each plant for 1975 and 2000 populations, would be
0.19 mgd and 0.33 mgd respectively.  Alternative 3 (Big Creek
sewerage treatment plant) would require a wastewater flow of
0.38 mgd at 1975 population levels and 0.66 mgd for a year
2000 population.  The length of outfalls for Alternatives 1
and 3 would have to be sufficient to place the top of the out-
fall 10 feet below mean low lower tide level.  It is estimated
that this would require an outfall about 1000 feet in length.
It is felt that NPDES permits for those outfalls would stipulate
a 50-foot radius mixing zone as similar for the existing City
of Yachats outfall.

     Whatever effects sewage effluent would have on marine
biota would probably be restricted to very near the point of
discharge.  Combinations of factors such as wind and tides
could cause effluent to be driven on-shore, having localized
effects on intertidal biota such as shellfish (razor clams)
and other benthic fauna and on recreation uses of the beach.

     If the contamination of shellfish or the water is severe
enough, the beach areas can be closed due to a health hazard.
Such events seem unlikely because the amount of wastewater
discharged is relatively small, and the levels of treatment
required by the EPA and DEQ for the NPDES waste discharge
permit are designed to meet the water quality standards for
marine waters of Oregon  (OAR Chapter 334 [Section 11-010;
11-205; 11-070]).

     The discharge of wastewater off of rocky coastline, as
in Alternatives 2 and 4, is thought to have less potential
for adverse impact than would discharging off of a sandy beach
or into an estuary.  The combination of good dispersion
capacities, aeration, sufficient water depth and little
recreational use level ensure the lesser potential for adverse
impact.  However, a long term malfunction of sewage facili-
ties, thus discharge of untreated waste, onto a rocky shoreline
would likely have a greater impact on marine biota than would
a like discharge onto a sandy beach.  This is because there is
a greater diversity of marine species inhabiting a rocky shore.
The NPDES water discharge permit will establish required
effluent quality conditions to ensure compliance with state
water quality standards.
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     Aesthetics.
          o  Aesthetics -impact.

     The sewerage facilities, with the attendant pump stations
along the interceptor line, will cause changes in the aesthe-
tic condition of the area.  Alternatives 2, 4 and 5 would
require the expansion of existing treatment facilities at
Waldport and Yachats, while Alternatives 1 and 3 would require
new treatment plants, either at Waconda Beach, San Marine or
Big Creek.

     Construction of these treatment facilities would impact
the existing aesthetic quality of their locations in a variety
of ways.  The existing Yachats and Waldport sewage treatment
plants  (Alternatives 2, 4 and 5) are located adjacent to
residential development and to school property.  Treatment
facility expansion would probably include some of the school
land.  The location of both plants within the Cities of Wald-
port and Yachats could create a visual impact greater than
will new treatment plants at Waconda Beach, Big Creek or San
Marine.  At new locations a treatment plant site may be
selected which would be removed from the visual range of the
Coast Highway, and a buffer area could be purchased to prevent
the encroachment of residential development within close visual
range of the treatment facility.  A mitigation measure common
to all treatment facility locations would be the provision of
sufficient landscaping to provide a pleasing foreground to the
treatment facility.  In addition, any buildings which are con-
structed should be architecturally blended with the existing
architecture of the area.

     The aesthetic impact of no action  (Alternative 6) would
be the  continuation of periodic septic tank overflow into
surface drainages and onto beaches resulting in the aesthetic
unpleasantness associated with raw sewage in public and
private use areas.  Those problem areas are likely to be
throughout the sanitary district because high groundwater and
impermeable soils conditions are prevalent over a wide area.

     Pumping  stations would  be  necessary for  5 of the 7 alter-
natives.  All pumping  stations would be buried except for a
2-foot  high manhole  extending above the ground.

     A  major  secondary  impact on the aesthetic quality of the
area could be created  by  future residential and commercial
development of the district.  The magnitude of that  impact
would  be  dependent on  the extent to which  the area  is built
out, the  size and  location of residential  lots, the  quality  of
residential development and the measures taken by homeowners to
build  and maintain  structures that  fit the natural  coastal
setting.

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     In order to minimize the visual impact of any of the alter-
native facilities the treatment plants should be constructed
using local building materials as much as possible and screen-
ing the plant by landscaping or wood fencing.

     Pump stations should be constructed to conform with
topographic profiles where possible and any exposed portions
should be painted or landscaped to blend with the surrounding
natural setting.
     Energy.


          o Impact of consumptive use of energy.

     All alternatives will, in varying degrees, have an impact
upon energy consumption.  Alternatives 1 through 5 will require
the greatest energy requirements, while Alternative 6, no action,
will have no energy requirements unless mitigation measures such
as septic tank repair or installation of storage vaults are
enacted.  The degree to which the six alternatives consume
energy is presented in Table 19.  Of the five treatment facility
alternatives, the least energy-consuming is Alternative 3,
principally because this alternative pumps all raw sewage
towards the middle of the District, eliminating multiple
pumping of sewage as is required in other alternatives.  In
addition to the electrical energy requirements shown in this
table, Alternative 7 also has a requirement for diesel fuel for
operation of the septic tank pumper truck.  Estimates indicate
that 91,200 gallons of diesel fuel would be required for a
20-year period of operation.  There are no proposed mitigation
measures to lessen the requirement for energy.
Social Features


     The following list indicates those social impacts discussed
in the subsequent text.

     - Parks and natural areas
     - Land use
     - Land use planning
     - Traffic
     - Population characteristics
     - Sewage facility management
     - Cumulative effects
                            103

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                               TABLE  19
                          ENERGY REQUIREMENTS
                       KILOWATT-HOURS/20 YEARS
ALTERNATIVE
TREATMENT
6,876,000
6,876,000
3,986,000
3,986,000
3,986,000
PUMPING
1,410,000
2,116,000
1,788,000
3,606,000
4,268,000
TOTAL
8,286,000
8,992,000
5,774,000
7,592,000
8,254,000
    1
    2
    3
    4
    5
    6
    7*                1,600,000                0            1,600,000
* Alternative 7 also requires about 91,200  gallons of diesel fuel
  {4,006,878  Kwh)  for the  septic tank pumper  truck every  20  years,
                                 104

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     Parks and natural areas.
          o  Impact on parks and natural areas.

     Five state and federal parks and campgrounds are in the
Southwest Lincoln County Sanitary District.  The five areas
total 39 acres and contain 126 overnight campsites and numerous
day-use picnic areas.  Two areas — San Marine State Wayside
and Blodgett recreation site  (U. S. Forest Service) — are
undeveloped and have no facilities.  The remaining three areas
contain day use or overnight facilities with toilet buildings
and/or showers.  All three areas have sewage disposal problems.
Sewage from Tillicum Beach is presently pumped to the Camp
Angell Job Corps Center for disposal (Collett, pers. comm.).
Beachside State Park was closed during part of 1974; however,
was reopened when a daily septic tank pumping program was
undertaken.  Waste pumped from the campground was disposed of
at the Waldport sewage treatment plant.

     Alternatives 1 through 5 would eliminate the septic tank
failure problems now associated with the park and campground
areas.  Alternatives 6 and 7  (no project and septic tank
maintenance) would be unacceptable (no project) or expensive
(approximately $31,000 per camping season per park for Alter-
native 7) .

     Continued sewage disposal problems at the parks could
result in the Department of Environmental Quality ordering
closure of the facilities or prompting each park to install
separate sewage treatment plants.
     Land use.
          o  Impact on land use patterns.

     None of the alternatives can be expected to alter the
existing land use patterns of the district.  The intensity
of present uses, however, can be expected to vary according
to alternatives selected.  Generally, the no project alterna-
tive would result in a stagnation of property values and a
slowing of real estate sales.  Build-out levels below current
expectations could result with the no project alternative.
Difficulties may also be anticipated with overloading of exist-
ing on-site facilities during peak population months of the
year.
                            105

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     In terms of secondary impacts, it appears unlikely that
any change in current pattern of land use would result from
the project.  The present mix of public, private and commercial
use is likely to be maintained.  The no project alternative,
however, would cause a decrease in the rate of vacation and
retirement home construction as well as after property values
in areas where septic tanks are prohibited.


     Land use planning.


          o  Impact on land use planning.

     No changes are anticipated in current zoning or land use
plans as a result of any of the sewerage alternatives.  The no
project alternative, however, could result in substantial
inconsistencies between current zoning and actual use.  If
Department of Environmental Quality and county criteria for
soil and water table conditions suitable for septic tank use
are adhered to then substantial portions of the district zoned
residential, may in the absence of public sewerage facilities,
be unusable in that classification, however other land uses
would be allowed to occur.

     The planning and siting of sewerage facilities can be
deemed an activity of statewide significance, requiring a
planning and siting action on the part of LCDC to determine
whether or not the project conforms with statewide land use
planning goals and, in this case, coastal zone management
goals.  Also a determination of compliance with the local
comprehensive land use plan is required.  Since neither the
coastal zone management goals of the State of Oregon nor the
Comprehensive Plan for Lincoln County have been prepared
according to LCDC requirements, the intended state forum is not
operating for the review of the proposed sewerage plans and
their relationship to land use.  LCDC officials have stated
in a letter to the EPA that they, in conjunction with the
Oregon Department of Environmental Quality, will oversee the
planning and siting of this project and thereby insure that
no hook-ups will be allowed until a comprehensive plan
addressing land planning issue has been filed with LCDC.
Whether LCDC has the authority to impose such restrictions on
local residents is a matter which has yet to be resolved and,
no doubt, will require a legal interpretation of the applic-
able statutes before a resolution is reached.  The designation
of urban growth boundaries affecting the Southwest Lincoln
County Sanitary District have not been made; thus, a deter-
mination of the orderliness of urbanization within the area
cannot be made in conformance with the stateiwde adopted
planning goals.
                             106

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     Traffic.
          o  Impact from traffic.

     A secondary impact of sewerage facility development and
subsequent residential development, will be an increase in
traffic loads on all roads within the Southwest Lincoln area.
Projected emissions generated from local and tourist traffic
between Yachats and Yaquina Bay are presented in Table 20.

     Daily traffic loads on Highway 101 are often at the
capacity of the highway (about 8,000 ADT) during the summer
months of June through August (Schwab, pers. comm.).  At
the present time there are no plans to increase the highway
capacity of Highway 101, either by roadway improvement or
construction of a new highway.

     Given this information/ it is likely that future develop-
ment in Southwest Lincoln County will add to the existing
seasonal traffic congestion problem.  Local streets, which
are unimproved, will degrade further and some may become
impassable during the wet season.


     Population characteristics.


          o  Impact of permanent vs. transient use.

     In addition to the two state parks currently being operated
in the district, the State intends to develop for park use its
property at San Marine  (Jacobson, pers. comm.).  These develop-
ments would be only day use areas; they would add little to the
peak tourist population which has been steadily increasing in
recent years.

     Commercial facilities which cater primarily to the
tourist traffic will, of course, benefit from this expansion.
Tourists who partake of the natural amenities of the area
gain benefits from having sewered camping and picnicking
facilities available to them.

     An issue is whether a mechanism can be devised which
insures that the small group of permanent residents is not
adversely impacted by subsidizing the non-resident, non-tax-
paying transient population as well as commercial proprietors
who benefit from the increased tourist traffic.  If no method
is developed to insure that transient populations bear their
share of the sewerage cost; permanent residents will be trans-
ferring their income to transient, non-residents who are pri-
marily responsible for the peak capacity needs which influence
the capital cost.
                            107

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                                                   Table  20

                          PROJECTED AIR EMISSIONS (POUNDS PER DAY) FROM LOCAL  AND
                                  TOURIST TRAFFIC — YACHATS TO  YAQUINA BAY
                                             Hydrocarbons
Nitrogen
Particulates
Carbon
Monoxide
Year
1974
1975
S 1980
00
1990
2000
2010
2020
2025
Local
2,960
2,749
1,501
1,000
1,216
1,433
1,650
1,750
Tourist
1,452
1,348
692
433
505
570
650
698
Hydrocarbons
Exhaust
Local
290
275
157
108
131
155
178
189
Tourist
142
135
72
47
58
62
70
76
Crankcase &
Evaporation
Local
106
82
35
32
39
45
52
55
Tourist
52
40
16
14
16
21
21
22
Oxides
(NOx as N02)
Local
275
275
202
150
182
215
248
263
Tourist
135
135
93
65
76
87
98
105
Exhaust &
Tire Wear
Local
31
32
38
48
59
69
79
85
Tourist
15
16
17
21
25
28
31
34
Sulfur Oxides
(S02)
Local
11
11
13
17
20
24
28
29
Tourist
5
5
6
7
8
10
11
12
Source:  Data projected frcm Oregon State Highway Division Traffic Volumes tables; population projections;
        U. S. Environmental Protection Agency, 1975.

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         o  The population impact of a sewerage system.

     Recent experience suggests that approximately 23 percent
of current permit applications are being denied (Postle,
reported in Meyer, April 1975); the fact that some permits
are being refused is already reflected in the estimate of
20-25 units per year absorbed.  It is this estimate which is
used to approximate growth under the no project alternative.

     The implementation of a sewerage system would facilitate
future growth in the area.  A number of the permits denied in
the past might be resubmitted once wastewater problems of
particular sites are solved, and a spurt of development re-
flecting the backlog of denied permits may be experienced.
The magnitude of this "catch-up" component of future growth
cannot easily be estimated, as some of those to whom a permit
was denied may have found other acceptable properties in the
interim.

     In the period following the completion of a regional
sewerage facility, annual growth would probably take place
at a higher rate than the historical experience of 20-25
units.  If 23 units were built when 23 percent of permit
applications were rejected, then the total demand must have
been in the vicinity of 30 units per year.  Projecting this
absorption forward, 20-year growth would result in a 1995
population of 3,480 non-transient persons, as is presented in
Table 21.  Population projections of the facilities engineer
are presented in the same table for comparative purposes.

     Over time, the annual growth increment is likely to
decline from 30 units per year to some lower figure.  This
will happen because the remaining sites in any given year
will be less desirable than in earlier years, the higher
amenity  (coast access and water view) sites having been
absorbed first.  Also, the level of urbanization itself may
make the area less desirable from the viewpoint of a house-
hold in the market for a recreation home.  Even in the recent
past, there has been a decline in the numerical increase in
the number of second homes in Lincoln County.  That number
rose by 377 between 1950 and 1960, but by 347 between 1960
and 1970.  The realization of the higher growth figures pre-
sented in Table 21 probably depends on a shift in ownership
patterns toward permanent, year-round occupancy, which in turn
would require expansion of employment opportunities in the
region.
     Sewage facility management.


         o Personnel needed to operate the treatment facilities,


                            109

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                                    Table 21



                      COMPARISON OF POPULATION PROJECTIONS






                              Source of Projection
Year
1975
1985
1995
2025
Historical
Housing Unit
Absorption1
2,040
2,590
3,145
4,800
Future Absorption
Without
Sewer Constraint
(30 units/year)
2,040
2,760
3,480
5,640
Sewerage Study2
Total
Peak
2,700
3,500
4,300
6,700
Less
Transient
600
825
975
1,450
Non-
Transient
Total
2,024
2,675
3,325
5,250
1   See Table 6b.



2   See Meyer,  September 1974,  Table I.

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     All of the treatment alternatives proposed will require
a District staff comprised of a superintendent and a bookkeeper.
In addition to this, operators will be required for the treat-
ment plant.  Projections at this time indicate that Alterna-
tives 1 and 2 will require a total of 3-1/2 people; Alternatives
3, 4 and 5 will require 3 people, and Alternative 7 will
require 2-1/2 people.  Alternative 6 requires no personnel,
as this is a no-action alternative, and no facilities will be
constructed or maintained.
     Cumulative effects.
         o Cumulative impact of sewering two sanitary
           districts.

     Although the southwest Lincoln County and Bay to Bay
Sanitary Districts are considered as separate legal entities,
the effects of sewering each district will not be limited
just to the district boundaries, but instead will have an
impact on surrounding communities and on each other.

     The sewering of each district might provide a catalyst
for residential and commercial development from Yachats to
Newport.  This increased growth will likely have a particularly
profound impact on U. S. Highway 101, the only major transpor-
tation route along the coast.  Traffic congestion under pres-
ent conditions occurs in Waldport and Newport during the summer
months.  As with many cities and towns along the coast, the
Highway 101 runs directly through the centers of Newport and
Waldport, creating a mix of local and through traffic.  The
increased local population (that portion of the population
owning homes or businesses in the area) and expected increases
in tourist traffic, may create more traffic congestion through-
out both sanitary districts and in nearby cities.

     The increase in local population and home development
will cause an increased demand in utilities -- electricity,
water and natural gas and in community services in the area —
police and fire protection, street maintenance, and solid
waste collection.  It is unlikely that there will be a signifi-
cant increase in school enrollment because of the summer resi-
dent and retirement nature of the community.

     The sewering of the two sanitary districts will cause
changes in land use along a 21-mile strip of coast.  Land now
as open space and covered with natural vegetation and supporting
wildlife species, will be changed to a rural residential land
use.  Other areas of open lands may become commercial.
                            Ill

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Financial Impacts


     The following list indicates those financial impacts to
be discussed in the subsequent text.

     - Local economy
     - Cost to property owners
     - Property values


     Local economy.


          o  Impact on local economy.

     The project's impact will be felt as an injection to the
local economy for expenditures on new and additional services.
Some jobs may be created for the duration of the project.
Approximately 1,308 man-days of labor will be necessary to
complete the collection system and another 2,500 man-days
necessary for treatment facilities and pumping stations.
Approximately 20% of this labor may be supplied locally
resulting in a total of approximately $60,928.00 of employment
income.  All of the necessary materials for the project are
expected to be purchased outside the area.

     The ability to expand existing commercial tourist facili-
ties will have a salubrious effect on the local retail trade
and service industry.  Accelerated growth in residential
building and real estate sales is expected regardless of which
viable project alternative is selected.  These long-term
effects are difficult to quantify but the general pattern of
development appears to be one of continued growth in residential
housing with new motels and stores.


     Costs to property owners.


          o  Financial impact on local property owners for
             project implementation and operation.

     The total cost of implementing any alternative appears as a
number of separate buildings to the user.  The purpose of this
section is, to approximate the separate costs which could be
incurred and then to estimate example total costs for various
lot sizes.  Although no alternative is recommended by EPA to this
                             112

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time, Alternative 4 - Yachats Alternative - is utilized to
calculate these example user costs.  Alternative 4 was selected
because it represents one of the lowest cost alternatives and
has been represented locally as an acceptable alternative.

     Six different costs comprise the total implementation
cost, and these are discussed in the following sections.


     Initial posts.

     - Connection cost - this is a one-time payment by
       property owners for connection to the public sewerage
       system.   The District's Engineer has recommended an
       initial  connection cost of $100.00,  and a $500.00  cost
       for property connected more than 90  days after sewer
       availability.

     - Inspection cost - This is a one-time payment to cover
       the District's cost of inspecting new service connec-
       tions to their system.  The District Engineer has
       recommended an inspection cost of $15.00.

     - Lateral  to public sewer - The sewer  collection system
       to be constructed will include laterals to the indi-
       vidual property lines.  The property owner is respon-
       sible for extending the lateral from the property  line
       to his house connection.   The cost of this extension
       will vary with distance and lot topography,  but will
       probably fall between $100 and $500  per lot.   A "middle
       of the road" cost of $250 has been utilized in this
       analysis.   Based on sanitary district figures for  the
       number of existing dwellings having  water service,  it
       is likely that there will be approximately 850 initial
       sewer hookups.


     Annual costs.

     - Local Improvement District  (LID) assessment - This
       assessment is comprised of two costs:

          1.  An area cost of $0.0264 per square foot assessed
              against all property within 300 feet of a pro-
              posed sewer.

          2.  A benefit cost of $0.0395 per square foot assessed
              against the first 150 feet of property depth.
                            113

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       The assessment can be paid as an initial cash payment
       or can be financed at a rate of 7% over a 10 or 20-year
       period.  Payments are made semi-annually.

     - Sewer service charge - This is a monthly charge assessed
       against each connection to pay for sewage transportation,
       treatment,  disposal and a portion of the bond payment.
       The District's Engineer has recommended a charge of
       $5.00/month/connection.

     - Ad valorem taxes - These are property taxes that are
       calculated according to the assessed value of the various
       properties within the District.  The rate of taxation
       was estimated to be $1.66 per $1,000 of assessed
       valuation in 1980, $1.07 per $1,000 in 1990, and $0.82/
       $1,000 in year 2000.  The rate of taxation decreases
       with time principally because the District's assessed
       valuation is rising, and bond payments remain constant.

     These taxes are not a part of operation and maintenance
costs for the sewerage system, but rather represent property
taxes designed to pay off bonds for treatment facilities.

     Summarized in Table 22 are the initial and annual estimated
costs for four different lot sizes.  The assumptions made in
the development of this table were:

     1.  L.I.D. assessments were financed over a 20-year period

     2.  Assessed valuation of lots was:

                    60' x 100' lot     -      $15,000
                  75.O1 x 100' lot     -      $21,000
                   100' x 200' lot     -      $30,000
                   200' x 200' lot     -      $50,000

     The table shows that an initial cost of about $365 would
be required to hook up to the sewer and annual costs would
range from about $122 to $353 in 1980  (depending on lot size),
decreasing to about $109 to $311 per year  (depending on lot
size) in year 2000.

          o   Ability to pay.

     The  Southwest Lincoln area  is characterized by compara-
tively low incomes, higher than  average median  age and relative-
ly low residential property values.  These are  all indicators
of possible difficulties in supporting a major  public capital
investment.
                            114

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                                                     Table  22

                         PROJECTED COST TO PROPERTY OWNERS FOR IMPLEMENTATION OF ALTERNATIVE 4


LOT -l

SIZE
60x100
75x100
100x200
200x200
INITIAL COSTS i/

CONNECTION


100.00
100.00
100.00
100.00

INSPECTION


15.00
15.00
15.00
15.00
FROM HOUSE -f
TO
PUBLIC SEWER
LATERAL
250.00
250.00
250.00
250.00


TOTAL


365 -/
365
365
365
ANNUAL COSTS -
L.I.D. ASSES-
MENT - 20-YR
FINANCING
PERIOD - $/YR
36.99 &
46.27
104.99
209.89
SEWER
SERVICE
CHARGE
$/YR
60.00
60.00
60.00
60.00
d /
AD VALOREM TAXES - $/YR-'

1980 1990 2000
24.90 16.05 12.30
34.86 22.47 17.22
49.80 32.10 24.60
83.00 53.50 41.00
TOTAL
ANNUAL COST - $/YR

1980 1990 2000
121.89 113.04 109.29
141.13 128.74 123.49
214.79 197.09 189.59
352.89 323.99 310.89
]_/  1st dimension is street frontage

21  Varies with distance  between house  and property line as well as
    property topography.   Expected range  is $100 to $500.

3/  May be paid by initial cash payment,  which would be from top of
    table to bottom:  $395.00; $494.00; $1121.00; and $2241.00. May
    also be paid in semi-annual payments  over a 10-year period,
    which would be from top to bottom:  $55.59/year; $69.52/year;
    $157.75/year; and $315.36/year.The  20-year financing can also
    be paid in semi-annual payments.

4/  Tax rates were estimated to be:  1980-$!.66/1000; 1990-$!.077
    1000; and 2000-$0.82/1000.  Assessed  valuations used to
    compute taxes were:
            60x100' lot
            75x100' lot
            100x200' lot
            200x200' lot
$15,000
$21,000
$30,000
$50,000
                                           5/  This  total  initial  cost would increase by
                                               $400  for a  cost of  $765 for  connections
                                               made  after  the 90-day availability period.

                                           6/  Total first year costs include the total
                                               initial costs plus  total first year  annual
                                               costs.

                                           Source:   Modified from  financial plan prepared
                                                     by Robert Meyer Engineers.

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     The two major sources of income for tax-paying residents
of the area are retirement benefits and self-employment
earnings.  These sources tend to yield mean incomes well below
that of median family income levels in the county as a whole,
even though the county is below that of the State of Oregon.
Table 23 presents 1970 median family incomes for the United
States, Oregon and Lincoln County.

     This low income factor must be taken into consideration
when deciding the appropriate sewerage facility financial
scheme.

     It should also be recognized that the median age of the
population in southwest Lincoln County is well above that of
the county as a whole.  This area is recognized as a retire-
ment center.  Retired and inadequately employed persons typi-
cally live on incomes which do not keep pace with inflation
and, therefore, must be given adequate consideration lest they
be displaced from the community as a result of unusually
great utility and tax costs.


     Property values.


          o  The impact of a sewerage system on property values.

     Property values have tended to increase more slowly in
southwest Lincoln County than in the county and the State.
There may be a number of forces responsible for this lag,
among which is the absence of adequate sewerage facilities.
The provision of such facilities may cause property values
to increase at a faster rate which could result in higher
property taxes for residents.  The State of Oregon has enacted
legislation which provides for a homeowner's and renter's
property tax refund applicable on a graduated scale for
households earning $15,000 or less incomes per year which
could mitigate the impact of increased taxes on many of the
permanent residents.  While the provision of sewer facilities
may cause property values throughout the district to increase
somewhat, Alternatives 1 and 3 which call for the location of
treatment facilities at Waconda Beach, San Marine and Big
Creek locations, may tend to have adverse impacts on property
values immediately adjacent to the plants and outfalls.  Alter-
natives 2, 4, and 5 would locate the treatment facilities out-
side the district boundaries and hence, would have no
depressing effect on property values within the district.  In
the long term properties adjoining the plants in Yachats and
                             116

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  Waldport may decrease as the treatment plants enlarge,  age and
  reach their treatment capacities, Alternative 6,  the no project
  alternative, can be expected to result in diminished property
  values in residential zones which are deemed unsuitable for
  septic tank usage by the County.  Alternative 7,  which  calls
  for a program of septic tank maintenance, would be an improve-
  ment over the no project alternative, however,  would still
  result in property value losses to property owners who  are
  unable to obtain septic tank facilities.
                            TABLE 23
         Family Incomes in 1970 of Lincoln County
             as Compared to State and Nation	


                                   Median Family Income


United States                           $9,590

Oregon                                   9,489

Lincoln County                           7,909
                             117

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.'?•  •«•            '    •—7..-.--*

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               V.  UNAVOIDABLE ADVERSE IMPACTS


     The unavoidable adverse impacts of all alternatives are
presented in Table 24.  While most of the sewage facilities
projects have similar impacts, there is a marked difference
between impacts of alternatives 1 through 5 and 6 and 7.  The
following is a summary of the adverse impacts of each of the
alternatives.

     1  Waconda Beach/San Marine Alternative.  The impacts on
groundwater, beaches, geologic hazards,air quality, vegetation
and wildlife, marine biota, aesthetics, parks and land use
patterns will be minor.  Of major consequence are the impacts
on land use planning, traffic, energy consumption, property
owners and permanent vs. transient use.  This alternative
represents one of the more costly alternatives for local
property owners.

     2  Waldport/Yachats Alternative.  The impacts of this
alternative would be similar to those of the Waconda Beach/
San Marine alternative except that there would be a minor
impact to both estuarine and ocean biota because of the two
outfall locations.  There would be a major financial impact
on the local property owners and on the consumptive use of
energy.

     3  Big Creek Alternative.  The impacts on groundwater,
beaches, public health hazard, operational reliability,
geologic hazards, air quality, vegetation and wildlife, marine
biota, aesthetics, parks and land use patterns will be minor.
There is a potential for a moderate adverse impact on archeo-
logical resources, land use planning, traffic, permanent vs.
transient use and cost to property owners.  Energy consumption
would be less than alternatives 1 or 2.

     4  Yachats Alternative.  The adverse impacts associated
with this alternative would be the same as those associated
with alternative 3.

     5  Waldport Alternative.  The adverse impacts of this
alternative are basically the same as those of alternative 4
except that effluent discharge will be into the Alsea estuary
rather than as an ocean discharge.  This alternative would
also consume more energy than will alternative 4.
                             119

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                             Table  24
          ENVIRONMENTAL SUMMARY OF ADVERSE  IMPACTS  OF
              PROJECT  ALTERNATIVES FOR THE SOUTHWEST
                 LINCOLN COUNTY SANITARY DISTRICT

















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     6  No Project.  The major adverse impacts of this
alternative will be associated with groundwater degradation,
sewage on beaches and a greater potential for a public health
hazard.  The periodic outflow of sewage onto beaches, ditches
and cut banks will create a major adverse impact on aesthetic
quality.  Those state parks having sewage disposal problems
will continue to be adversely impacted.  The impact on land
use patterns will be moderately adverse.  No action will
allow existing discharge of sewage effluent to Big Creek
from Camp Angell.

     7  Septic Tank Maintenance Alternative.  Moderately
adverse impacts associated with this alternative will be con-
tinued degradation of groundwater and potential for sewage
on beaches and a potential health hazard.  Even with septic
tank maintenance, groundwater will continue to move laterally
along cemented soil layers and thence out of cutbanks and
beaches.  Groundwater will continue to outcrop regardless of
whether or not a septic tan}- and leachfield is used.  Because
of the inherent impermeable soils and high groundwater through-
out the study area, the operational reliability of a septic
tank maintenance program will be poor.  Some state parks will
continue to have periodic problems and landowners will likely
continue to have septic system denials.
                             121

-------

-------

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-------

-------
     VI.  LOCAL  SHORT-TERM USES  OF  THE  ENVIRONMENT  VS.
   MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY


     All alternative wastewater  treatment and disposal  systems
including no action involve the  acceptance of trade-offs among
beneficial and adverse project impacts.  Selection  of the most
"cost effective" alternative is  promulgated to result in the
greatest beneficial effects obtainable  at the least possible
environmental, social and monetary  costs.

     The principal beneficial effects of alternatives 1
through 5 are the alleviation of adverse environmental effects
related to the periodic malfunctioning  of septic systems
throughout the district, and the potential contamination of
groundwater resources.  These periodic  malfunctions, have in
the past, resulted in sewage on beaches, cut banks  and in
ditches and a maladorous and unsightly  aesthetic situation.

     Alternative 6 (no action) would allow for the  continuation
of such problems while alternative  7 (septic system maintenance)
would reduce the incidences of malfunctions but would not
alleviate the problem due to the inherent high groundwater and
impermeable soils present throughout the district.

     While alternatives 1 through 5 would remove the adverse
community level impacts associated with the use of  septic tanks,
new impacts,  probably seen as adverse by many local citizens
will be engendered.  These impacts relate to increased taxes
and service charges,  and the likelihood of a great  population
in the service area in the future.

     Throughout much of the Southwest Lincoln County Sanitary
District,  the present means of sewage disposal can be considered
a short-term use of the environment which has periodic adverse
effects on the water  resources and aesthetic quality of the area,
The proper treatment  of wastewater will become a long-term
benefit to the area by eliminating the  potential for groundwater
contamination and reducing the likelihood of violations of
state water quality regulations.
                            123

-------

-------
l^nTTRREVERSIBLE AND IRRETRIEVABLE
    COMMITMENTS OF RESOURCES
                                            i  ,

-------

-------
  VII.  IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES


     With all alternatives except no action, there will be
minor and major irreversible and irretrievable commitments of
renewable and non-renewable resources.  Significant commitments
of general irrecoverable resources, i.e., time, building
materials and energy, will be required during construction of
any of the treatment alternatives.

     After construction, operation of the treatment plant will
require irrecoverable resources such as time, chemicals, energy
and maintenance materials.

     The secondary effects of population growth will result in
the conversion of open, natural land to urban development,
reduction in air quality, increased use of water, electricity,
petroleum products, timber and food, and increased demand for
social services.  If growth occurs in a reasonably well con-
ceived manner, none of these effects are forecasted to be
significantly adverse.  However, much of the area is not plan-
ned to obtain the best foreseeable growth uses and unless this
situation is altered, adverse impacts are more likely to occur.
                             125

-------

-------
VIII. COMMENTS AND RESPONSES
      ON THE DRAFT EIS

-------

-------
          VIII.  COMMENTS AND RESPONSES TO THE DRAFT EIS
     This section contains letters of comments from individuals and
groups to the Southwest Lincoln County 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
during the 45-day review period, 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 EIS nor do they require a response from EPA,  they are not
reproduced in this document.  A listing, however, is included in table
form which separates letters into categories of support or opposition
to wastewater treatment facilities for the Southwest Lincoln County
Sanitary District.  We have attempted to point out areas with which
these letters were most concerned.  A brief summarization of the issues
raised most frequently has been included after this table.

     On June 2, 1976 at the Angel Civilian Conservation Center, EPA
held a public hearing on the Southwest Lincoln County Sanitary District
draft EIS.  The hearing was attended by approximately 170 people of
which 11 read testimony into the official record.  A question and
answer session, after the presentation of testimony, was also a part
of the hearing and is included in the hearing 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 and the areas in which they were most
concerned.  Letters and petitions received at the public hearing have
been included into the hearing record.  A summary of the testimony,
letters and petitions follows the public hearing table.  The Public
Hearing Record is available for public scrutiny at the  Newport City
Library, Newport, Oregon, the office of the Southwest Lincoln County
Sanitary District, EPA's Oregon Operation Office, Portland, Oregon
and EPA's Region X Office, Seattle, Washington.

     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.
                                127

-------






























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Comments Received On Draft
Environmental Impact Statement
Costs
Shellfish
Alternatives
Water Quality
Recreation
Fisheries
Wildlife
Construction Impacts
Secondary Impacts
Archeological
Historical Preservat
Population
Land Use Planning
Air Quality
Water Supply
Transportation
Soils
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Septic Systems
Federal Policy
Aesthetics
Reserve Capacity
Energy
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Health & Sanitation


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Comments Received On Draft
Environmental Impact Statement
Costs
Shellfish
Alternatives
Water Quality
Recreation
Fisheries
Wildlife
Construction Impacts
Secondary Impacts
Archeological
Historical Preservati:
Population
Land Use Planning
Air Quality
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Comments Received On Draft
Environmental Impact Statement
Costs
'Shellfish
Alternatives
Water Quality
Recreation
Fisheries
Wildlife
Construction Impacts
Secondary Impacts
Archeological
Historical Preservat
Population
Land Use Planning
Air Quality
Water Supply
Transportation
Soils
Effluent
Septic Systems
Federal Policy
Aesthetics
Reserve Capacity
Energy
Sludge Disposal
Health & Sanitation


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Comments Received On Draft
Environmental Impact Statement
Costs
Shellfish
Alternatives
Water Quality
Recreation
Fisheries
Wildlife
Construction Impacts
Secondary Impacts
Archeological
Historical Preserved
Population
Land Use Planning
Air Quality
Water Supply
Transportation
Soils
Effluent
Septic Systems
Federal Policy
Aesthetics
Reserve Capacity
Energy
Sludge Disposal
Health & Sanitation


-------
MEMORANDUM
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE

               PUBLIC HEALTH SLRVICE
           FOOD AND DRUG ADMINISTRATION
        Mr. Richard R.  Thiei
        Chief, Environmental  Impact Section,  M/S 443
                    DATE:  May 3,  1976
FROM   : Deputy Chief, Northeast Technical  Services Unit
SUBJECT: Review of EIS Drafts - Bay to Bay Sanitary District  and  Southwest  Lincoln
        County Sanitary District, Oregon
        We have reviewed both EIS drafts as requested  and  have the following
        general comments which would apply to both:

            1.  We favor any alternative which allows  the  treated  sewage  to dis-
                charge to ocean outfalls rather than any of  the small  bays involved.
                The added cost will  be worth it in the long  run.   We are  speaking
                in terms of public health protection with  regard to molluscan
                shellfish and the subsequent problems  with proper  classification
                of shellfish areas.   As an example,  the alternative No. 5—an
                outfall into the channel to AI sea Bay  is unacceptable since the
                Bay will have to be reclassified to contain  sufficient closed
                safety zone for the secondary treatment and  chlorination.

            2.  Plants with ocean outfalls "probably"  will not need the added
                expenses for shellfish protection required by EPA  Technical Bulletin
                EPA 430/9-74-010, July 1974, "Protection of  Shellfish Waters."
                The main concerns are adequate alarms, standby power, chlorine
                residual monitoring, possible holding  tanks, etc.   Plants discharging
                to bays having actual or potential for commercial  shell fishing  may
                not immediately need these items, but  provisions should be made in
                the designs for future additions. (24-hour holding ponds, for
                example, will need some additional land area.)

        Santo A. Furfari
        SAP/1 mm
                                RECEIVED
                                             132

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Response to Comments from the Department of
     Health, Education and Welfare


1.   The EIS has been revised to reflect the comment
     page 100.

2.   Comment noted.
                             133

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                          DEPARTMENT OF THE ARMY
                      PORTLAND DISTRICT. CORPS OF ENGINEERS
                                  P. O. BOX 2946
                              PORTLAND, OREGON 97208
           REPLY TO
           ATTENTION Of,
 NPPEN-ER                                                    -   19 May 19.76
 Mr. Richard R. Theil, P.E., Chief
 Environmental Impact Section, M/S 443
 U. S. Environmental Protection Agency, Region X
 1200 Sixth Avenue                                              ...y 9 Q 1976
 Seattle, Washington  98101                                     ™™
                                                                   EPA-EIS
 Dear Mr. Theil:

 We have completed review of the Draft Environmental Impact Statements for
 waste water treatment systems for the Southwest Lincoln County Sanitary
 District and the Bay to Bay Sanitary District, Lincoln County, Oregon.

S Each of the discussed alternatives appears to involve several stream
 crossings and several require the construction of ocean outfalls.  Struc-
 tures in navigable waters including the territorial seas of the United
 States require permits under Section 10 of the Rivers and Harbors Act
 of 1899.  The Corps of Engineers also has the responsibility to regulate
 discharge of dredged or fill material in coastal and inland waters and
 their adjacent wetlands under Section 404 of the Federal Water Pollution
 Control Act of 1972.  As of 1 July 1976, Section 404 permits are required
 for discharge of dredged or fill material in traditional navigable waters
 of the United States, their primary tributaries, all lakes of five acres
 or more, and adjacent wetlands.  After 1 July 1977, all streams with a
 flow of five cubic feet per second or more and their adjacent wetlands
 will also be included in this regulatory program.  The final environ-
 mental statements should reflect this requirement.  Additional informa-
 tion on the Corps of Engineers' permit program may be obtained by
 contacting Mr. Roy Brockschink, Chief, Regulatory Functions Branch, at
telephone 777-4441, extension 302.

 We have no additional comments relating to the Corps of Engineers func-
 tional area of responsibility, basically; flood control, navigation, and
 hydropower.  This opportunity to review and comment on the draft statements
 is appreciated.

                                       Sincerely yours,
                                  134
                                       L. J.
                                       Chief, Engineering  Division

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Response to Comments from the U.S. Army Corps of  Engineers
1.    The final EIS has been revised to reflect the comment.
                                134a

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                 United States Department of the Interior

                             OFFICE OF THE SECRETARY
                             PACIFIC NORTHWEST REGION
                          P.O. Box 3621, Portland, Oregon  97208
                                                            June  9,  1976
      ER 76/400
      Richard R. Thiel, P.E., Chief
      Environmental Impact Section, M/S 443
      U. S. Environmental Protection Agency,  Region X
      1200 Sixth Avenue
      Seattle, Washington  98101
 RECEIVED

JUN 1 4 1S76

  EPA-P'S
      Dear Mr. Thiel:

      We have reviewed the Draft Environmental  Statement  for  the  Southwest
      Lincoln County Sanitary District and offer the following  comments  for
      your consideration in preparing the Final  Statement.
      GENERAL COMMENTS

      The statement contains an adequate description  of geology  and  geologic
      hazards in the District.  However, minerals  and mineral  resource de-
      velopment are not discussed.  Nonmetallic construction  aggregate ma-
      terials in the form of sand and gravel, and  crushed  rock are occasionally
      produced from quarries in the area.

      Direct project impacts on fish and wildlife  will  be  minor  since major
      construction is limited to urbanized areas or along  roadways.  Secon-
      dary impacts of increased development and greater human use of nearby
      areas which would be encouraged by this project could have more sub-
      stantial effects on wildlife and its habitat.  However, the document
      recognizes these impacts satisfactorily.
      SPECIFIC COMMENTS
I       Page 22, fifth paragraph, second line:   The flammulated  owl,  Otus  flammeolus,
       is found principally in eastern Oregon  and would not be  expected to  occur
OV.UT/0^
       in the southwest Lincoln County study area.
                                         135

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8
Pages 55-84, Alternative Wastewater Treatment Facilities:   Throughout
this section, increased housing construction is treated as inevitable
since sewage treatment facilities would be built to meet year 2025
population predictions.  Alternative capacities for sewage treatment
(either greater or lesser) which could substantially affect population
growth and fish and wildlife should also be discussed.

Pages 88-89, Table 17. Short-Term Impacts:  Disruption  of  benthic habi-
tat caused by dredging or other activities associated with outfall con-
struction in bays or ocean should be included in this table.   Mitigative
measures could comprise location of outfall pipes and diffusers to avoid
important fish, shellfish, or wildlife use areas and timing of construc-
tion activities to avoid critical spring and summer use periods.

Page 91, last paragraph:  Increased angling harvest and harassment pres-
sure upon anadromous and resident fish in streams is a  secondary effect
which would accompany increased development.  This could be acknowledged
in the document.

Page 97, fourth paragraph:  We suggest that the Starr Creek archeological
site be evaluated for eligibility for the "National Register of Historic
Places" as required by Executive Order 11593, "Protection  and Enhance-
ment of the Cultural Environment."  If the site is eligible,  consulta-
tion with the Advisory Council on Historic Preservation should begin as
required by 36 CFR 800.  The mitigating measures listed for the Starr
Creek site should be incorporated into all the alternatives or be con-
sidered as another alternative.

As a point of clarification, there is one other historic site listed
in the Federal Register of March 2, 1976, in Lincoln County.   It is
the Siletz Agency site at Siletz but is not in the project zone.

Page A-5, Appendix A-3:  This listing should include English sole,
Parophrys vetulus, and surf smelt, Hypomesus pretiosus, as common bay
and estuary residents.

Thank you for the opportunity to review this statement.  Please let
us know if we can provide further assistance.
                                         Sincerely yours,
                                        Charles T. Hoyt
                                        Special Assistant to the Secretary
                                           136

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Responses to Comments from the U._ S. Department
     of the Interior
1.   Additions regarding mineral resources have been made on
     page 14.

2.   Correction made to text and tables — see page 19.

3.   The discussion of alternative capacities  (i.e., on a
     phased approach) will be dealt with at the time when
     project need is determined conclusively.  That will be
     after a complete septic system survey is done of the
     district.

4.   Additions were made to Table 17, page 88-89, as requested.

5.   The impact of increased angling pressure will be recognized,
     however, it is expected to be of a minor effect.

6.   The suggestion will be submitted to the Oregon State
     Historic Preservation Office for their review.

7.   Changes were made to the text to reflect this information.

8.   Additions were made to Appendix A-3 as requested.
                              137

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              United States Department of the Interior
                        FISH AND WILDLIFE SERVICE
                       Division of  Ecological  Services
Reference: ES
 Portland Field Office
 919 N. E. 19th Avenue
Portland, Oregon  97232
                                                    April 19, 1976
Mr. John Ives
% Jones & Stokes Associates
l\55 Capitol Mall
Sacramento, California 95814

Dear Mr. Ives:

Per your request, I have been able to  obtain  at  least a partial list of rare
plant species which may be present in  the  area you designated on the Oregon
Coast - between Newport and Yachats.   All  of  these species are known to occur
along the Oregon coast.  Some are more southerly, some more northerly, some
occur in both northern and southern areas.  Some are endemic to a particular
region (#'s 3,9,10), some have widely  disjunct sites of occurrence  (#'s 1,2,
6,7,8), some are rare or threatened within Oregon (//'s 4,5,11), and one is also
on the Smithsonian list of threatened  and  endangered plants of the United
States (#2).
                               T> 1 „.„ 4-  O— ~ — — --
1.  Anemone oregana var.  felix
2.  Arenaria paludicola
3.  Cirsium acanthodontum
4.  Empetrum nigrum
5.  Microseris bigellovii
6.  Plantago macrocarpa
          7.   Platanthera  unalascensis  ssp. maritima
               (Habenaria  greenii)
          8.   Romanzoffia  tracyi
          9.   Sidalcea malvaeflora  ssp. patula
         10.   Sisyrinchium californicum
         11.   Stellaria humifusa
References concerning this  information are:  "Provisional list of the rare,
threatened and endangered plants  of  Oregon," a summary of lists compiled by
Dr. Kenton Chambers,  Oregon State University Herbarium, for a forthcoming pub-
lication in the series "Rare and  Endangered Plants and Animals of Oregon," and
by Mrs. Jean Siddall  for "Research Natural Area Needs in the Pacific Northwest;'
and the Smithsonian Institution "Report on Endangered and Threatened Plant
Species of the United States," January 1975, also published in the July 1, 1975
Federal Register.

I hope this information will be helpful to you.  If you have any questions,
please feel free to contact me at (503) 234-3361, Ext. 4083.

                                     Sincerely yours, /,
                                                ^-^^
                                    Heidi Haid
                                    Wildlife Biologist
                                     138

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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE	

16th Floor, 1220 S.  W.  Third,  Portland,  Oregon 97204

                                                          June 10, 1976
Mr. Richard R. Thiel, P.E.,  Chief
Environmental Impact Section M/S 443
U.S. Environmental Protection Agency,  Region X
Seattle, Washington 98101
Dear Mr. Thiel:

We have reviewed the draft Environmental Impact  Statement  for  the
Southwest Lincoln County Sanitary District and have no  comments.

We appreciate the opportunity to review this statement.

Sincerely yours,

                                                         RECEIVED

                                                        JUN 1 5 1976
Guy to. Nutt
State Conservationist                                     HP/s-r""

cc:
Office of the Coordinator of Environmental Activities
Administrator, SCS, Washington, B.C.
Chairman, Council on Environmental Quality (5)
                                   139

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         |[| \        DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
    - * illlilll * >                           REGIONAL OFFICE
    \ Ulllllt ^                ARCADE PLAZA BUILDING, 1321 SECOND AVENUE
      '"'^a *<**                        SEATTLE, WASHINGTON 98101

                                       June 14, 1976
     REGION X                                                             IM REPLY REFER TO:

Office of Community                                                      -,QD   -MJC  317
Planning & Development
         Richard R. Thiel, P. E. , Chief                                oercix/cn
         Environmental Impact Section, M/S  443                        RECEIVED
         U. S. Environmental Protection Agency,  Region X              MIM 1 £ 1G~T~
         1200 Sixth Avenue                                            jUN * 0 i3ib
         Seattle, Washington 98101                                      p   ,..,,.

         Dear Mr. Thiel:

         Subject:  Draft EIS - Southwest Lincoln County Sanitary District Waste
                   Water Treatment Works EPA-1—OR-Lincoln-WWTS-76.

         We have reviewed the subject draft EIS  for areas of interest to HUD.
         The major action which may  significantly affect the quality of the human
         environment is to provide a wastewater  treatment and disposal program
         for the Southwest Lincoln County Sanitary District.  Seven alternatives
         are identified for providing the district with wastewater facilities.

         Proposed alternative actions 1-5 would have no apparent adverse en-
         vironmental impacts on HUD  projects.  On the contrary, a properly coor-
         dinated, soundly planned and implemented wastewater treatment and dis-
         posal program is a basic functional element of sound community and area-
         wide planning and development.

         Of concern to HUD is the clear need for effective intergovernmental
         coordination and timing of  proposed Sanitary District sewerage project (s)
         with the growth management  objectives of community planning, Lincoln County
         planning, the State LCDC's  coastal zone management goals, and other State
         agency goals.  The draft EIS outlines serious unresolved growth management
         issues.  The unresolved issues are correctly recognized as institutional
         problems awaiting further political and social actions.
         Sincer-e'ty, I
                  S/t
           bert
          ssistant Regional Administrator
                                              140

                                        AREA OFFICES
                             PORTLAND, OREGON . SEATTLE. WASHINGTON
                                        Insuring Offices
                            Anchorage, Alaska • Boise, Idaho • Spokane, Washington

-------
Response to Comments from the Department of
     Housing and Urban Development
1.   Please see comments from the Oregon State Lands
     Conservation and Development Commission.
                              141

-------
Advisory Council
On Historic Preservation
I 522 K Street N.W.
Washington. D.C. 20005
                                     May 24, 1976
 Mr.  Clifford V.  Smith, Jr.
 Regional Administrator
 Region X
 U.  S.  Environmental Protection Agency                      .,lf. 1   1-17-
 1200 Sixth Avenue                                         wbil -   ^'b
 Seattle, Washington   98101                                 COA  r...


 Dear Mr. Smith:

 This is in response to your request of April 20, 1976, for comments  on the
 draft environmental statement (DES) for the Southwest Lincoln County
 Sanitary District,  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 DES has
 demonstrated compliance with Section 106 of the National Historic
 Preservation Act of 1966 but that it is inadequate because it has
 not  demonstrated compliance with Section 1(3) of Executive Order 11593,
 "Protection and  Enhancement of the Cultural Environment" of May  13,  1971,
 as  implemented by the "Procedures for the Protection of Historic and
 Cultural Properties" (36 C.F.R.  Part 800).

 It  is  noted from review of the DES that an archeological site near the
 mouth  of Starr Creek will be destroyed by proposed construction  and  that
 the  Environmental Protection Agency (EPA) proposes to permit the salvage
 of  this cultural resource.  Archeological salvage is a destructive action
 which  substantially alters a site.  Therefore, before approving  the
 proposed undertaking, the EPA is required: (1) to determine if the
 archeological site  possesses the criteria for inclusion in the National
 Register of Historic Places in consultation with the Oregon State Historic
 Preservation Officer (Mr.  David G. Talbot, State Parks Superintendent,
 300  State  Highway Building, Salem, Oregon 97310); and, (2) to afford the
 Council an opportunity to comment in accordance with the "Procedures,"
 if  the  archeological site is determined by the Secretary of the  Interior to
 be eligible for  inclusion in the National Register.

 Further,  it is noted that EPA has determined the proposed undertaking will
 not  affect the Yaquina Bay Lighthouse, a property listed on the  National
                                      142
The Council is an independent unit of the Executive Branch of the federal Government charged by the Act of
October 15, 1966 to advise the President anil Congress in the field of Historic Preservation.

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Page 2
May 24, 1976
Mr. Clifford V. Smith, Jr.
Southwest Lincoln County Sanitary District
Register, and the Oregon Coast Highway, a property included in the State
wide Inventory of Historic Sites.  The final environmental statement
should contain documentation of the Oregon State Historic Preservation
Officer's concurrence with those determinations.

                                    Sincerely yours
                                    Louis S. Wall
                                    Assistant Director, Office
                                      of Review and Compliance
cc:  Mr. Sheldon Meyers, EPA
                                      143

-------
Response to Comments from the Advisory
     Council on Historic Preservation
1.   The request to evaluate the Starr Creek site for possible
     inclusion in the National Register of Historic Places
     will be submitted to the Oregon State Historic Preservation
     Office.

2.   Please see letter dated May 4, 1976 from Paul. B. Hartwig.
                             144

-------
    L.ES AuCOIN
  1 ST DISTRICT, OREGON


     COMMITTEES:
BANKING, CURRENCY AND
     HOUSING

MERCHANT MARINE AND
     FISHERIES
             Congress of tfje ®mteti
                           . ».C.  20515
                     April  28,  1976
                                                     WASHINGTON OFFICE,
                                                 329 CANNON HOUSE OFFICE BUILDING
                                                         __  „.-.-
                                                   WASHINGTON, D.C.  20515
                                                      (202) 225-0855
                                                     1220 S.W. THIRD
                                                       . o«».
                                                      (503) 221-2901
Mr. Richard R. Thiel, Chief
Environmental Impact Section,  M/S  443
Environmental Protection Agency, Region X
1200 Sixth Avenue
Seattle, Washington 98101

Dear Mr. Thiel:

I have received the draft  Environmental Impact Statement for
the wastewater treatment system proposed for the Southwest
Lincoln County Sanitary District,  and would like to raise a
concern I have about the alternative plans.

As noted in the statement, the district is characterized by
a concentration of retirement  age  residents who are largely
dependent on fixed-incomes,  such as Social Security, for
their livelihood.  And I want  to say here that I was dis-
appointed that this information about the district was not
developed more fully, especially in light of its importance
to the financing plan for  the  proposed alternatives.

To put this important characteristic into perspective, I
checked with the Social Security Administration about the
number of people in Lincoln  County as a whole who are re-
ceiving retirement benefits  and learned that as of December,
1974  (the latest available figures), 4700 persons were
drawing retirement checks  for  an average $190.00 a month.
Of course since 1974 there have been some increases in
Social Security benefits and many  people may also have
additional income from private pensions.  Still, it should
be remembered that the age and number of retired persons
are higher in the district than in the rest of the county,
and I think these figures  do help  us to see what the possi-
ble impact of a new sanitary system may be on the low-income
elderly—homeowner and renter  alike.

An initial hook-up fee of  $365.00  and an annual maintenance
cost of $121.89 for a 60 x 100 lot is a substantial burden
for someone who is only making two to three thousand dollars
a year.  Even for the renter,  any  increase in rent to cover
the owner's additional expenses places additional strain on
an already tight budget.
                                                       RECEIVED
                              145
       THIS STATIONERY PRINTED ON PAPER MADE WITH RECYCLED FIBERS

-------
Mr. Richard R. Thiel
April 28, 1976
Page 2
I would urge that each proposed alternative be carefully
weighed in light of its financial effect on this group and
that particular attention be given the method of financing
the local share of any system that is to be built.
                             Sincerely,
                             LES AuCOIN
                             Member of Congress
LA: me
                            146

-------
Response to Comments from Les AuCoin,
     U. S. House of Representatives
1.   The fact that such a large number of retired people
     live in Lincoln County and in the Southwest Lincoln
     Sanitary District was discussed on page 44 and again
     on pages 112-117.  The financing of any recommended
     project will be in light of the financial capability
     of the district's constituents.

2.   Comment noted and will be considered.

3.   Comment noted and will be considered.
                             147

-------
                                                                         Vt'
                              MAY 1 3 1576
         10000
                                              Ra:   Cay to Bay S.D.  and
                                                 v/S.W. Lincoln County S.D.
 f-'r.  EcV'ard long
 State  ,'iistorlc Preservation  Office
 Oregon State Highway  Division
 Highway Building
 Salem,  Oregon 97310

 Daar f'r. Long:

     As part of EPA's  preparation of  the  draft  environment Impact state-
 ments  for Day to Bay  Sanitary  District and  S.W.  Lincoln County Sanitary
 District, an archeological survey of the area  v,-as  authorized.   The re-
 port attached is prepared by Mr. David Braunsr,  Oregon  State University.
 Review of this re-port indicates that the criteria  of adverse affect
 (36  CFR ^00.9) applies  if portions of the sewerage system are  construc-
 ted  as  proposed.  !!cvjever, those portions of both  projects which the
 criteria of adverse affect apply could be nitigated if  certain measures
 are  taken.  Tho attached table lists the sites,  the inpact the proposed
 project \;ould h=ve on the site, and  the  mi gated  rcasure proposed by EPA
 to avoid the intact.   Your comments  on the  report  an'd attached tabla
 would  be appreciated.   The enclosed  sewer nap  will  help you locate the
 designated sewer lines  in Bay  to Bay Sanitary  District.

     In  order to implement the  two recommendations  on page 8 of tha
 report, FIPA could condition the appropriate Step 2 grants (preparation
 of construction drawings and specifications) to  the sanitary districts
 that would allow f'essrs. Richard Ross and David  Brauner to review and
 coTrnsnt on final plans  and specifications.  The  specification  could
 list a  professional archoolooist "on call"  to  work with the contractor
 during  construction in  the event a buried site is  encountered.

     If you have any specific questions,  please call  rr.e  at 221-3250.

                                  Sincerely yours,
cc:  OEQ
                                  William J. SoNolewski
                                  Project Officer
£Sobole\;skf/vlk 5/17/76
                               148

-------
Site
A? JL3J(_? -JLi
35LCN16"
   (Shell nldden
  site)
Huckleberry H111
   (burials)
Deer Creek
  (Village 4
  Shell Midden)
35LCN14
  (Village and
  Shell Midden)
Seal Rock Area
between 89.4 and
B10.1
  (artifacts,
  burials, midden}
_            _
Starr Creek
  (midden site)
Inpact the Proposed
Project Uould Have
on tha Site
Sewer line PA 2.9
may cut through un-
disturbed shell
mid.ien.
Sewer line B76.1
could disturb burial
(not confined) on
the point overlooking
Beaver Creek.

No Impact 1f sewer
line PB-8 as pro-
posed runs adjacent
to Highway 101 and
P.S. PS-3 1s situated
wall north of the
site.

Sewer line 89.5
(north-south) cuts
directly through the
east side of the
rain shell nldden

Area Is a high risk1
area for uncovering
artifacts, burials,
and midden.
Proposed pump station
and force main could
disturb midden site.
                                             Migatcd Measure to be   »•••
                                             Taken to Avoid tha Impact
Test excavation will be
done prior to construction
If undistrubed midden is
present, excavation will
be necessary preceding
construction.

Last 75 to 100 feet of
sc,;er will be constructed
with the presence of an
archeologist watching
for graves.

M/A
Relocate sewar 100 feet
to the east.  Excavation
for sewer line P8--9 will
not be 1n roadcut.
Test excavations will
be conducted by team of
archeologlsts prior to
construction.
Pump station will be
located north of gravel
road and beach access.
Sewer from pump station
will be relocated 100
feet east of the proposed
location.
                           149

-------
 PARKS  AND  RECPvEATIQN  BRANCH
 DEPARTMENT OF TRANSPORTATION
 525 TRADE STREET S.E.
•     SALEM, OREGON

June  1,  1976
97310
 Mr. William J. Sobolewski
 US Environmental Protection Agency
 1234 SW Morrison St.
 Portland,  Oregon   97205

 Dear Mr.  Sobolewski:

     This  letter is in response to your telephone call of  this
 date requesting our comment on the Southwest Lincoln Sanitary
 District  project.  As stated earlier in my May  17th letter on
 the Bay-to-Bay Sanitary District,  the survey by Professors
 Brauner and Ross was well executed.  In addition, the survey
 report covers well  the subject of  mitigation of impact.  We
 do feel that the project engineers should follow closely
 Professor  Brauner's suggestions for mitigation.  If this is
 done, our  office feels that the project's impact on cultural
 resources  would be  entirely acceptable.

     If our office  can be of further assistance, please  feel
 free to contact us  again.

                             Sincerely,
                          (S»jlt
                             Paul B.  Hartwig
                             Historical  Programs Coordinator
                             State Historic Preservation Office
PHrko
                          150

-------
                  OREGON  STATE
                  HIGHWAY DIVISION

                   525 TRADE STREET, SE
        SALEM, OREGON   97310
ROBERT W. STRAUB
    GOVERNOR

    F. B. KLABOE
   Administrator and
  State Highway Engineer
May 4, 1976
                  Mr. Jonathan H. Ives
                  Jones & Stokes Associates, Inc.
                  Suite 835 - 455 Capitol Mall
                  Sacramento, CA   95814

                  Dear Mr. Ives:

                       I have been given a copy of "The Archeological Recon-
                  naissance of the Proposed Newport to Waldport and Waldport
                  to Yachats Sewer Systems, Lincoln County, Oregon" by Prof.
                  David Brauner of Oregon State University.

                       Our office feels that Prof. Brauner has done an ex-
                  cellent job in identifying non-renewable cultural resources.
                  We also feel that mitigation procedures are well addressed
                  and should be given close attention.  Inasmuch as Prof.
                  Brauner consulted with Dr. Stephen Beckham on historical
                  resources in the area of this project, we are satisfied
                  with this aspect of the survey.  Dr. Beckham is a historian
                  well known for his work on the Oregon Coastal area.

                       The survey report by David Brauner fulfills the require
                  ment of a survey as outlined to you in Mr. Long's letter of
                  February 10, 1976.  We would, however, like to request that
                  close attention be paid to Prof. Brauner 's recommendations
                  in regard to mitigating the impact of this project.

                                              Sincerely,
                    1,
                   0
                                              Paul B. Hartwig
                                              Historical Programs Coordinator
                                              State Historic Preservation Office
                  PH/EL:ko
                                           151
 Form 81-734-3122

-------
                                                    AN EQUAL OPPORTUNITY EMPLOYER
               EXECUTIVE DEPARTMENT
               INTERGOVERNMENTAL RELATIONS DIVISION
               240 COTTAGE STREET S.E.
         SALEM, OREGON 97310
ROBERT W. STRAUB
    GOVERNOR


  STAFFORD HANSELL
    Director
June 7, 1976
            Richard R. Thiel, P.E., Chief
            Environmental Impact Section, M/S 443
            U.S. Environmental Protection Agency, Region X
            1200 Sixth Avenue
            Seattle, Washington  98101
            Dear Mr. Thiel:
                                         Re:  Wastewater Treatment System
                                              PNRS #7604 4 990
                   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.  Department of Land Conservation and Development,
            Water Resources Department, Highway Division, State Parks
            Division, Department of Geology, and Division of State Lands
            offered the enclosed comments which should be addressed in
            preparation of your final Environmental Impact Statement.

                   We will expect to receive copies of the final state-
            ment as required by Council of Environmental Quality Guidelines.
                                              Sinceurely,
                                             ^Michael L. Burton
                                              Supervisor
            MLB:1m
            Enclosures
                                                               RECEIVED
                                     152

-------
        OREGON PROJECT NOTIRCAT8ON AND REV!£\# SYSTEM

                          STATE CLEARINGHOUSE            LAND^^^IOM

                 Intergovernmental Relations Division
         t- ,  240 Cottage  Street S.E., Salem, Oregon 97310
                            Ph: 378-3732

               Vc  P N  R  S  STATE   REVIEW         SALEM


Project ft; 760^  -\  990         Return Date;    /f-<2 i? - 76?	

                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.

( /)  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



   SEE ATTACHMENT
                               153
                 / finn
Agency 	\

-------
RESPONSE TO DEIS #7604-4-990
                 #7604-4-1170

    The selection of an alternative under this project and its related
land use implications must be coordinated and consistent with local
comprehensive paans in general and current efforts of the involved
jurisdictions to update their plans in particular.  In this regard
the City of Newport and Lincoln County presently are requesting a
planning extension and financial assistance to  perform the work
needed to develop comprehensive plans consistent with the provisions
of the statewide planning goals.

    Accompanying these requests are a compliance schedule and de-
tailed work program.  Staff of the Department of Land Conservation
and Development have conducted a detailed review of these documents
and have made recommendations to the Land Conservation and Develop-
ment Commission.  These recommendations, if approved by the
Commission will provide for the development of a complete preliminary
comprehensive plan for the area included in the Bay to Bay and
Southwest Lincoln County Sanitary Districts and the area around
the Cities of Newport, Waldport and Yachats by July 31, 1977.
These recommendations would also result in a delay of less than
one year in selecting an alternative and proceeding to phase 2
(eg development of a design plan and specifications for the
selected alternative).
    The purpose of the delay would be to ass'ure that the selected
alternative is consistent with the revised comprehensive plan; that
issues and conflicts are resolved early in the process; and that
further complications and delays in solving sewage disposal and
water pollution problems are avoided.
    Action on the recommendations by LCDC is expected on June 18, 197<
At that time the report and notice ,of the LCDC's action will be
transmitted to you for your information.
                                 154

-------
                                                        cc '.
                                                                         J ?'<
OBERT W. STRAUB
   GOVERNOR
               DEPAR
               LAND CONSERVATION AE\!D DEVELOPMENT
 1175 COURT STREET N.E.   •  SALEM, OREGON  •  97310  •  (503)378-4926

 July  1,  1976
  HAROLD F. BRAUNER
     Director


LAND CONSERVATION AND
DEVELOPMENT COMMISSION


    I. B. DAY
    Chairman


   STEVEN SCHELl
   Vice Chairman


  DOROTHY ANDERSON
  ALBERT BULLIES, JR.

  RICHARD GERVAIS
   DR. PAUL RUDY
   JAMES SMART
 Richard  Thiel
 Environmental  Protection Agency
 Mail  Stop  443,
 1200  6th-Ave.
 Seattle, WA  98101

 Dear  Mr. Thiel:
RECEIVED

JUL 8  1976
  EPA-EJS
 In  our  comments  on the  DEIS for the Bay to Bay and South-
 west Lincoln  County Sanitary Districts we indicated that
 we  had  reviewed  the proposals and had made recommendations
 to  the  Land Conservation"and Development Commission."
 These recommendations,  as  approved by the Commission,
 will provide  for the development of a complete prelim-
 inary comprehensive plan for the area included in the
 Bay to  Bay and Southwest Lincoln County Sanitary Districts
 and the area  around the cities of Newport, Waldport and
 Yachats by July  31,  1977.   The staff report sets forth
 the Commission1s action and is attached.  While the
 Commission did not specifically comment on the proposals
 or  the  recommended increase in funding, it did address
 the overall timeframe for  compliance.  You should note
 that the timeframe has  been reduced from 1987 to 1980.
•This indicates the Commission's commitment to assuring
 that coordinated comprehensive plans are developed in
 an  expeditious manner.   Consistent with this commitment
 is  the  assurance that comprehensive plans are developed
 in  a coordinated and balanced fashion.

 Accordingly,  in  regard  to  the proposals you are consid-.
 ering,  we would  like to request that you delay a decision
 pn  both of the proposals until a desirable alternative
 is  identified through development of the local coordinated
 comprehensive plan.   A  delay,.estimated at not more than
 a year,  would allow the planning process to operate as
 intended.  Conflicts between uses would be resolved and
 would permit  the development of a sewerage alternative
 consistent with  land uses  and documented needs.
                                     155

-------
Mr. Richard Thiel
July I, 1976                                      -2-
I would also like to take this opportunity to bring
your attention to some factual erroio in the DEIS's.

First, the Land Conservation and Development Commission
has not yet implemented a permit process for activities
of statewide significance; including, sewerage and -
solid waste disposal facilities.

Secondly, the Commission and the Department are placing
emphasis on the evaluation of comprehensive plans and
development of compliance schedules to complete these
plans in accordance with the provisions of the State-
wide Planning Goals and Guidelines (copy attached for
your information).

Such errors are understandable in light of the fact that
our program has been evolving very rapidly and at the
time the DEIS's wj^ere developed some of the facts may
not have been very clear.  In this regard, a meeting
between our agencies might be desirable so similar act-
ivities in the future may be more effectively directed
and delays avoided.

Should you have any questions, please don't hesitate to
contact this office or Neal Coenen, of my staff, who is
the Department's field representative for Lincoln County.

Sincerely,
Harold F. Brauner
Director

NC:lj

Enclosure

cc:  Lincoln County Commissioners
     Bill Sobolewski
     Max Rijken
                      156

-------
Response to Comments from the Department
     of Land Conservation and Development
1.   Please see Preface to this final EIS,

2.   These comments have been recognized.
                              157

-------
        OREGON PROJECT NOTIHCATION AND  REVIEW SYSTEM

                         STATE CLEARINGHOUSE            Su"

                Intergovernmental Relations Division
             240 Cottage Street S.E.,  Salem, Oregon  97310
                            Ph:  378-3732
 l.r,c-L •   "Mr
                  P N R S
MAY 2 tf i97S
Project #:   ? 6 0 4
                       STATE
                                       R E V I E VI
                                    Return Date;
               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.

(A)   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
                                       tL
                                       ^
    L
f'j^cL
          i
           -
-------
Response to Comments from Department
     of Water Resources
1.   Comments noted and additions made — see page 24,
                              159

-------
        OREGON  PROJECT NOTiHCATION AND REVIEW SYSTEM

                       '  STATE CLEARINGHOUSE              -^

                 Intergovernmental Relations Division
             240  Cottage Street S.E., Salem, Oregon  97310
                            Ph: 378-3732
                   P N  R S   STATE   REVIEW

Project f ; _  7604  4   990
                                     Return Date;
1.
2.
               ENVIRONMENTAL IMPACT REVIEW PROCEDURES
    A response  is required to all notices requesting environmental review.
    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.

(;. 0   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
                       /  —
                      r tJ ? T
                                              /
                                                    ;«. /
C 6 n -f' i a
                           C* 11 3 rf ^ C rt 
-------
Response to Comments from Highway Division


1.   The recommendations have been noted and will be instituted
     whenever a project is determined for the sanitary district.
                              161

-------
         OREGON PROJECT  MOTiTSCATSON AND REVIEW SYSTEM
                     • '  f i          ,
                       '   STATE CLEARINGHOUSE

                 Intergovernmental Relations Division
             240 Cottage Street S.E. ,  Salem, Oregon  97310
                             Ph: 378-3732

                   P N R S   STATE   REVIEW
Project f;   7^0 k   k  990
                                      Return Date;
                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.
 JO
      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
                                           A
                                         j
        A//  P fl>  *
                                      *
                                    c   u  A
                                     J  if.
                                                                   +<-T
                                162
Agency
                                      By  *

-------
         OREGON PROJECT NOTIFICATION  AND  REVIEW SYSTEM

                         •STATE CLEARINGHOUSE
                 Intergovernmental Relations Division
             240 Cottage Street S.E.,  Salem, Oregon  97310
                             Ph:  378-3732
                   P N R S   STATE    REVIEW
Project f ;    7 f> 0 4
                         990
                                      Return Date:
1.
2.
                ENVIRONMENTAL IMPACT REVIEW  PROCEDURES
    A response is required to all notices  requesting environmental review.
    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)  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
                     *
           *f
                                                        '  <*
                            P
                                 163
Agency
                                      By

-------
Response to Comments from Geology
1.   The necessary procedures will be carried out at the time
     of project designation and implementation.
                             164

-------
          OREGON PROJECT NOTIRCATSON  AND REVIEW SYSTEM

                            STATE CLEARINGHOUSE
                   Intergovernmental Relations Division
               240 Cottage Street S.E., Salem, Oregon  97310
                                Ph:  378-3732
                     P N R S    STATE   REVIEW


 Project #:  7 L A Ji   >.   Q Q fi         Return Date:	
             / U U  r   *?   I 7\J
                                                                ^.:
                  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.

 (   )  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

If  the alternative .selected involves the construction of a new ocean outfall or a
crossing of  state owned submerged or submersible land, an easement will be required
from the Ldvision of State Lands.

also, if tr.e project would require the removal or fill of 50 cubic yards or more
of  r.aterial  below i.he bank of t>e  waterway, we ur<;e the applicant to apply for
state fill or  removal permits well in advance on construction deaolines to prevent
unnecessary  project delays.                   .'               •: ->,

Specific information on tr.e neea for pcmito or easements nay be obtaaneu from
t,,e bivision of State Lands' office at 1^  State Jtreet, Saler.i, Oregon V7310.
Phone 378-3805.
                                    165

Agency 	-C/^txyU*--*?	   By Vji

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Response to Comments from State Lands





1.   Comments noted.
                            166

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                  OREGON STATE
                  HIGHWAY  DIVISION
               PARKS AND RECREATION BRANCH  525 Trade Street S.E.  Salem  97310
ROBERT W. STRAUB
    GOVERNOR                                   June 11, 1976
    F. B. KLABOE
   Administrator and
 State Highway Engineer                                                         RECEIVED

               Richard  R. Thiel, P.E. Chief                           JUN 1 4 1S76
               Environmental  Impact Section, M/S 443
               U.S.  Environmental Protection Agency, Region X           EP,"> r'~
               1200  Sixth Avenue
               Seattle, WA 98101

               Dear  Mr. Thiel:

               In  the seven-mile segment of central Oregon coast between Yachats
               and Waldport,  the Oregon State Parks and Recreation Branch maintains
               three parcels  of land.  These properties, located within  the
               boundaries of  the Southwest Lincoln County Sanitary District, are:

               1.  Beachside  State Park—16.70 acres.  Facilities include 80
                  overnight  sites (20 trailer, 60 tent), one day-use/beach access
                  parking area.

               2.  Governor Patterson Memorial State Park--10.23 acres.   Facilities
                  include one day-use/beach access parking area with restrooms.

               3.  San  Marine State Wayside--7.20 acres.  This park is undeveloped.

               Specific Parks Branch comments in regard to the Draft Environmental
               Impact Statement of the Southwest Lincoln County Sanitary District
               are:

               a.  Pages 46 and 47, under headings of Tourist Population and
                  Recreation respectively.

                  The  state  park property at Smelt Sands State Wayside, when
                  developed, will be served by the City of Yachats sewerage
                  system.  The park is not within the boundaries of the Southwest
                  Lincoln County Sanitary District.
                                           167

-------
 Richard R. Thiel
 June 11, 1976
 Page 2
 2.  Page 47, under Recreation heading.

     "There are two developed and operating state parks and
     recreation facilities in the district" (instead of the
     "four" stated).  These are Governor Patterson Memorial and
     Beachside State Parks.
v
, 3.  Page 53, under Public heading.

     "In addition the two facilities, encompassing about 27_ acres,
     currently being operated, plans exist to develop one additional,
     the San Marine property.  The development of this facility will
     result..."

 4.  Page 55, last paragraph, last sentence in reference to the
     proposed small sewage treatment plant at Beachside State Park.

     "However, this project was never carried out because of
     objections from the sanitary district.  This interim system
     would have been utilized only until sewer service could have
     been supplied by the sanitary district^

*5.  In regard to the financial participation for sewer system costs:

     Page 65, top of page.

     Tax exempt agencies "will pay an initial  one time cash payment
     to help offset facilities construction, a payment that would
     probably be based on the value of properties determined in a
     manner similar to that used by the county tax assessor."

     It is recommended that this sentence end at "to help offset
     facilities construction."

     The Parks Branch certainly expects to pay its "fair share" cost
     of providing sewerage service to state parks in the district's
     service area.  However, state park policy in regard to this
     participation is based on the demand park facilities will  place
     on the sewage system, not the value or amount of property.
     The need to maintain open space for public enjoyment and
     useage is a primary responsibility of the Parks Branch.   As
     such, park lands provide a stabilizing factor to the landscape,
     as opposed to the speculative possibilities of open space in
     private ownership.

 The Parks Branch supports the efforts of the Southwest Lincoln
 County Sanitary District to construct and operate a wastewater
 treatment system to serve the area's residents and visitors.
                              168

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Richard R. Thiel
June 11, 1976
Page 3
In providing service for park visitors, the system would enable
full utilization of the facilities at Beachside State Park and
ensure for the future adequate wastewater disposal at Governor
Patterson State Park and the proposed/San Marine State Wayside.

                               Very tfpuly^ours,
9P

cc:
                               LarryJJacjjJ&on, Assistant
                               State Parks Superintendent
Henry Baldwin, Southwest Lincoln County Sanitary District
Robert E. Meyers Engineers
J. Christopher Minor, Attorney
Lincoln County Commissioners
                             169

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Response to Comments from Parks and Recreation Branch


1.   Comments noted.

2.   Changes to pages 47 and 50 were made as necessary.

3.   Corrections were made in the sentence on page 47 to
     reflect the presence of state and federal facilities.

4.   Change made as necessary to page 53.

5.   Additions to paragraph on page 55 were made as requested,

6.   Changes made to page 65 as requested.
                             170

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                                  Board of County Commissioners
                                ALBERT R. STRAND, CHAIRMAN - ANDY ZEDWiCK - JACK W. POSTLE

                                                                        4&*~
                                COUNTY   OF   LINCOLN
                                           Newport, Oregon  97865

                                              June 3rd,  1976
Clifford V.  Smith,  Jr., Ph.D., P.E.
Regional Administrator
United States Environmental Protection Agency
Mail Stop 613
Region X
1200 Sixth Avenue
Seattle, Washington 98101

       RE:  Draft Environmental  Impact Statement
            Southwest Lincoln  County Sanitary District

Dear Dr. Smith:

We are writing to you as  the Board of Lincoln County with regard to the draft
Environmental Impact Statement prepared for the Southwest Lincoln County
Sanitary District.

We understand that there  is some question about the effect of the sewer
system on land use in Lincoln  County generally, and Southwest Lincoln County
Sanitary District in particular. Apparently there has been some talk about
the fact that at the present time there is no way to ascertain County land
use planning compliance with Statewide land use goals.

W1- would like to point  out to  you that Lincoln County has been a leader in
the .state in land use planning.   We feel that our county has made active efforts
in this regard, and has done a good job of land use planning to date.  Nat\irally,
the State of Oregon has initiated an entirely new program under the Land
Conservation and Development Commission, which still has not adopted its ov.'n
initial goals and guidelines,  and \-re anticipate that there will be new planning
efforts to be made in the future to keep our land use planning efforts abreast
of ne\j developments at  the state level.

However, it seems grossly unfair to categorize our efforts as incomplete and
inadequate simply because the  State of  Oregon has initiated a new program
which has just begun.  Certainly our efforts up to date should not be ignored.
                                      171

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Clifford V. Smith, Jr., Ph.D., P.E.         June 3rd, "£76
Page Two                                    RE: Southwest Lincoln County
                                                Sanitary District


We feel that the proposal of the Southwest Lincoln County Sanitary District
to solve the sewage disposal problems in that area are exemplary; we endorse
and support their efforts.

As you may be aware, several years ago, then Governor Tom Me Gall made it clear
that he thought itextremely urgentthat certain areas of Lincoln County, including
Southwest Lincoln County, formulate a solution to the problem of inadequate
sub-surface sewage disposal in general, and failing septic tanks in particular.
It was shortly after this that civic minded individuals acted to form the
Southwest Lincoln County Sanitary District and to seek this solution, and we
feel .it regretable that substantial delay has already been encountered.
Certainly we hope that this necessary program can be moved along as rapidly as
possible.

Thank you very much for your consideration.

                                            Sincerely,

                                            LINCOLN COUNTY BOARD OF COMMISSIONERS
                                               Andy Zedwick (absent)
                                            Commissioner
                                      172

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Response to Comments from the Board of County
     Commissioners,  County of Lincoln
     See comments from LCDC, pages 153-156.

     The EIS has not ignored local planning but has instead
     recognized that planning is in a transition period and
     that the development of a sewerage system must be in
     light of the changes.
                             173

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                         Permits, Utilities & Resources Department
                                    Sub-Surface Section
                                   Sanitarian: 265-5341, Ext. 33        , -~,
                                       Director: 265-5772         X ,
                          COUNTYoF LINCOLN
                                   Newport, Oregon 97365
                                   21st May,  1976
                                                      RECEIVED

                                                     MAY 2 5 197C
Richard R.  Thiel,  P.E. Chief
Environmental Impact Section, M/S 443
U.S. Environmental Protection Agency, Region X
1200 Sixth  Avenue
Seattle, Washington 98101

Dear Sir:

I am a Lincoln County Sanitarian working in the  Permits, Utilities
and Resources Department.   We are responsible for determining
approvability of lots for installation of private sewage disposal
systems.

Recently, we  have  encountered difficulties in finding disposal
sites for septic tank pumpings.   Currently,  the only treatment
plant which can or will accept these pumpings on a regular basis
is the Newport Treatment Plant.   Other plants will accept loads
of raw sewage, out the aerobic  sludge cannot be handled.   Appa-
rently, the activated sludge plants are sasceptible to shock
charges of  an aerobic material.

Land disposal is bein ; used as temporary means for handling this
sludge.  These methods include both lagoons  in a level field
wit/i regular  discing.   However, these sites  are difficult to
impossible  to locate as little or no run-off  can be allowed to
occur, contamination of wells or springs must be guarded against,
and proximity to residences must be considered.

Therefore,  I  feel  tnat in any planning for new or enlargement of
existing sewage treatment plants, aerobic pretreatment system to
handle aerobic sewage sludge should be included.
     CLEMENS
LINCOLN COUNTY SANITARIAN

GrC/jl
                           174

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Response to Comments from the County of Lincoln _-_-
     Permits/ Utilities and Resources Department
1.   The septic tank maintenance alternative contains a
     facility to handle sewage sludge.
                              175

-------
J. CHRISTOPHER MINOR

FRED A. YECK

WILLIAM R. NOEL. ( I S69-1 B7E )
  MINOR  & YECK
  ATTORNEYS AT LAW
   156 W. OLIVE ST.
NEWPORT. OREGON 9736S

  June 10,  1976
   TKL.EPHONBI
 268-eeeo
                                                                 RECEIVED
      Mr. Richard R. Thiel, P.E., Chief
      Environmental Impact Section, M/S 443                     JUN 1 4 1976
      U.S. Environmental Protection Agency, Region X
      1200 Sixth Avenue                                           FP*.r"*
      Seattle, Washington   98101

      Re:  Southwest Lincoln County Sanitary District, Environmental
           Impact Statement

      Dear Mr. Thiel:

      At the request of the Board of Directors, I am enclosing
      herewith various materials which have been received by the
      District, to be forwarded to you to be made a part of the
      record of the hearing on the Environmental Impact Statement
      for the District, which is now under consideration.

      Included are the following items:

           1.  Letter from Mr. Paul F. Ehinger, Jr., P.E. from the
      firm of Robert E. Meyer Engineers, Inc., Engineers for the
      District, containing a brief explanation of some of the typical
      costs which might be incurred by a patron of the District follow-
      ing the financial plan prepared for the District.  The District
      requested that the engineer supply this information because,
      at the draft EIS hearing, there seemed to be some misinformation,
      coming from the audience, regarding the costs of the plan.

           2.  Various individual letters received from patrons of the
      District, some of which were directed to the Board of Directors
      and some of which were directed to you through the Board.  We felt
      that you should have access to all of these.

           3.  A letter from Mr. Lewis N.  Powell, also one of the District's
      engineers, regarding the designed flow for the sewer system.
      Apparently there had been some input from an environmental group
      indicating that the system should be designed for a flow of 100
      gallons per capita per day.  Mr. Powell points out that his
      engineering study shows that such a design of flow would be
      entirely inadequate, and that a design flow of at least 140 gallons
      per capita per day would be necessary.

           4.  A 24 page commentary pointing out deficiencies in the
      Draft Environmental Impact Statement page by page.  These materials
      were not prepared by the District, but were forwarded to the
      District Board by interested citizens, who urge you to give your
      attention to the materials contained.  It tends to illustrate the

                                    176

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Mr. Tichard R. Thiel
June 10, 1976

Page 2.

proposition that persons who are unfamiliar with a geographical
area, even though they may devote a good many man hours to
a superficial study, may make many errors because they do not
have the deep seated feel for the area that long time residents
may have.

       5.  A chronology of the district area, which outlines some
of the history and the reasons for its formation, which may be of
interest to you.

                                Sincerely,

                                MINOR & YECK,
JCM:ph
Encls.

cc:  Southwest Lincoln County Sanitary District
     Star Rte. North Box 886
     Yachats, Oregon  97498
                                177

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Comments Disagreeing With E.P.A.'s Position
(E.P.A. -10-or-Lincoln - S.W.L.C.  - W.U.T.H.  -76}

The errors of omission, commission, are so frequent that an abbreviated
code will be used in reference as  follows:

     F _ refers to (Federal  Register volume 40, No. 72,  April  14, 1975)
         40, Part III, Part 6

     S - refers to Southwest Lincoln County Sanitary District newspaper
         clipping file.

     C - refers to data contained  within the transcripts of case
         #34867 in the circuit court of the State of Oregon for the
         County of Lincoln.

     D.- refers to discussion or comment on a particular line on a
         particular page of the draft E.I.S.  (example:   p.25 D. L. 26
         means a comment, discussion, or explanation of line 26 on page 25.

    NC - refers to no comment
Analysis as Follows:

 I  Cover Sheet  - NC

II  Table of Contents  i-ii NC
     /  jiii - D -  Table 5 page 23 - incorrect table.

         iii - D - should have included data on zoning  ordinances &
                   zoning maps, and other available data

          iv -     NC

           v - D - Should have included current zoning  map

          vii- D - L. 18 - "3,000 acres".   The actual district boundaries
                   are about 3,000 acres,  but the study area includes
                   beach area, steep areas of logged-off land (that are not
                   buildable) which comprises of approximately 2,500
                   additional acres considered as open  space.  Adjacent
                   to the subject 5,500 acres study area is the Siuslaw
                   National Forest on the  east which is appropriately
                   managed by the U.S.  Forest Service.   The beach and the
                   Pacific Ocean are on the west side of the study area.
                               178

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           vii - D -L.19 2,024 permanent residents and approximately 660
                    seasonal residents "the projection of population was
                    based upon a 1972 study by Jack Jarvis and Co.  This
                    study has not accounted for the "state actions" on
                    Lincoln County which have been to use unreasonable rules
                    and regulations to impede reasonable growth in housing
                    and population increases.  We have had a situation
                    that if septic tanks were approved, there was no water
                    approval; or if water was approved the rules on septic
                    tanks were reworded so you probably couldn't get a
                    permit (see C)

          Ivii - D - L. 22  High groundwater not so - (see L) - should read
                    perched water table (seeC)

          vii - D - L. 29:  Some areas within the district are suitable for
                    subsurface sanitation once the underlying banded layer
                    of "cemented" sand is ripped, {see C)
          viii -

            ix -

             x -

            xi -
              NC

              NC

              NC

              NC
  III
7
Introduction PI  D - L - 9 to 15.   Not the same wordings  as  Federal
Register in Vol. 40, Number 72, Part III,  Part 6 (pg.  16814)
Monday April 14, 1975, as signed April  3,  1975, by Russell  E.  Train,
Administrator, E.P.A.

     P. 1 - D - L.  22  "It was decided by  the E.P.A.  that  an  E.I.S.
              was needed,  (see F.  $ 6,200 (a) CD -  "However,
              preference should be  given to preparing  E.I.S.  on
              proposed actions which, on balance, have adverse
              effects"  We believe  that E.P.A. 1s in  conflict with
              urban policy growth,  1970, 42 U.S.C.A.  $ 4502 (d),  (1),
              (2),  (5), and (6), and Public Law 91-190, 91st.
              Congress, S. 1075, Jan, 1, 1970.  Sec.  2.  "The pur-
              poses of this act are:  To declare a national policy
              which will encourage  productive and enjoyable harmony
              between man and his environment;"(underlined  for
              emphasis)  (N.E.P.A.  1969).


     P. 1 - D - L.  23  "Likely changes in  land use patterns"   Error-
              see ordinance number  34, Lincoln County, Oregon by tts
              Board of County Commissioners dated this 6th. day  of
              March 1974, and entered nunc pro tunct  as of the 12th day
              of February, 1974. Also see Hagman, D,  Public Planning
              and control of Urban  and Land Development, 1973.  pg.
              90-93 and pgs. 135-137 i.e.  "The thesis  of this chapter
              is that while planning has at least proved itself
              sufficiently meritorius to warrant continued experi-

                          179

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   i
   6.510 (a) no treatment works - only  buried
         pipe and pump stations.
       P. 1 - D - L. 25 to L. 35 - Misquoted (see F $ 6.510 (a-g)
                P. 1 , D. - L. 25  "The increases in population which
                may be induced"  Increases in population are desireable
                because it provides a place and fills a need for a
                segment of the population who need more and better
              .  housing,  (see 42 U.S.C.A. $ 4502 (d) (1), (2), (5),  (6)
 II
13
P. 1 - D - L.  26 - (error - not quoted correctly)   Csee  F.  $  6.510)
         correct is:   "The faster rate of change of population"
         Population will  change at a faster  rate because the  State
         of Oregon has thru its administrative  rules induced  an
         artificially sub-normal  growth rate.

P. 1 - D - L  "changes in population density"   Population densities'
         for the study area will  be totally  less dense than most
         neighborhoods of Salem,  Eugene,  Portland  ore Corvallis.
         (see  zoning  maps, zoning ordinances, subdivision laws)
         However it is our belief that density  is  not the measure
         of the "quality  of life".

P. 1 - D - L.  26 a Error - left  out "The potential  for  over-
         loading sewage treatment works;  "This  would be  avoided
         by proper and appropriate design considerations."
                             180

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n
P.  1 - D - L 27-28  "The extent to which  landowners may
         benefit from the areas subject to  increased  development;"
         Land owners could benefit from sales  of  developed  lots
       as could the general  public in  that  developed  lots provide
         sites for housing which fills a  need  for more and  better
         housing,   (see 42 U.S.C.A.  $  4502  (d)  (1),  (2),  (5),  (6)  )

P.  1 - D - L. 29 "The nature of land use  regulations  in the
         affected area (no comma) and  their potential effects  on
         development;"  Th~e report failed to even address this
         subject (see zoning ordinances,  land  use plans,  and
         subdivision ordinances, and (F.  f  6.510  (a). )

P.  1 - D - L. 29 a  Left out.   ; "and  deleterious changes in the
         availability or demand for  energy."  (meaning hurtful-
         changes)

p-  1 - D Parts Omitted:  (F. 6.510 (b), (e), (d)   (1) (2)(3),
         (e), (f), (g) and in addition to considering the
         criteria in $ 6.200.  (see F.  $ 6.202.  ~ E.I.S.'s
         are factual and comprehensive, i.e.)

P.  1 - D - L. 31-33  Not properly quoted  "effects on  Parklands—
         (see F. $  6.510 (e)  "The  treatment  works  or plan will
         have significant adverse effects on park lands,  other
         public lands or areas of recognized scenic,  recreational,
         archaeological or historical  value."

         The plan is to bury a sewer line and  appurtenant pump
         stations to carry effluent  to the  Yachats  treatment
         plant or other suitable treatment  facility.  It  is
         doubtful  if any significant adverse effects  could  be
         justified other than perhaps  archaelogical,  and  in that
         case, the sewer lines could be moved  away  from the r
               .  What we wonder—has  the State of  Oregon treated
         all archaelogical sites of  equal significance?
         How about the site under the  north end of  the St.  Johns
         bridge in Portland, Oregon  where the  city  of Portland
         at Cathedral Park is putting  in  a  public boat launching
         and parking lot?  We believe  that  this is  a known
         archaelogical site and has  it been fully excavated?
         Is the State of Oregon using  selective discrimination
         as to what they choose to delay  to obtain  what they
         think is desirable?  (Oregonian  pg. Al May 14, 1976.)

P.  1 - L 34-47  NC

General Comment - Page 1 didn't clearly state  that  the S.W.L.C.S.D.
         plan was to bury a sewer line and  appurtenant  pump
         stations to carry effluent  to an existing  treatment
         plant.  Within the S.W.L.C.S.D.  is the S.W.  Lincoln
         County Water District which has  recently completed
                           181

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         a $325,000 expansion  of the water  distribution system
         (see S 8-15-74)   Purpose of the  E.I.S.  is  to  analyze
         all  the alternative  actions and  resultant  changes  that
         would occur by either going according  to plan, not
         going at all,  or some other reasonable  alternative.

P.  2     Background of  Past Events
         D.  - L. 1-44See attachments  concerning:   Political
         organizations, politicians, and  public  officials

P.  3 D.  - L 1-36
                     See S_.  and Chronology
P.  4 D  - L 1-21
         of S.W.L.C.S.D.

P.  4 D.  - L.  15-17  "Headquarters Washington, D.C.,  awards  con-
         tract to Jones & Stokes Associates5  Inc. to assist
         E.P.A. in preparation of E.I.S."

Questions
         (1)   Was awarding of the contract  by bid and who were
              the bidders?

         (2)   Who recommended that Jones  &  Stokes et al assist  E.P.A,?

         (3)   How much  time did Jones  & Stokes  et al spend  on
              the E.I.S.?  When and where?

         (4)   How much  were Jones & Stokes  et al paid for  their
              services?

         (5)   Did any State of Oregon  employer  recommend Jones
              & Stokes  et al?  If so who  were they?
Important Issues and Considerations

P. 4 D - L. 34-37 1.  "Present and projected land use - i.e."
         (Comment see:  Data in county clerks office, zoning
         ordinance #34;  Land use maps; state subdivision law;
         topographical maps; gedlogical maps; Hagman D,
         Public Planning & control of urban and land development.
         1973 pgs. 90-93, pgs 135-137, pgs 770-773.

P. 5 D L 1-3.  "On vacant land ie  see previous definition of
         vacant

P. 5 D - L 4-6  "Patterns of land ownership" i.e
         Land owners could benefit from sales of developed
         lots as could the general public in that developed
         lots provide sites for housing which fills  a need for
         more and better housing,  (see 42 U.S.C.A.  4 4502
         (d) (1), (2), (5), (6) )
                      182

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          P.  5   -  D  L  7-9   "Response of traffic, ie"  The 1974 traffic
                  data  for Otter  Rock, 21-002 on the permanent recorder
                  indicates  that  the average traffic volume for June
                  thru  September  is about double the average traffic
                  volume  of  the other eight months of the year.
                  Classification  breakdown indicates only 8% of the
                  traffic is out-of-state passenger-cars.  This means
                  that  about 82%  of the  tourists on the Oregon coast
                  during  the summer months are Oregonians.  (see
                  Oregon  State Highway Division Traffic volume tables
                  for 1974,  pg. 227.)  Thus, the beachside public parks
                  could be considered by some as an "attractive
                  nuisance"  and a resultant cause of summertime traffic
                  congestion on U.S. Highway 101.

          P.  5  - D - L 10-12  Comments same as response to pg. 4 lines 34-37

          P.  5     N.C.  L  13-14  "Possible interrelationships ie"

          P.  5  - D - L 15-17  "Possible direct impacts of projects on
                  parks ie."  As  82% of  the summertime tourist traffic
                  congestion is Oregonians at the state beachside parks;
                  it  is the  parks that are impacting all the other pro-
                  perty.   Perhaps the parks near the ocean should be
                  restricted so the traffic congestion and pollution
                  are abated.

          P.  5  N.C.  L  18-19  "General level of hazard ie"

          P.  5     N.C.  L  20-21  "The financial impact ie"

          P.  5  - D - L 22   "The purpose and objectives of doing an E.I.S."
                  See General comment  about page 1

          P.  6     N.C.  Blank

IV  Environmental  Setting

          P.  7     N.C.  L  1-6

          P.  7  - D - L 7-8 Waldport is  81 miles from Eugene
                                      105 miles from Salem
                                      135 Miles from Portland

          P.  7     N.C.  L 9-18

          P.  7  - D.  -  L  19 Average annual precipitation at Newport
                  (1937-68), 68.18" not  66"

                  comment:  Might add:   average year-round temperature
                             50° F.

          P.  7     N.C.  L. 20-34
                               183

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      P. 8  - D -  Figure 1 should also delineate the study area
               which should be from the Pacific Ocean to the Siuslaw
               National Forest.
      P. 9     N.C.  Figure 2
      P. 10    N.C. L  1-14
      P. 10 D - L 15-20 "ranges from 10 to 80 feet."  Incorrect, should
               read from sea level to 250 feet.
      IP. 10 D - L 20 "Those creeks"  Lint Creek was not included in
      I         the list.
      P. 10    N.C. L 21-24
      P. 10 D - L 25 "Substantial flood hazard"  -  Department of
               Housing and Urban Development Federal Insurance
               Administration Flood Hazard Boundary Maps for Lincoln
               County do not indicate "substantial"
      P. 10    N.C.  L 25-40
      P. 10 D - Line 41 "high water table, cemented sands" correction
               high should read perched (see C)
               Cemented sands - the cemented sands when ripped in
               some areas will then permit adequate percolation for  -
               septic tank absorption field use.  (see C)
      P. 10    N.C.  L 42
      P. 11    N.C. Table 1
      P. 12    N.C.  Figure 3
* A  |p- 13 D - Table 2  A partial explanation is shown on pages
* i  I         16,19, 20, 28, 29 of Soil  Survey Alsea  area
      1         Oregon, October 1973.
"30   JP. 14 - D L 1  "High water tables"   High should read perched.
      P. 14    N.C.  L 2
  -*i  JP. 14 D - L 3  "(Less than 80 feet ie)" should say:  To 250 feet
  ^  I         above sea level.
      P. 14 - D - L 5-12  "Septic tanks ie"  This is a generalized
               statement which says a whole lot about nothing.
      P. 14    N.C.  L 13-25
                           184

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                                                             8
33. (>.
      - D - L 26  "in thickness  from a  few  feet  to more  than 20
         feet."  Should read:   to  more  than 200  feet.
33
P. 14    N.C.  L 35-40

P. 15    N.C.  L 1-2

P. 15 - D - L  3-4  "high ground water ie"   Should  read  perched.

P. 15 - D L 5-18  "Erosion ie"   (see S 4/3/75)   Erosion on  the
         beach could be alleviated to some  degree  if the
         State of Oregon, D.O.T.  would prohibit burning,
         taking, and removal  of logs and other  flotsam  and  jetsam -
         which the "tourists" remove or burn.   Department of
         Transportation State of Oregon has jurisdiction over
         the beach areas.  If erosion is so critical  perhaps
         people should be prohibited from going on the  beach
         areas and no more parks along the  beach to alleviate
         the "tourists."

   15 - D - L  19-31  Seismetic disturbances in  the fault areas
         is not considered critical  as all  areas of the State
         of Oregon have faults.  The subject study area has a
         lesser degree of likelyhood of earthquake fault problems
         than  either Salem, Eugene,  Corvallis,  or  Portland, Oregon.

   15 - D - L  32-35  "High groundwater tables"   should  read:
         Perched  groundwater tables.

   15 - D - L  36-38  "The problem of high groundwater"   should
         read perched (see C )  Cause of the perched water
         tables is from iron which tends to consolidate the
         sands into a semi-impermiable barrier  which restricts
         the downward percolation of water.  When  the consolidated
         sands are broken they probably wouldn't reconsolidate
         within 100 years.

   15 - D - L  39-47  See flood hazard boundary  maps H.U.D.  for
         Lincoln County, Or.  Unincorporated area.

P. 16 - D - figure 4 - legend should be corrected:  "High
         groundwater" to perched groundwater, also coastal
         erosion (see S 4/3/75) for the whys of erosion.

         Figure 4 should show the entire study  area, not just
         the sanitary district - all 5500  acres.

P. 17    N.C.  Table 3

P. 18    N.C.  L 1-7

P. 18 - D - L  8 "The erosion hazard is generally high"   (see
         S 4/3/75)
                           185

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P.  18    N.C.   L 9-42

P.  19    N.C.   Figure 5

P.  20 - D - Figure 4 on page 16 shows critical  erosion of
         sand spits and dunes,  yet the legend on figure 5
         doesn't show any dunes or sand spits.   Why?

 '.  21 - D - Table 4  Should also show:  Present zoning is:
                     residential
            tourist commercial
            industrial (sawmill)
            natural resources
            rural residential
-  1667  acres
    28  acres
    10  acres
   430  acres
   302  acres

2,327  acres
         In addition to this there are three state park sites
         which total 34 acres, a federal  park of 45 acres,
         Camp Angel! Job Corp of 25 acres, Si us! aw National
         Forest of 140 acres and a 29 acre airport which total
         about 273 acres.   There are 352  acres of sandy beach
         and 17 acres of rocky coast which is under the
         jurisdiction of D.O.T.  State of  Oregon.  In addition
         to this there is  an 80 acre, nine-hole public golf
         course which is classified as open space.  This totals
         about 3,159 acres.

         Property under public ownership  or control is about
         722 acres and the breakdown is:

             golf course:   80 acres
          State control   422 acres (includes airport)
          Federal control  210 acres
                          722 acres

         Federal property  within the district boundary is about
         6.6%, state property is about 13.3% and the two com-
         prise about 20% of the total property in the area.

         Primary cause of summer traffic  increases are directly
         related to the tourists of which 83% are Oregonians.  The
         "attractive nuisance" feature which brings them to the
         subject area are  related directly to the 12.5% land
         mass of public parks & beaches controlled by the
         State of Oregon and the Federal  Government.
P.  22    N.C.   L 1-13
                     186

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     P. 22 - D - L 14-18    "Rare and endangered wildlife"  Both
              lists used were incorrect.  See U.S. Department of
              Interior, U.S. Fish & Wildlife Service.  United States
              list of endangered fauna.  May 1974, and Oregon
              Wildlife Commission list, Portland, Oregon, January 1975.

it            this is 1976.  Procedures are required as to  the
              actions on threatened or endangered species.
              Section (6) speaks for itself—no more—no less.
     P. 22 D - L - 18  "Those animals are listed in table 5"  Table
              5 is incorrect.

     P. 22 - D - L 19-20  "among the nine species ie"  There are only
              nine that might be found in the study area.  Neither
              the white-footed vole or flammulated owl are on the
              1/75 Oregon Wildlife Commission of threatened or en-
              dangered Oregon Wildlife list or the Federal list.

              The following is a list of threatened or endangered
              wildlife  that might be found  in the study area
              (5,500 acres) according to the 1/75 Oregon Wildlife
              Commission.

              Mammals                                  Status
                Sea otter  (§jihy_dra lutris)               T
                Wolverine  (Gulo gulo")   "                 T

              Amphibians and Reptiles
                Western spotted frog  (j-fcnpi pretiosa)     T
              Birds
                CaTifornia brown pelican                  E *
                 (Pe lee an us occidental is californicus)

                Aleutian Canada Goose                     E *
                 (Branta Canadensjs Leucopareiaj
                American Peregrine Falcon                 E *
                 (Falcg Pereqrinus, Apatum)

                Northern Bald Eagle                       T
                 (Haliaetus UucocepJifllus AJ
                Northern Spotted Owl
                 Strix Occidental is Cajjrina)

                Western Snowy Plover
                 (Charadrius Alexandrinus Niyosiis.}_
              *  Classified as endangered nationally by the Department
              of Interior,  U.S.  Fish & Wildlife Service.
                         187

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                                              11
The sea otter is a marine mammal which inhabits the
southern Oregon coast principally around Cape Arago
and Cape Blanco.  These animals could be an occasional
visitor to the offshore rocks and feeding grounds-
should they happen to stray into the Alsea Bay area.

Wolverines used to be inhabitants of dense forest of
the Cascade Mountains, but are extremely rare in Oregon.
Typically their range now is in Canada and Alaska.
There has been one possible sighting of a wolverine
in northern Lincoln County.

Western spotted frogs have decreased dramatically since
1930 with the introduction of the bullfrog.  The bull-
frog eats the spotted frog and that is why the spotted
frog in Oregon is now rare.

California brown pelicans nest in Mexico and migrate
north and are commonly observed on the Oregon coast
during the summer months.  The population of brown
pelicans numbers several thousand and are fairly common.
Nesting sites in Mexico are the critical item in the
life cycle of the brown pelican.

Aleutian Canada Geese are about 800 in population.
Aleutian geese nest on Buldair Island at the end of the
Aleutian Chain and migrate to Crescent City, California.
The problem with the Aleutian Goose is a matter of
identification.  There have not been any positive
sightings of this goose in Oregon, however it is
possible that it could visit the Alsea - Yachats area on
its migration route.

American Peregrine Falcons were historically cliff
nesters in the Columbia Gourge area.  There are 10
nesting pairs in California, none have been sighted
in Washington and only two sightings have been re-
ported in Oregon.  These birds of prey might have
been seen in the study area, but that is hightly unlikely.

Northern Bald Eagles range from Fort Rock to the Oregon
coast.  The primary population problem is D.D.T. in the
good chain in which the females lay eggs with very thin
shells.  The birds step on the eggs and many are
broken in the nest before they can be hatched by the bird.
The eagle could possibly be observed in the study area.

Northern Spotted Owls are typically found in the dense
forested areas of higher elevations and may rarely
forage in the study area and might be indirectly
affected by the project.
             188

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                                                       12
         Western Snowy Plovers typically nest on sand spits  on
         the Oregon coast.   One nesting population  is located
         at Bayshore on the north spit of Alsea  Bay which is
         about a mile north and across the Bay from the northern
         end of the project.   The Snowy Plovers  could visit  the
         subject study area but the project would have little
         direct consequence to this bird.


A forest fire started by a careless tourist would have several
thousand times more negative impact on all the species of
mammals and fowls than the impact of this project.

One oil spill on the ocean, whether by U.S.A. or foreign
vessel have say caused the loss of 10,000 birds.

The impact of this sewer line is negligable as compared to the
effects of one oil spill.

P. 22    N.C. - L 21-39

P. 23 - Table 5  See revision on pg. 22 line 19-20

P. 24 - D - L 1  "However, the aesthetic qualities  ie"  "By
         Assuming, however, that beauty is a matter neither
         subject to rational  criticism nor capable  of measurement
         by precise standards, courts say that although individuals
         may desire beauty, or, more accurately, what they
         think is beautiful community officials  qjua officials should
         not be allowed to force their own individual "subjective,"
         "non-measurable," "irrational" aesthetic preferences
         upon others through use of police power.  D. Hagman
         pg. 501.  See:  (also)  Section 13.040  Lincoln County
         zoning ordinance No. 34 March 1974.

P. 24    N.C. - L 2-23

P. 24 - D - L 24 "high ground water- should be :  perched
         water table

P. 24    N.C. L 25-40

P. 25    N.C.

P. 26 & 27 (See C pages 2466 to 2468 - as to what the courts
         opinion was of Mr. Osborne)

P. 28-30  Comment:  The townsite of Waldport is  an  old Indian
         burial ground of the Alsea Tribe.  Alsea in the Indian
         tongue means "Peace"

P. 31-34 N.C.
                      189

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                                                           13
 P.  35  -  D -  As more  people  retire with higher fixed incomes
          these individuals  could be attracted to this area by
          the mild  climate and low tax rate of $19.73 per  $1,000
          of  assessed value  as compared to say $30.00 per $1,000
          of  assessed value  in many other parts of the State of
          Oregon.

 P.  36     N.C.

 P.  37  -  D -  Comment:  The Otter Rock permanent recorder had a
          classification of  traffic as being 8% out-of-state
          passenger cars and the one at Winchester Bay 8.6% out-of-
          state passenger cars.  See traffic volume tables for
          1974.  This  indicates that about 82% of the summer
          traffic increase as tourists are Oregonians.

 P.  38-41  N.C.

 P.  42     N.C. L 1-4

 P.  42  -  D -  L - 5-6   "extensive tours of the area"  Question:
          Is  an extensive tour 1 day, two days, three days?  How
          many actual  hours  were spent by Jones & Stokes & Assoc.,
          Don Owen  &  Assoc.,  and Gruen, Gruen & Associates in the
          field within the confines of the study area after
          the contract was awarded in Washington, D.C.7

 P.  42     N.C. - L  7-41

 P.  43     N.C.

    44  -  D -  Comment:  Although the data infers that incomes of
          the residents in the study area are lower than that
          of  the county and  state averages it could be they might
          have more spendable income as a proportion of their
          total incomes than the averages of county & state
          populations.
 r


I
P.  45-50  N.C.

  51    Land use planning.   Lincoln  County has  had a  planning
        staff and had zoning ordinances  many years prior to
        Oregon  SB 100,  1973.  The  current zoning  ordinance
        #34 is  dated March  1974.   "Only  a year  after  the county
        planning commission met a  state  ultimatum to  get the
        county  planned  and  zoned,  the whole process is  beginning
        again.ie—Paul  BrooKflyser,  another staff member,
        says' that the county plan  already addresses most of the
        goals and guidelines adopted by  the L.C.D.C.  He
        feels that the  county merely has to justify its plan
        to the  state."   The clamor by elected and public officials
        for more citizen participation rather than more
        professional  planning is a cop-out on the part  of elected
        and public officials.   This  is like getting 100 people

                    190

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                                                              14
         together—looking  at  a  patient  and  then  telling  the
         doctor how  to  operate,   (see  S  2/13/75)  (also  see
         county records)  L.C.D.C.  is  not  following  all of  the
         legislative intent when S.B.  100  was passed (see
         hearings)

         Anti-growth factions  drafted  the  bill  and one  of the
         first drafts states that:   "all warranty deeds must
         show that the  property  is  connected to water & sewer
         before it is sold."

         For example:  Governor  Tom McCall had  Les AuCoin intro-
         duce S.B. 2607.   It passed and  became  law.   This bill
         was law for about  a week as the State  of Oregon's
         Department  of  Veteran Affairs,  which is  one of Oregon's
         largest home lenders; even refused  to  lend  money for  loans.
         AuCoin admitted  he had  not even read the bill.

         There are reports  that  S.B. 100 will be  on  the November
         2,  1976 ballot and possibly repealed.

         Reasonable  comprehensive plans  are  desirable;  but  when
         a legislature  mandates  that you prepare  a comprehensive
         plan and then  implies that you  will be sanctioned  by  the
         full  force  and effect of all  state  and governmental agencies
         if not done within one  year;  and  you do  not receive
         the necessary  funds that year from  legislative
         appropriation  then that government  is  unreasonable.   This
         is  acutely  true  to a  small coastal  county which  is
         relatively  poor  in resources  and  a  tight budget.

P. 52    N.C.   L -1

P. 52 - D - L -2 "(2)  the  planning and  siting  of public  sewage
         systems, water supply systems and"  Comment: The
         statutes say that  these items "may  be  of statewide
         significance"  -  the statutes  do not  say   Will  Be.

P. 52    N.C.   L 4-42

P. 53    N.C.

P. 54    N.C.  Blank

P. 55 - D - L 18  "high groundwater11  all  references on this
         page should be changed  to perched.

P. 56-57

P. 58    N.C.  L 1-20
                      191

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P.  58 D - L 21-26  Lincoln County has  a unique  situation  in
         that in areas of septic tank  approval  there  was  no
         approval from the State of Oregon  on the  water systems;
         or if the water was approved  the subsurface  sanitation
         rules were redrafted so you couldn't get  a permit
         or the state changed the cost of permits  and design  of
         septic tanks arbitrarily so it would elevate the costs
         to an unreasonably high price.  In other  words there
         was no justification that the public welfare was bettered
         by the changes in rules and regulations,   (see S &  C )


The following explanation will demonstrate  the  arbitrariness  of
the Oregon administrative Rules, Chapter 30, Division 7.   Sub-
surface and alternative sewage disposal which were effective
September 1, 1975.  Since 1970 there have been  about  seven
different sets of rules,  (see C)

The same D.E.Q. staff in the Terminal  S'ales Building  in
Portland, Oregon (the same building that E.P.A. is in) drafted
al-1 the administrative rules and regulations for subsurface
sanitation and those pertaining to waste water  treatment
(sewage treatment plants).  A dwelling, irrespective  of whether
it is connected to a sewer or septic tank,  will have  the  same
outflow of waste water.  D.E.Q. requires that sewer inteceptor
lines be sized at 250 gallons per capita per day.   Then the
engineering study assumed what they believed might be   reasonable
as 110 gallons per capita per day generated within the home.

Then assume a modest two bedroom home  was built out in the
country on good soil.  The home has a  living room, kitchen,
two bedrooms, a small sewing room, one bath and it was also  de-
cided to enclose the back porch.  D.E.Q. rules  then stipulate
that the sewage flows from this dwelling are 600 gallons  per day
and the septic tank system has to be designed  accordingly.
(see O.A.R. CH. 340, D. 7, pg. 2, 39)

In other words the retired, poor, and  rural minorities are
penalized by the State of Oregon in that they  have to have more
land and drainfields and this excludes and  precludes  them from
living in many rural areas.

E.P.A. Region X report on 1974 needs survey (based on 1973 dollars)
of the estimated back-log of needed sewage  facilities (pre-
liminarly) indicated Oregon has needs  of $3,434,000,000.   If the
total needs of Oregon in dollars as estimated by E.P.A. were
put in the bank at 6% interest, this would  earn $206,040,000
of net spendable income before federal and  state taxes.
                      192

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                                                              16
s\
The market value (gross value)  of all  agriculture products  in
1969 for Oregon was $531,209,146 as shown in area reports part
47, Oregon, U.S. Bureau of the  Census, Census of Agriculture,
1969, Vol. 1.  Presume that today the  value of agricultural
products have risen to say $100,000,000 in Market Value and
that the profit margin is a generous 10% - then the resultant sum
is $10,000,000 of net spendable income before federal  and state
taxes.  The hypothetical annual earnings from E.P.A.'s estimates
(of Oregon's dollar needs in sewage facilities) of dollar needs
would be 20 times the net earnings of  Oregons second largest
industry,  (see OSPRIG reports  - Prime Farm Land. 1973)

E.P.A.'s estimates are to cost  about $1,500 for each man, woman,
and child in Oregon for more sewage facilities, in addition to
what now exists.  Is this realistic?  Perhaps this is one of the
real reasons developments have  to be subsidized.

P. 58    N.C.  L 27-42

P. 59    N.C. L 1-28

P. 59 D - L 29  "A perched water table"  Comment:  Typically when
         the consolidated sands are broken the "perched"
         condition of the water disappears.

P. 59    N.C.  L 30-44

P. 60-65 N.C.

P. 66    N.C.  L 1-17

P. 66 - D - L 18  "owned by the city of Waldport - although this
         treatment facility is  reasonably new, some of the  older
         existing interceptors  could possibly have high infiltra-
         tion problems.

P. 66    N.C.  L 19-45

P. 67    N.C.  L 1-24

P 67 - D - L 25  "various facilities are sized for various
         capacities"  Comment:   Sizing for the collection system
         and interceptors could be sized for their estimated
         life of 50 years (population  10,000 +) presuming the
         cost is not over 10-15% more  by doing such (The benefit
         would be that Highway  101 traffic would not have to be
         disrupted 25 years from now — to redo something that
         should have been done  the first time, and presuming
         Oregon D.O.T. is willing to pay most of the additional
         cost.), then size the  pump stations for 25 years
         (6,000 population) or  their anticipated life.
                            193

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                                                      17
P. 68-78 N.C.

P. 79    N.C.   L 1-34

IP. 79 - D - L  35  "groundwater table"  should read perched
         water table.

P. 79    N.C.   L 36-47

P. 80    N.C.

P. 81    N.C.   L 1-2

 . 81 - D - L  3  "high groundwater"  should read "perched" groundwater

P. 81    N.C.   - L 4-36

P. 81-83 N.C.

P. 84    N.C.   L 1-26

P. 84 - D •- L  27-29  "sized for a 20 year capacity - ie"
         Comment - Interceptors on Highway 101 should probably
         be sized for a 50 year life if Oregon D.O.T. and
       Federal Parks System will pay most of the additional
         cost so the highway and sewage system will not have to
         be disrupted for 50 years.  The pump stations could be
         sized for 25 years.

P. 84    N.C.    L 30-33

P. 85    N.C.

P. 86    N.C.  L 1-2

IP. 86 D - L 3  "appendix A"  error - should read "appendix D"

P. 86    N.C.   L 4-24

P. 87-89 N.C.

P. 90    N.C.   L 1-22

P. 90 - D - L  23  "High groundwater should read "perched groundwater"

P. 90 -D - L 24 "poor tank design"  Comment:  The State of Oregon
         specifies how septic tanks are to be designed—super
         adequate.

P. 90 - D L 25 "inadequate lot size"  D.E.Q. staff by their own
         admission said that a lot had to be 15,000 sq. ft.,
         but when designed before the court-and the 1973 rules
         it appeared that a septic tank could be placed on a
         7,500 sq. ft. lot.  (see C)

                      194

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(,0
    |P. 90  - D - L 25-26  "under such conditions, groundwater resources"
    )         should read "under some conditions, perched water resources"

    P. 90    N.C.  - L 27-28

37 r. 90  - D - L 29  "groundwater as a potable"  should read "perched
    1         water as a potable"

    P. 90    N.C.  - L  30-37

    P. 91    N.C. L 1-26

       91  - D - L 27-33  "The conversion of land from natural
             vegetation to impermeable surfaces will affect run off
             patterns and rates ie"  Comment:  Vegetation removal
             is not the critical factor but the ripping of the
             layered  areas of semi-permeable areas of semi-
             consolidated sands.  Obviously the consultant who advised
             the Crestview Golf Course as to their water problem was
             not contacted by whomever wrote this paragraph.

       91  - D - L 34-40  "Table 18 gives-ie"  This is a comparison
             of low density residential Oregon and a high density
             area of Los Angeles where the smog seldom lifts.  Per-
             haps it could be said that a grape and a basketball are
             round, but they are not the same.

       92  - D Table 18.  Could be but—This Table would need more
             interpertation to have any real meaning to the subject
             study area.

    P. 93    N.C.  - L 1-26

    P. 93  - D - L 27-31  "The waste treatment facilities, interceptors,
             pump stations and treatment plant would be subject to
             disruption of operations or physical damage from
             earthquakes, high groundwater and surface flooding.  Cat-
             astrophic coastal erosion also represents a physical
             hazard in some locations."
             Should read:  The waste treatment facilities, inter-
             ceptors, pump stations and treatment plant might possibly
             be subject to disruption or operations or physical
             damage from earthquakes, perched water tables, and some
             surface flooding.  The coast line is being eroded about
             one foot per year in some areas so this also represents
             a physical hazard in some locations.
             Comment:  Geological hazards in the Portland, Oregon
             area and particularily the S.W. Hills of Portland have
             many times more probability of facilities disruption.

    P. 93    N.C.  - L 32-39
                            195

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|p.  94  -  D  - L  1-2  "high groundwater and flooding"  should read
         "perched  groundwater and occasional flooding"

 P.  94  -  D  - L  3-6  "groundwater and heavy rains have caused
         problems  with infiltration"  Comment:  Perhaps the
         interceptor  lines are buried below the flood plain,
         which would  be the basic cause of high infiltration
         during  high  tides, heavy rains, and together with a
         seiche.

 P.  94    N.C.  - L 7-11

 P.  94  -  D  - L  12-19.   "In order to reduce the potential — ie.—
         ie__against  groundwater infiltration.  Comment:.  The
         person  who wrote this paragraph is presuming that the
         interceptor  lines are going to be buried below either
         sea level or the flood plain.  That person assumed the
         same  situation for the subject sewage lines as the
         Waldport  lines.  Not so.

 P.  94    N.C.  - L 20-43

 P.  95-96 N.C.

 P.  97    N.C.  L - 1-7

|p.  97  -  D  - L  8  "its  historic integrity be harmed"  Question:
         Please  explain how an asphaltic road bed has historic
         integrity?

 P.  97  -  D  - L  9-32 Question:  Was the consulting archeologist
         "on call" when the City of "Port!and decided to con-
         struct  the boating and parking facility at the north
         end of  the St. John's Bridge in Portland, Oregon?
         We are  concerned with areas of archeological significance,
         but would not like to think that we are getting all
         the preferential treatment.

 P.  97    N.C.  -  L  33-35

 P.  97  -  D  - L  36-42   "Sewage facilities require land —-ie—ie
         excluded  from this use."  Should read:  Sewage facilities
         require land and the removal of some native "vegetation
         and displacement of some wildlife.  'Removal of some
         habitat will affect wildlife, both directly and indirectly.
         Subsurface dwelling and sedentary mammals, amphibians
         and reptiles at facilities locations might be destroyed
         by construction activities.  Some birds, mammals and
         reptiles  that periodically use facilities sites might
         be excluded  from this use.

 P.  98    N.C.
                      196

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P.  99    N.C.  - L 1-4
P.  99 - D - L  5  "will  eliminate"   Should  read  " will  reduce  some"
P.  99 - D - L  5 "and some local"   Should read   "and will  displace
         some  local"
P.  99    N.C.   L 6
P.  99  - D - L 7  "will be destroyed"   Should read "might be
         destroyed"
P.  99 - D  - L 8  "fauna reduced"   Should  read   "fauna possibly
         reduced"
P.  99    N.C.  L 9-19
P.  99 - D - L  20  "in the loss  of  vegetation -  ie  — wildlife
         species."  Should read "in the loss of some vegetation
         and displacement of some  associated wi1dlTfe  species.
P.  99 - D - L  21  "Rare and endangered species"  Should read
         "Threatened & endangered  species"
P.  99 - D - L  22 "Rare"  delete rare
P.  99 - D - L  23 " possibly threatened ie" delete (possibly)
         Then  say:  "threatened might  occur within the s£udy
         area"
P.  99    N.C.  L 24-25
P.  99 - D - L  26  "and may occur"   Change  to "  and might occur"
P.  99    N.C.   L 27-28
P.  99 - D - L  29-39  Refer back to the rewritten section on
         "Threatened or Endangered Species" Comment:   Neither the
         Fisher, White-footed Vole, nor Flammulated Owl are on
         either the U.S.F.W.S.  or  Oregon Wildlife  Commission
         current list of threatened or endangered  species list.
P.  99 - D - L  34-39 delete  "The while-footed Vole - ie — i&
         water main construction activities."
P.  99 - D - L 40  "The greatest impact should read "   any probable
         impact on threatened or endangered wildlife is most
P.  99    N.C.   L 41-43
P.100 - D - L 1  "facilities, will cause"   should  read  "facilities,
         might cause"
                     197

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     P.100    N.C. L 2-3
     P.100  - D - L 4  "now supports - ie"  should read  "might
              support.
              then delete spotted owlsr
              then delete "and the white footed vole"
     P.100 D - L 5  "will be reduced"  should read  "might be reduced"
     P100 L - 5&6  "The more substantial impact ie-"  should read
              "as a comparison, the minimal impacts of full
              sewering of the sanitary district as provided for in
              alternatives 1 through 5 will be somewhat more than
              alternatives 6-7,  Upon the threatened and endangered
              species.
     P.100 D - L 9-15  "The impacts on - ie - ie — decisions on
              land use.  Delete in entirity.
     P.100    N.C.  L 16-40
     P. 101-106  N.C.
     P.107    N.C.  L 1-19
13 |p.107 D - L 20  "facilities has been"  Not correct - should be
    •         "facilities can be"  (see SB 100, Oregon 1973)
 ' ' IP.107 D - L 21-43  Comment - This is a discussion
     P.107 D - L 44  "The area cannot be made" should read  "The
              area may not be made"
     P.108-111   N.C.
     P. 112   N.C.  L 1-13
     P. 112 D - L 14  "district will" should read  "district might"
     P. 112 - D - L 15  "instead will"  should read "instead might"
     P. 112   N.C. 116
     P. 112 - D  L 17 "district will" should read "district might"
     P. 112   N.C. L 18
     P. 112 - D - L 19  delete (this) increased
     P. 112 - D - L 19  "growth will"  should read "growth might"
     P. 112 - D - L 20 "profound impact"  delete profound
                         198

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                                                        22
P. 112 D - L 21 - 29  Comment:   83% of the traffic  increases  are
         generated from Oregonians  outside the coastal  region.
         Traffic could be decreased on the coast by giving
         and allocating and restricting the coastal parks which
         appear to be the attractive nuisance.

P. 112   N.C.  L 30-36

P. 112 - D ?  L 37  "districts will cause"  should read  "districts
         might cause"

P. 112 - D - L 38-41  Comment:  check all  the data again--
         particularily the zoning ordinances.

P. 113-114   N.C.

P. 115 - D - ability to pay.  Comment:  their net spendable income
         may be higher.

P. 116 - D - L 19  "There would be "  should read  "There could be"

P. 116   N.C. L 20-37  Comment:  Waldport alternative # 5 could prove
         to be more expensive than projections show.

P. 120 - D - Table 25 should be redone

P. 121   N.C. 1-18

P. 121 - D - L 19  "high groundwater"  should read"perched groundwater"

P. 122   N.C. Blank

P. 123   N.C.  L  1-18

P. 123 - D  - L 19 "high groundwater:  should  read  "perched groundwater"

P. 123   N.C.  L  20-24

P. 123 -  D  - L 25   "of a great  population" should read "of a
         population  increase"

P. 124   N.C.  Blank

P. 125   N.C.  L  1-10

P. 125  -  D  - L  11  "The  secondary  effects"   should read "The
         possible secondary effect"

P. 125  -  D  - L 11  "growth will  result"   should read   "growth
          might result"

P. 125  -  D  - L  12  "The  conversion"   should  read  "The possible
          conversion"
                     199

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                                                          23
P.  125 - D - L 13  "reduction  in"  should read  "possible reduction in"

P.  125   N.C.   L 14-16

P.  125 - D - L 17-19.   Comment:   This area is  apparently properly
         planned, but certain  individuals in Salem,  Oregon  seem
         to perceive the situation in a different light.

P.  126   N.C.   Blank

P.  127   N.C.   L 1-8

P.  127 - D - L 9 "must be dealt"  should read "should be dealt"

P.  127   N.C.   L 10-12

P.  127 - D - L 13  "Goals finally" should read "Goals that might
         finally be"

P.  127   N.C.   L 14-15

P.  127 - D - L 17  "goals relate"  should read  "goals might relate"

P.  127 - D - L 17 "coastal environments to be  most"  should read
         "coastal environments that might be"

P.  127   N.C.   L 18

P.  127 - D - L 19 "(C) beaches and dunes." Comments:  Dunes have
         only been mentioned about five other  times  in the entire
         report (other than relating to habitat of wildlife) and
         in those instances references to dunes was  on legends on
         pages 16, 19, and 20.  Webster says:   dune, N.  A hill
         or ridge of sand piled up by the wind.

         Figure five on pages  19  & 20 doesn't  show any dunes on
         the vegetation and land  use maps even though the legend
         is keyed for sand dunes.   Question:   How many sand dunes
         did E.P.A. count on their extensive tours of the study
         area?

P.  127 - D - L 20-23  Comnent:  Did E.P.A. on  their  extensive
         tours of the county find:
              (1) a court house?
              (2) a planning staff within the  court  house?
              (3) An existing  comprehensive plan of  the entire
                  county?
              (4) A set of zoning ordinances  (No. 34)?
              (5) Minutes of planning commission meetings showing
                  the intelligence, diligence, foresight, and
                  ability of the  staff and commission?
              (6) Minutes of the  meeting of the Lincoln County
                  Comnjssioners?

         See Federal Register  Vol. 40, No. 72, Part  III, part 6,
         $ 6.202 - "E.P.A. is  responsible for  ensuring that
         E.I.S.'s are factual  and comprehensive"  (underlined for
         emphasis)
                       200

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                                                     24
OQ
O
         See part 6,  f 6.304 body  of E.I.S.  "It  (the  E.I.S.)
         shall  be prepared using a systematic, interdisciplinary
         approach and shall  incorporate  all  relevant  analytical  dis-
         ciplines to  provide meaningful  ancf factual data,  information,
         and analyses.
           Webster says:   inter -  to lace  together
                          discipline - a branch  of knowledge  in-
                          volving  research.
         Question:  How much research did  E.P.A.  do?   By whom?

P.  127 - D - L  25-27   Would E.P.A. take  notice of the county
         zoning ordinance, the study area, and the Siuslaw
         National Forest.   (Note:   they  all  exist)

P.  127 - D - L  28-33     E.P.A.  should again  note that the  same
         discussion that applied to p. 127  L 20-23 applies to
         this section.

P.  127 - D - L  33-36   Comment:   L.C.D.C. might or might not
         designate the planning and siting of a  sewage system as
         a matter of state wide significance.
         Comment:  Mr. L.B.  Day wrote a  letter October 30, 1975
         to Mr. John  Vlastelicia of E.P.A. at 1234 S.W. Morrison
         which  seems  to tell E.P.A. that land use implications of
         this (S.W.L.C.S.D.) area  are of a local  and  state
         concern.  Is E.P.A. going to tell Mr. L.B. Day what  he
         is or is not going to do?  He is  the Chairman of  L.C.D.C.

P.  128 - D - L  1-5  Comment:  Again refer  to Mr.  L.B. Day's letter
         of October 30, 1975—Is E.P.A.  telling  Mr. Day what  he  can
         and cannot do?

P.  128   N.C.  L 6

P.  128 - D - L  7-12  "sanitary district ordinances favor—ie—
         Comment:  S.W.L.C.S.D. doesn't have any such ordinances.
         Even if it did the ordinances would not be discriminatory.

P.  128 - D - L  10-12  E.P.A. should take notice  that  the area is
         zoned and there is adequate open  space.

P.  128   N.C. 13-24

P.  128 - D - L 25-28  The last one - "What legal  assurance will
         there  be from L.C.D.C. that no  new sewer hook-up  will
         take place prior to the completion of a comprehensive
         plan for the southwest Lincoln County area?"
           The Answer:  When E.P.A. follows  the  Federal Register
         in writing and then will  write an unbiased E.I.S.;
         then at that time E.P.A.  will be  deserving of an  appropriate
         answer.

No comment on Bibliography etc. pg. 129-135 and  appendixes.
                   201

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                CHRONOLOGY OF S.W. LINCOLN COUNTY SEWER DISTRICT
November 5,  1972-



November 13, 1972-
December 1973-
 11:00  PM  news T.V.      •
 McCall  says  "I'm going to do something in Lincoln County."


 Governor  Tom McCall instructed the Oregon State Health
 Division  and the -Department of Environmental Quality to
 review the water, sewer and septic tank problems in
 Lincoln County  and to issue a report by January 15, 1973.
 (See II - 1  paragraph 2 "Lincoln County Survey, Oregon
 State  Health Division January 15, 1973)


 The Southwest Lincoln County Sanitary District was formed
 with a  five-member elected board of commissioners.  The
 district  was formed because of recommendations of
 Governor  IlcCall's report  (January 15, 1973) which states:
 "The housing density and base population in these areas
 (ie Walciport-Yachats) are probably sufficient to support
 a  community  sewage system, and these communities should
 be encouraged to work toward that end.  In the other areas
 mentioned, a detailed community survey should be conducted
 during  the summer months of 1973 in order to precisely
 locate  the extent of the problems and recommend either
 annexation or the construction of separate sewage
 facilities.  In those cases where the density of develop-
 ment is not  high enough to make community sewage
 facilities feasible and where the failures cannot be
 corrected by subsurface means, action should be taken to
 form local or county service districts to eliminate the
 problems."   (see II - 25 & 26 - "Lincoln County Survey,
 Oregon  State Health Division, January 15, 1973)
June 30, 1974-

September 1974-


October 1974-
Draft report by Robert E. Meyers submitted to S.W. L.C.S.D.

Facilities plan by Robert E. Meyers, Inc. - submitted


S.W. Lincoln Sanitary S.D. Plan submitted to D.E.Q.
(Note:  This plan had been in D.E.Q.'s office and
according to a D.E.Q. interoffice memo dated March 5,
1975- from Fred M. Bolton to H. L. Sawyer, P.O. Curran
and C.P. Hilbrich.  They (the sewer district) are con-
cerned because of no_ response (from D.E.Q.)
December 14, 1974-
Decenber 18,  1974
Acknowledgement of Notice of Intent
Oregon Project Notification & Review System - State
Clearinghouse - program review and comment on project
#7412 2 330.  S.W. L. C. S. D.


Environmental assessment held Wednesday Decerrber 18, 1974,
public meeting at Angell Job Corp. Center south of
Waldport for S.W. L.  C. S. D.
                                        202

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January 10, 1975-
Clearinghouse Review Staff Report
(page 4, paragraph 3)
IV.  Summary and conclusions.
"It is the opinion of staff that no unacceptable or
overriding adverse environmental effects will result from
the project.  Moreover, it has been demonstrated that
the project represents the most cost effective approach
in solving the wastewater disposal needs of the district,
without working to the detriment of future sewage system
development in South Lincoln County.  Since the project
appears to be agreeable to all parties concerned, it is
recommended that the Yachats alternative receive approval."
January 10, 1975-
Oregon District Four, Council of Governments,
240 N.W. 6th. Street  Corvallis, Oregon
Notification to the S.W. L. C. S. D. of the January 20, 1975
meeting in the Lincoln County Courthouse, Newport, Oregon,
at 1:30 P.M. concerning clearing house reviews.
January 17, 1975-
Notification to S.W. L. C. S. D. that S.W. L. C. S. S.
PNRS #74122330—the state clearinghouse has completed
its review.
Paragraphs 3 & 4
"We are pleased to add our approval, subject to appropriate
review at the local level, including a public hearing."

"A copy of this letter and attachments should accompany
your application to the federal agency as evidence of your
having complied with OMB A-95."
January 20, 1975-
S.W. Lincoln County Sanitary District application for a
$1,800,000 federal grant recommended for favorable
approval by Oregon District Four, Council of Governments.
January 24,  1975-
Director of D.E.Q., Kessler R. Cannon states-paragraph 3
(response to citizen letters)
"We are aware of the progress that is being made toward
the orderly solution to the subsurface disposal problems
by the Southwest Lincoln County Sanitary District.  The
department has committed $24,600 to the District for
its sewage study and we will shortly be ranking the
proposed sewage project on our priority list for future
federal construction grant funding.  The anticipated
project will provide relief for the local situation and
we will be continuing our support of your efforts in this
regard."
                                         203

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February  4,  1975
February 19, 1975
Itfarch 5, 1975
March 18, 1975

June 27, 1975
Jaly 31, 1975
September 3, 1975
Notification to S.W^C.S^D, tha.t "The
Executive board of the Oregon District 4 Council
of Governments, at its meeting in January 30,
1975, voted to ratify the action taken by the
Lincoln Subdistrict."   (Recommendation of
favorable approval for a $1,800.00 federal
grant to construct sanitary sewage facilities
in S.W. Lincoln County Sanitary District)

Fred M. Bolton and Larry Lowenkron of D.E.Q.
staff attend S.W.L.C.S.D. meeting at Camp
Angel work center.
Discussion consisted of:
   1.  Public hearing on proposed sewer project
   2.  March 18, 1975, $700,00 bond election
   3.  Sewage problems with state parks

Interoffice Memo
Fred N. Bolton MEMO to H.L. Sawyer, P.O. Curran
  and C.P. Hilbrich
Subject:  S.W. Lincoln County  (received March 6
          1975)

Paragraph 6- We intend to support the effort
of the District by reviewing health problems
in the area.  We cannot change their priority
points  (49th on the new list)  just to get
approval for state parks (an idea suggested)
Paragraph 7-As their plan has been since Octobe
1974, a review and comments are necessary,
They are concerned because of no response.
(The sewer district)

S.W.L.C.S.D. bond election passes 228 to 101

Agenda item D, June 27, 1975
E.Q.C. meeting
Subject:  Sewage works construction grant
priority list for fiscal year 1976.
Priority list FY 1976
"This permits the inclusion of projects
1 thorugh 129 within the current (funding
limitations.
S.W.  Lincoln CO. S.D. assigned a priority
number of 130.

Bill Sobolewski of E.P.A. called Lew Powell
to notify him that E.I.S. would be decided
by the regional administrator.

E.P.S. Meeting S.W. Lincoln County S.D. sewer
District St. Lukes Episcopal Church-Waldport,
Oregon.
                               204

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September 11, 1975
September 12, 1975
September 23, 1975
September 30, 1975
October 10, 1975
April 20, 1976
Newspaper article by John Hayes concerning
E.P.A.'s requirement of an E.I.S.

E.P.A.'s Richard R. Thiel, P.E. Chief,
Environmental Impact Section.  Letter to
Ms. Jean Dickett, Secretary, S.W.L.C.S.D.

Memo from E.P.A. Roger Mochnick to Dick Thiel
E.P.A concerning S.W.L.C.S.D.

Notice by E.P.A. of intent to prepare an
E.I.S. on S.W.L.C.S.D signed Edwin Coate

P.D. Curran of D.E.Q. to Hal Brauner with
cc to Loren Kramer  (Director of D.E.Q.) and
Halrold L. Sawyer.

"At Kramer's request, I am enclosing a potposrri
of informational nuggets related to the S.W.
L.C.S.D. present situation.'" As you probably
know, E.P.A. decided to perform an E.I.S. on the
adjacent districts of S.W. L.C. and Bay to
Bay S.D.

Release of Draft- E.I.S.

The public hearing will be held on June 2,
1976 at 7:30 p.m. at the Angell C.C.C.-
4 miles south of Waldport on U.S. 101.
Comments received through June 14, 1976
will be considered.
                                205

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Response to Comments from Minor & Yeck


 1.  Table corrected.

 2.  Zoning map on page 49, Figure 6.

 3.  Comment noted.

 4.  Comment noted.

 5.  Terminology is according to Environmental Geology of Lincoln
     County, Oregon, 1973, Bulletin 81 prepared by the Department
     of Geology and Mineral Industries.

 6.  If that were the case, septic systems would be installed
     as seepage pits, which are installed vertically.  Seepage
     pits have been known to fail within the district in the
     past.

 7.  Comment noted.

 8.  See response to comments (#2) from Carl Trowbridge &
     Associates, Inc., page 272.

 9.  Comment noted.

10.  Comment noted.

11.  Comment noted.

12.  Comment noted.  See response to comments (#4) from
     Carl Trowbridge & Associates, Inc., page 272.

13.  Comment noted.

14.  Comment noted.

15.  This subject was considered under Socio-Economic features —
     page 44-53.

16.  Comment noted.

17.  It is the responsibility of the EIS to note any and all
     effects on park lands, archeological or historical resources.
     What happened in Portland,  Oregon, has no bearing on this
     project.

18.  Comments noted.
                             206

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19.  Answers to questions:

     (1)  Contract was awarded by technical qualifications and
         a bid price.  Bidders were:   Environmental Science,
         Inc.; Woodward/Clyde, Inc.;  Michael Baker, Jr., Inc.;
         James M. Montgomery, Inc.; Wilsey & Ham, Inc.;
         Stephens, Thompson & Runyan, Inc.; Environmental
         Quality Analysis,  Inc.,; and Jones & Stokes Associates,
         Inc.

     (2)  The EPA Region X recommended Jones & Stokes Associates,
         Inc., based on technical proposal evaluation by an
         evaluation team based on set criteria and a fixed price
         contract.

     (3)  Jones & Stokes Associates, Inc.  —  310 hours
         Gruen Gruen + Associates         —  416 hours
         Don Owen & Associates            —  354 hours
         Approximately 195  hours spent within Lincoln County
         and study area.  Remaining hours for contacts with
         appropriate government agencies and preparing written
         document.  Approximately half of that time was for
         preparation of the EIS for Southwest Lincoln County
         Sanitary District  and the remaining half for Bay to
         Bay Sanitary District.

     (4)  $35,702 to prepare draft and final EISs for Southwest
         Lincoln County Sanitary District and Bay to Bay Sanitary
         District.  Approximate proportion was $17,850 for each.

     (5)  No.

20.  Comments noted.

21.  Changes made to text according to comments.

22.  Average annual precipitation at Newport was based on
     U. S. Department of Commerce data  (1974).

23.  Average year-round temperature tells little of the climate
     of an area and is therefore not used a great deal.

24.  The study area is outlined by the dotted lines and is the
     same as the Southwest Lincoln County Sanitary District
     boundaries.

25.  Change made as requested.

26.  Lint Creek has been added to text — see page 10.

27.  "Substantial", meaning to have a flood hazard worthy of
     identifying as such.
                             207

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28.  See response #5.

29.  Comment noted.

30.  No

31.  Terraces do not extend above 80 feet.

32.  Not according to Environmental Geology of_ Lincoln County,
     Oregon, 1973, pages 25 and 27.

33.  No

34.  Comment noted.

35.  True

36.  No

37.  See Environmental Geology of Lincoln County, Oregon, 1973,

38.  Comment noted.

39.  No sand dune formation within the district.

40.  Comment noted.

41.  Changes made to text as necessary.

42.  Comments noted.

43.  Comments noted.

44.  Comments noted.

45.  See response #19 (3).

46.  Could be.

47.  See comments from Lincoln County Planning Department,
     pages 276-282.

48.  Changes made as mentioned.

49.  No.

50.  Comment noted.

51.  See response #6.

52.  Comment noted.
                             208

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53.   Comment noted.

54.   No.

55.   Comment noted.

56.   Change made as necessary.

57.   Comments noted.

58.   Correct as is.

59.   No.

60.   Comments noted.

61.   Wording changes were made as needed.

62.   Wording changes made as necessary.

63.   Comment noted.

64.   It is not necessary to have interceptors buried below sea
     level or flood plain to have infiltration problems, par-
     ticularly in Lincoln County where high groundwater is
     such a problem.

65.   Highway 101 has been identified as having historical
     significance.

66.   Comment noted.

67.   Wording was changed as necessary.

68.   Wording changes made as necessary.

69.   Correct.  Proper changes made to text.

70.   Word changes made as necessary.

71.   Changes made.

72.   Wording changes made as necessary.

73.   Change made.

74.   Comment noted.

75.   Word changes made as necessary.

76.   Comment noted.
                             209

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77.   Word changes made as necessary.

78.   Changes made as necessary.

79.   No dunes in the area; Figure 5 is correct.

80.   Due to time constraints, existing data are used to prepare
     the EIS.

81.   Comments noted.

82.   Change made as necessary.
                             210

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              ROBERT E. MEYER ENGINEERS, INC.
              Consulting Engineers, Planners and Surveyors
              14250 S.W. ALLEN BLVD.  •  BEAVERTON. ORE. 97005
AREA CODE (503) 643-7531
   1066
May 28, 1976
              Mr. Henry F.  Baldwin,  Jr.
              S.W. Lincoln County Sanitary District
              SRN 886
              Yachats, Oregon 97498

              Mr. Baldwin -

                          some concern has been expressed relative to our
              use of a design flow of 140 gallons per capita per day (gpcd)
              for design of sewerage  facilities in the Southwest Lincoln
              County Sanitary District.

                          We understand the 1000 Friends of Oregon proposes
              that a flow of 100 gpcd be used.  Based on average water
              consumption of 150 gpcd  we estimate  sewage flows will be about
              110 gpcd with no allowance for infiltration. We have allowed
              30 gpcd for infiltration which we feel  is a reasonable allowance
              for the Oregon Coast with the relatively high groundwater table
              which may be encountered.

                          It is our opinion that use  of a design flow of 100 gpcd
              would result in a grossly underdesigned system.

                                              Sincerely,
                                              Lewis N.  Powell
               LNP:bjm

               cc:  Chris Minor
                                         211
CIVIL • SANITARY • MUNICIPAL • PLANNING • INVESTIGATIONS
                                                 REPORTS • CONSTRUCTION COORDINATION • MAPPING • SURVEYING

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                ROBERT E. MEYER ENGINEERS, INC.
                Consulting Engineers, Planners and Surveyors
                14250 S.W. ALLEN BLVD. • BEAVERTON, ORE. 97005
                                          AREA CODE (503) 643-7531

                                          June 8, 1976
                 Mr.  Richard R. Thiel,  P.E., Chief
                 Environmental Impact Section, M/S 443
                 U.S. Environmental Protection Agency, Region X
                 1200 Sixth Avenue
                 Seattle,  Washington  98101

                 Subject:  Southwest Lincoln County Sanitary District
                          Environmental Impact Statement

                 Dear Mr. Thiel:

                        At the public hearing held to discuss the Environmental
                 Impact Statement for the proposed sewerage project in the
                 Southwest Lincoln County Sanitary District,  there appeared to
                 be some  confusion about the financial aspects of the proposed
                 project.
                 Plan
  We would like to call your attention to the Financial
prepared for the District by this firm in December, 1974.
                 This plan presents the recommended method of financing the
                 improvements.

                        The basic recommendations are:
                         1.

                         2.

                         3.

                         4.
      Connection Charge

      Inspection Fees

      Service Charge
$100
  15

   5/month
      Issuance of General Obligation Bonds for
      the local share of the interceptor and
      treatment plant and repayment by Ad Valorem
      taxes.  The initial tax rate is estimated to
      be $1.91/$1000 of true cash value.
                                          212
CIVIL • SANITARY • MUNICIPAL • PLANNING • INVESTIGATIONS
                                                 REPORTS • CONSTRUCTION COORDINATION • MAPPING • SURVEYING

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Mr. Richard R. Thiel
June 8,  1976
Page 2
       5.  Formation of a Local Improvement District (LID)
           to finance the collection system.  The LID will
           include all property within 300 feet of a sewer .
           The assessment will be on an area-benefit
           basis.  The area assessment will be about
           $0.022  per square foot and the benefit assess-
           ment will be about $0.033 per square foot for
           property within 150  feet of the sewer.

       The cost for a 75 x 100 foot lot with an assessed valuation
of $21,000 would  be as follows:

       Initial Costs

           Connection Fee         $100
           Inspection  Fee           15
              Subtotal              $115

           An additional expenditure of from  100 to 500
           dollars  will be required to construct a lateral
           to the sewer.

       Annual Costs

           Property Taxes $1.91x21 =  $40.11/year

           LID Assessment -
           $412.50 for 20 years at 7% =   38.94/year

           Sewer Service Charge -
           $5x12                   =   60.00/year

              Annual Cost              $139.05

              Monthly Cost             $  11.59
                         213

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Mr. Richard R.  Thiel
June 8,  1976
Page 3
       It should be noted that the annual cost to a property
owner with an annual income of less than $15,000 per year
would be reduced by the State of Oregon's Property Tax Relief
Program .
                           Sincerely,
                           Paul F. Ehinger, Jr., P.E,
                           Project Engineer
PFE:jm
cc: Mr.  Chris Minor, Attorney
    Mr.  Bud Baldwin, Southwest Lincoln County
       Sanitary District w/copies for Board Members
                        214

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               ROBERT E. MEYER ENGINEERS, INC.
               Consulting Engineers, Planners and Surveyors
               14250 S.W. ALLEN BLVD. •  BEAVERTON. ORE. 97005
                                          AREA CODE (503) 643-7531
   1066
                                          May 24,  1976
              Mr. Richard R. Thiel,  P.E. Chief
              Environmental Impact Section M/S443
              U.S.  Environmental Protection Agency, Region X
              1200 Sixth Avenue
              Seattle, Washington  98101

              Subject:   Draft Environmental Impact Statement
                        S.W. Lincoln County Sanitary District

              Dear Mr.  Thiel:

                     The following are comments we wish to make about
              the Draft E.I.S. for the Southwest Lincoln County Sanitary
              District.
                                                  RECEIVED
              General Statement

                     The Draft E.I.S. refers to the Southwest Lincoln County
              Sanitary  District Area as rural.  Is it truly rural or is this the
              determination of the author?  Page 42  states that over one-half
              of the District area is subdivided.  Page 111 states a present
              population of 2000 to 2700.  This is an urbanizing area.
               1.
Summary Section
                      A.     Page viii - Alternative 5 cost is listed at $5,290,400
                            in the text - not $5, 140,400.

                      B.     Page viii - Alternative 7 will have long-term impacts
                            in that increased energy (fuel oil) will be used to pump
                            and transport septic tank wastes.

                      C.    Page ix  - No mention is made  in the summary of
                            Alternative  7 of the problems and costs involved with
                            continued use of drain fields.   These will continue to
                            fail and cause groundwater and ground surface
                            contamination by sewage.  Pumping of septic tanks two
                            or three times a year will not prevent this problem.

                                         215
CIVIL • SANITARY • MUNICIPAL • PLANNING • INVESTIGATIONS
                                                 REPORTS • CONSTRUCTION COORDINATION • MAPPING • SURVEYING

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Mr. Richard Thiel
May 24,  1976
Page 2

       D.    The correct name of our firm is Robert E. Meyer
             Engineers,  Inc., not as  listed.

2_.	Introduction Section

       A.    Page 3 - On June 27, 1975, a presentation challenging
             the low ranking of the project was also made by the
             District.

3_.	Environmental Setting^

       A.    Page 25 - The Water District supply and storage facilities
             were expanded in 1974-75 by the Dicks Fork Project.  The
             Project added an intake,  settling basin and 200,000 gallons
             of storage.

       B.    Page 27 - Of the six examples of sewage problems listed,
             Items 2 and  3 are located east of Highway 101.

       C.    Page 37 - Tables 7, 8 and 9 do not include 1975 figures.
             Using only  up to 1974 may be misleading.

4_.	Alternative Wastewater Treatment Facilities

       A.    Page 80 - (Also see Item I C) Alternative 7 - District
             Maintenance Septic Tank.   How would septic tanks be
             inspected?   What criteria would be used to determine
             when  to pump ? No mention is made of costs to maintain
             drain fields  (if they can be  maintained in working order).
             How and under what circumstances would new systems be
             allowed where they presently are denied?

             It would not be possible  to  pump a great number of tanks
             and use them as storage  vaults without the use of many
             pumping trucks.

             This alternative is not presented so as to be comparable
             to the other alternatives. It would be difficult and
             expensive to do and would not improve water quality.
                          216

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Mr. Richard Thiel
May 24,  1976
Page 3
5.    Analysis of Environmental Impacts of the Alternatives

      A.   Page 92 - Table 18 - "Urban and  Non-Urban Run-off
          Emission Rates" .  The source of data is listed as
          California State Water Resources Control Board.
          Would this  table hold true for Oregon and especially
          the southwest Lincoln County area ?

      B.   Pages 95 and 96 - Sewage sludge incineration is
          discussed.   The District is not considering incineration
          for sludge disposal.

      C.   Pages 115 - 117.  Ability to Pay - The E.I.S. discusses
          the cost of  a sewer system to the homeowner and the
          financial ability of the average homeowner in the
          District. Additional costs to be considered are:

          1.   Many homeowners face extensive septic tank
              drainfield repair or replacement costs.

          2.   Some septic systems can not be repaired or
              replaced.

          3.   The State does have the option to close a house
              where a septic system cannot function properly
              and causes a health hazard.

          4.   Septic  tank repair costs of $500 to $1000 could be
              faced by some homeowners several times within the
              20 year project planning period.

6.    Unavoidable Adverse Impacts

      A.   Page 120 -  Table 25. Alternative 7 - Septic Tank
          Maintenance.  As presented, Alternative 7 will have
          the same degree of Adverse Impacts as Alternative 6,
          No Project.
                         217

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Mr. Richard Thiel
May 24,  1976
Page 4
7.    Irreversible and Irretrievable Commitments of Resources

      A.  Page 125 - Last Sentence.  This appears to be only the
          opinion of the author and is unclear as to its basis.
          The area  is zoned for residential use.  This  appears
          to be good use for the area.
      If you have any questions about these comments,  please
feel free to ask.

                              Respectfully Submitted,
                              Lewis N.  Powell
                              Project Partner
LNP:bjm

cc: S.W. Lincoln County Sanitary District
                        218

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Response to Comments from Robert E. Meyer Engineersf Inc.


Letter to H. Baldwin, Jr., May 28, 1976

1.   We concur with your statement.



Letter to R. Thiel, June 8, 1976

     Comments noted.



Letter to R. Thiel, May 24, 1976

1.   In the true sense of the word, the Southwest Lincoln area
     is neither rural nor urban; however, it fits the definition
     of rural more so than it does urban.  According to Webster
     the definition of rural is "of or relating to the country
     or characteristic of the country".  It would probably be
     more appropriate to consider it an "urbanizing" area.

2.   A.  Correction made.

     B.  Addition made.

     C.  The problems  (impacts) associated with Alternative 7
         were identified on p. xi.  Costs will need to be
         further analyzed at a later date.

     D.  Correction made.

3.   A.  Addition made.

4.   A.  Addition made.

     B.  Comment noted.

     C.  At the time of data compilation, figures  only
         up to the year 1975 were available.

5.   A.  A broader analysis of this alternative and others
         will be undertaken following the necessary compre-
         hensive septic system survey of the district.
                            219

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6.   A.  Changes have been made to text relating to this table.

     B.  While the district may not be considering incineration
         for sludge disposal, it was necessary to identify the
         impacts of the alternatives disposal methods considered
         in Chapter III, particularly since the specific method
         of sludge disposal had not yet been determined.

     C.  Such cost analyses will be discussed in depth if it
         is determined after the comprehensive septic tank
         survey that septic tank maintenance is a feasible
         alternative.

7.   A.  The degree of adversity of several impacts varies
         with Alternatives 6 and 7.

8.   A.  This last sentence is based on the following conclusions:

         - Allowable minimum lot sizes have not been coordinated
           with the needs for proper sewage disposal using septic
           tanks and leachfields.   While lot sizes are adequate
           for housing needs, sufficient area has not been pro-
           vided to support septic systems plus replacement area.

         - Many road systems have been developed with no fore-
           thought to maintenance or responsibility,  resulting in
           rutting and sometimes impassable roads to houses and
           lots.

         - Areas have been subdivided in the past with little
           thought of natural constraints such as high ground-
           water (in some cases standing water), steep slopes
           or some other restriction prohibiting home construction,

         - For all intents and purposes, the entire district is
           zoned for residential or commercial use (except for
           737 acres of state parks plus 120 acres of U. S.
           Forest Service land).  It is unlikely that all re-
           maining land is suitable for residential use.

           These problems in concert with others, could create
     a situation where population growth would have a particular
     adverse effect on the area.
                             220

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                      1OOO FRIENDS OF OREGON
ADVISORY BOARD

  Tom McCall, Chairman
    Salem
  Eric W. Allen, Jr.
    Medford
  Ray A. Atkeson
    Portland
  Martin H. Buchanan
    Milton-Freawater
  Elizabeth C. Ducey
    Portland
  J. W. Forrester, Jr.
    Astoria
  John D. Gray
    Portland
  Glenn L. Jackson
    Medford
  Hector Macpherson
    Albany
  Pat Straub
    Salem
  Thomas Vaughan
    Portland
  Mrs. Robert C. Warren
    Portland

BOARD OF DIRECTORS

  Wade Newbegin, Jr., President
    Clackamas
  Allen Bateman, Vice President
    Klamath Falls
  Elizabeth K. Johnson Secretary
    Redmond
  Joe D. Kershner, Treasurer
    Portland
  John E. Bryson
    Portland
  Claudia Burton
    Salem
  Steven H. Corey
    Pendleton
  John E. Frohnmayer
    Portland
  Alfred A. Hampson
    Portland
  Peter McDonald
    Wiisonville
  George Thompson
    Neskowin
  Martin T. Winch
    Bend

  Henry R. Richmond, III
  Director
                            June 11, 1976
 Dr. Clifford V. Smith, Jr.
 Regional Administrator
 Environmental Protection Agency
 1200 Sixth Avenue
 Seattle,  Washington  98101

 Attention:   M/S 443
 RECEIVED

JUN 1 4 1976
  rrp*  rr***
 Re:  Southwest Lincoln County Sanitary District
      Draft Environmental Impact Statement

 Dear Dr.  Smith:

      1000 Friends  of Oregon  submits  the following
 comments  on the Southwest Lincoln County Sanitary
 District  Draft Environmental Impact  Statement.

      We find that  the draft  statement  fails to
 justify a $5.5 million sewerage treatment and
 disposal  system.   We find also that  each of the
 five "viable" alternatives would violate the
 statewide planning goals and induce  strip develop-
 ment along seven miles of the Oregon Coast.

      V7e note that  these comments are based almost
 entirely  on information contained in the DLIS.
 The purpose of the NEPA process is to  generate
 information about  the impact of a proposed project
 for responsible decision-making.  That the DEIS
 raises the questions addressed in these comments
 indicates that the NEPA process is working as
 intended.

'I.   DRAFT EIS FAILS TO DEMONSTRATE  A  NEED FOR  A
*      $5-$6 MILLION SEWERAGE  TREATMENT  AND DISPOSAL
      SYSTEM.
i      —_———_

      A-   DRAFT FAILS TO DOCUMENT EXISTENCE OF
»           SERIOUS DISPOSAL PROBLEM

      Septic tank surveys along the coast in Lincoln
 County show failures within  the Southwest Lincoln
 County Sanitary District boundaries.   A 1968 survey
                                     221
        3709S.E. BELMONT  PORTLAND, OREGON 97214  TELEPHONE: (503) 233-5408

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 Dr.  Smith,  Jr.
 June 11,  1976
 Page two
|found eight failures  in the  district (DEIS,  p.  2).   A 1972  survey
'found a "continuation"  of  the  1968  problems  (DEIS,  p.  2).   Both
I surveys indicated  that  the problems were  clustered  at San Marine
• and the area from  Yaquina  John Point to Waconda Beach (DEIS,  p. 26)

      A 1975 DEQ  report  reviewed past surveys and summarized
 problems.   That  list  of historical  problems  is  at p.  27  of  the
 DEIS.

      However,  a  1974  DEQ survey of  the  Yaquina  John Point area
 indicated  correction  of most of the area's documented problems:

      "Those septic systems found in violation during the
      1972  survey have been for the  most part corrected
      by pumping  out the septic wastes and/or relocating
      seepage pits  or  adequate  leachfields."   DEIS,  p.  27

      Turther analysis indicates that many of the septic  system
 failures were older systems, constructed  prior  to the adoption of
 existing Oregon  state standards for subsurface  sewage disposal.
 These  failures

      "can  often  be eliminated  by repositioning  or expanding
      the leach line length and/or expanding  septic  tank
      capacity.   This  has been  adequately  demonstrated by the
      upgrading of  existing systems  that have failed in the
     past."   DEIS,  p. 75.

Many of the  permit denials (DEIS, p.  55)  have been  based on lack
of  water to  supply a  septic  system,  not potential groundwater
 contamination.

     According to  Lincoln  County Sanitarian  Emmett  Dobey, almost
 all of the existing systems  found to violate county regulations
Lave been  modified and  upgraded,  either by the  addition  of  new
 ]each  lines,  by  the expansion  of septic tank capacity, or by  a
combination  of the two  (DEIS,  p.  79).   Because  a majority of
residences of  the  sanitary district are on a district water supply,
 there  is no  documentation  of well contamination (DEIS, p. 28).

     Thus,  aside from continued system  failures at  Beachside
State  Park,  it is  not clear  from the  information contained  in
 the DEIS that  a  serious groundwater contamination problem exists.
liar does the  DEIS  show  why the few  remaining problems  cannot  be
corrected  by  upgrading.  If  a  serious problem does  not exist
there  is no  justification  for  a $5-$6 million sewerage system.
If  alternative methods  are available  to correct the failures
and other  minor  problems without an expensive system  which  will
 induce development, EPA ought  to consider them  closely.
                               222

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Dr. Smith, Jr.
June 11, 1976
Page three
     B.  DRAFT FAILS TO GIVE ADEQUATE CONSIDERATION TO ALTERNATIVE 7

     Alternative 7 calls for sanitary district maintenance of
septic tanks:

     "The District would purchase a septic tank pumping
     truck and be responsible to maintain all septic tank?
     in satisfactory operating condition.  To accomplish
     this, the District would periodically inspect all
     septic tanks within the District, and as required,
     pump the tanks and convey the pumpage to aerobic
     digestion facilities ..." DEIS, p. 80-81.

     Presumably, Alternative 7 would combine with continued
upgrading of existing septic systems and increased minimum lot
sizes.  Total capital costs for Alternative 7 would be $310,000,
with a local share of $145,000.  Jinnual operating costs would
be $60,800 (DEIS, p. 81).  This compares with the least expensive
treatment alternative:  capital cost of $5,154,200, with a local
share of $3,141,800 and annual operating costs of $341,700
(DLIS, p. 75).

     There is little social justice in requiring retired persons
on fixed incomes to bear the burden of expensive treatment works
to subsidize development of second homes for seasonal residents.
Lincoln County contains the highest concentration of retired
persons among all Oregon counties.  The median age in the Vialdport
Statistical Division is 4.7 years older than the Lincoln County
median age (DLIS, p. 31)

     The DEIS dismisses Alternative 7 for two reasons.  First,
septic tank maintenance will be expensive ($31,000 per park per
season) at state parks in the district.  Second, although septic
system maintenance solves the problem at present, and would permit
continued development at current levels  (DEIS, p. 80) septic
tank permits and building permits will still have to be denied
in some areas of high groundwater and impermeable soils  (DEIS, p. 81)

     Uiether reason justifies dismissal of Alternative 7.  First,
in the face of huge property assessments  ($b5.13 annually for
assessment and ad valorem taxes alone on 75 x 100 ft. lot, DEIS,
p. 116), connection fees and hookup costs, $31,00 per park per
season doesn't seem so expensive.  That cost can be passed on to
park users, transients who burden treatment facilities at peak
flows, but escape their share of facility costs.  Also, the DEIS
mentions that after failures in 1974, officials at Beachside
Park considered installation of a small package plant.  There is
no discussion about why the plant was not installed or could not
remedy the situation  (DLIS, p. 55).
                              223

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 Dr.  Smith,  Jr.
 June 11,  1976
 Page four
<      The  second reason raises  the  key issue involved in both the
^Southwest Lincoln  County  and the Bay  to Bay Sanitary District
.proposals:   Is  it  proper  to spend  $13 to $14 million of public
 funds (for both projects)  to overcome inherent groundwater and
 soils limitations  in order to  render  rural lands  developable at
 urban density?

      The  only limits on development of the 1200 undeveloped,
 platted lots in the  Southwest  Lincoln County Sanitary District
 are  septic system  limitations  (see DEIS, p. 48, for lot analysis).
 Lincoln County  zoning in  the sanitary district sets minimum lot
 sizes of  2,500  square feet (R4 with sewer and water), 5,000
 square feet (R2, E3  with  sewer and water)  and 6,000 square feet
 (Kl  with  sewer  and water).   Lincoln County planning places no
 additional density limits  in the district.   A sewerage system
 will render septic system  limits inapplicable.  Thus, a sewer
 system will expose the entire  district to development on hundred:
 of 2,500,  5,000 and  6,000  square foot lots.

      The  problem which concerns the authors of the  DEIS is not
 present danger  to  the area's groundwater.   There  is no documented
 groundwater contamination  problem  (DEIS,  p. 28).  The "problem"
 is that groundwater  and impermeable soils impede  future develop-
 ment (DLIS,  p.  81, 123).   The  DLIS arrticipates a  groundwater
 problem which would  arise  if development continued  at a rate and
 density possible on_ly_ iff  sewers are installed.  The district
 population projected for year  2020 will not occur unless the
 sewerage  system is installed.

      It is  not  the proper  objective of the Construction Grants
 Irogram to overcome  natural obstacles to development and subsidize
 •-trip development  along the nation's  coastal shorelines.   The
 "urpose of  the  program is  tP clean up the nation's  waters.   Unless
 there is  a  substantial hazard  to the  area's groundwater which a
 z^on-treatinent facility alternative cannot handle, there is no
 justification for  any of the expensive "viable" treatment systems.
 Information in  the DEIS indicates  that proper land  use planning
 (e.g.  larger minimum lot size)  can eliminate groundwater problems
 v.dthout a  waste water treatment system.

      The objective of Oregon's land use planning  program is to
 direct development away from valuable natural resources,  toward
 areas suitable  for development at  minimal public  service infra-
 structure  cost.  A sewerage system whose primary  objective is to
 overcome natural impediments to urban density development in
 rural  areas  conflicts directly vitb the statewide planning goalr-
                               224

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Dr. Smith, Jr.
June 11, 1976
Page five
II.  EACH OF THE FIVE "VIABLE" ALTERNATIVES WOULD VIOLATE THE
     STATEWIDE PLANKING GOALS

     Federal regulations require EPA to determine that a waste
treatment project complies with state law:

     "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 deter-
     mine * * *
     35.925-14:  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

     Thus, before EPA can award a grant to the Southwest Lincoln
County Sanitary District, the Pegiorial Administrator must drter-
mine that the project will comply with Oregon's statewide .!••••'
use planning goals.

     A.  URBANIZATION GOAL

     The statewide Urbanization Goal requires cities and counties
to establish urban growth boundaries around incorporated areas to
separate urban and urbanizable land from rural.  Lands inside the
urban growth boundary are available over time for urban density
development.  Lands outside the urban growth boundary are"rural
lands":

     "Rural lands are those which are outside the urban
     growth boundary and are:
      (a)  Non-urban agricultural, forest or open spaces
     land or
      (b) Other lands suitable for sparse settlement, small
     farms, or acreage homesites with no or hardly any
     public services, and which are not suitable, necessary
     or intended for urban use."  660 Oregon Admin. Rules 10-060

     The Urbanization Goal limits urban development to areas
within urban growth boundaries.  The Goal directs development
toward areas where public facilities and services are already
available or can be provided  economically.  Development on rural
lands must be  "sparse settlement, small farms or acreage homesites
with no or hardly any public  services * * *"  Definitions, 660
OAR i0-060.
                               225

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 Dr.  Smith,  Jr.
 June 11, 1976
 Page six
\      None of the land in the Southwest Lincoln County Sanitary
• District lies within the urban growth boundary of either Waldport
lor Yachats.   (The City of VJaldport contends that its plan fully
 complies with statewide planning goals but the Land Conservation
 and Development Commission (LCDC)  has not yet issued Waldport a
 "certificate of compliance."  The City of Yachats sought and
 received a temporary extension of time for submission of its
 plan for LCDC review.)  Thus, land in the district is "rural
 land. "

      The Lincoln County subarea plans (Alsea Bay and Coastal
 Plans) and zoning designations permit urban density development
 throughout the sanitary district (85-90% is zoned Rl, 6,000 sq.
 ft.  minimum lot size with public v/ater and sewer, or, six to
 seven units/acre).   Septic tank limitations prevent development
 at this density.   Provision of sewer services will render all
 areas served developable at urban density.  The treatment works
 alternatives would violate the Urbanization Goal by inducing urban
 development in a rural area.

      That Lincoln County zoning permits  urban development outside
 the urban growth boundaries of Waldport  and Yachats in apparent
 violation of the Urbanization Goal does  not excuse EPA from having
 to conform the proposed treatment works  to the Urbanization Goal.
 40 CFP 35.925.   Lincoln County is  presently on an LCDC compliance
 schedule which requires compliance with  the Urbanization Goal.
 Approval of a construction grant prior to comnletion of that ore •
 cess will pre-empt and negate the  procesr.

      B-  PUBLIC FACILITIES AND SERVICES  GOAT.

      The statewide Public Facilities and Services Goal requires
 cities and counties to limit facilities  and services in rural
 areas  to the "needs and requirements" of rural areas.  Guideline
 7i2 under the Goal states:

      "Public facilities and services for rural areas
      should be provided at levels  appropriate for rural
      use only and should not support urban uses."
      660 OAR 10-060

      Each of the five treatment works alternatives would support
 urban  uses (five to seventeen units/acre)  in rural areas outside
 the  Waldport or Yachats urban growth boundaries.   Each treatment
 alternative  would provide a level  of services inappropriate in a
 rural  area.   Each of the treatment alternatives would violate the
 Public Facilities and Services Goal.
                               226

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Dr. Smith, Jr.
June 11, 1976
Page seven
     C'  THE PROPOSED TREATMENT FACILITY ALTERNATIVES PRE-L'HPT
         THE LAND USE PLANNING PROCESS

     Inclusion within an urban growth boundary of an area unserved
by urban facilities and services reflects a determination that the
area is needed to accommodate long-term growth and that services
can be provided in an orderly and economic manner.  Lincoln County
can include or urbanize specific areas only after consideration of
seven factors set forth in the Urbanization Goal.  660 OAR 10-060.
Plans to extend public services to a specific area must be coordi-
nated with the designation of urban growth boundaries.  Public
Facilities and Services Goal, 660 OAR 10-060

     In this instance, that process is reversed.  Extension of
sewer services would precede rather than follow a determination
that urban density residential development in the sanitary district
is appropriate and complies with statewide planning goals.
Urbanization woul? follow the interceptor lines. Lincoln County's
comprehensive plan would simply acknowledge that development.

     The EPA may not permit the Construction Grants Program to
subvert Oregon's land use planning program (40 CFR 35.925).  The
Oregon Department of Environmental Quality (DEQ) cannot approve
a construction grant or issue an NPDES discharge permit for a
sewerage system which violates the statewide planning goals.
CRS 197. 18C.
    "The DEIS fails to demonstrate a need for a $5.5 million
waste treatment system.  The DEIS anticipates a water quality
problem which would derive from a development density possible
only if the treatment system is installed.  The objective of a
system appears to be to overcome natural obstacles to urban den-
sity residential development, not to prevent groundwater conta-
mination.

     A non- treatment system alternative exists which would cost
less than one/tenth the cost of the least expensive treatment system
alternative. The DEIS dismisses this alternative without convincing
the reader that septic tank maintenance and upgrading could not
protect the area's groundwater without an impact on area land use
patterns.

     The DEIS proposes treatment systems which would violate the
statewide urbanization and Public Facilities and Services Goals
and undermine Oregon's Land Use Planning Program.

     The DEIS fails to consider adequately alternatives which would
not require sewering the entire district, such as clustering at
San Marine and Waconda Beach and linking other areas with the
Yachats and Waldport systems.

                              227

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Mr. Smith, Jr.
June 11, 1976
Page eight
     We urge closer consideration of Alternative 7 and clustering
alternatives.  We recommend further evaluation of the extent of
subdivision in the district to determine the impact of adoption
of Alternative 7 with increased minimum lot size on land owner-
ship in the district.

                                        Respectfully submitted,
                                        Richard P. Benner
                                        Staff Attorney
RPB/mlr

cc:  Southwest Lincoln County Sanitary District

     Joseph Richards, Chairman
     Environmental Quality Commission

     L. B.  Day, Chairman
     Land Conservation and Development Commission

     Janet McLennan,  Assistant to Governor Straub for Natural
     Resources

     Hal Erauner,  Director
     Land Conservation & Development Commission

     Loren Kramer, Director
     Department of Environmental Quality

     Senator Bob Packwood

     Senator Mark  O.  Hatfield

     Representative Les AuCoin
                             228

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Response to Comments from 1,000 Friends of Oregon


1.   Please refer to the Preface of this final EIS,  pages i-iii.
     Because there appeared to be no fully demonstrated problems
     in Southwest Lincoln County Sanitary District,  the EPA
     requests a comprehensive survey be conducted within the
     district and to prepare a project to solve identified
     problems.

2.   Please refer to comments from the Department of Land Con-
     servation and Development regarding postponement.  There
     appears to be no violation of statewide goals,  since any
     county land use plans prepared prior to the LCDC adoption
     of statewide planning goals "shall remain in effect until
     revised under this act" ORS 197, Section 40.
                             229

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                                                                      APR 2 6 1976

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         U.S.   ENVIRONMENTAL  PROTECTION  AGENCY

                               REGION  X

                           1200 SIXTH  AVENUE

                      SEATTLE, WASHINGTON  98101
REPLY TO   ., . _ ..^
ATTN OF:   M/S 443
        Thor H.  Mork
        Box 6111  Wakonda Beach Road
        Waldport, Oregon  97394

        Dear Mr.  Mork:

             Dr.  Smith  has asked me to respond to your April  26, 1976
        letter in which you request additional information and clarifica-
        tion of  terms used in the Draft Environmental  Impact  Statement
        (EIS) for Southwest Lincoln County Sanitary District  (SWLCSD).
        I  hope that the  following information will assist you  in your
        review of this  statement.

        Page

        vii    Permanent resident refers  to individuals  who reside in the
              district on a year-round basis.

        vii    The 1972 surveys were conducted by the  Lincoln County Health
              Department and the Oregon  State Department of  Environmental
              Quality.   Please refer to  either of these agencies  for par-
              ticulars concerning how the surveys were  conducted.

        viii   The phrase"protection of groundwater refers to the  elimina-
              tion of  inadequately treated wastes which are  discharged
              to groundwater from failing septic tank/drainfield  systems.
              Alternatives  1-5 would provide  an  opportunity  to reduce
              septic tank usage.

        viii   The results of the Lincoln  County  Health  Department  survey
              documented  failing septic  tanks  within  the District.   Al-
              ternatives  6  and 7 evaluate the  impacts associated with the
              continued  use  of septic  tanks.   Continued failing septic
              systems  create a potential  for  the spread of contagious
              diseases  as a  result  of  the discharge of  inadequately
              treated wastes.   These diseases  are  quite often  a result
              of contaminated  drinking water  supplies.
                                    232

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 1     The term "full disclosure" refers to a complete and de-
       tailed discussion in the EIS of the environmental impacts
       associated with various alternative wastewater treatment
       systems.

 1     All studies listed in the Bibliography are existing studies,
       Please see pages 129-132 in the Draft EIS.

 2     EPA does not believe the number of citizens who founded
       the District to be vital to an environmental evaluation.
       The exact number, however, may be available from the
       SWLCSD Board of Commissioners.

 2     Robert E. Meyers and Associates.

 3     Please contact Henry Baldwin, President, Board of
       Commissioners, SWLCSD for a complete list of the names
       of individuals on the Board,

 3     Request for delay in release of the Notice of Intent
       was received by EPA in a letter from the SWLCSD Board
       of Commissioners.

 4-5   The list of issues was  prepared by the Environmental
       Protection Agency.

 4     SWLCSD "officials" refers to the Board of Commissioners.

10     The entire district.

14     Impervious soils and/or improper maintenance are primary
       reasons for septic tank failure.

24     The entire SWLC study area.

24     We see no teference to classification on page 24.

24     Contaminated dune areas are usually evident from surfacing
       sewage.

25     Coundaries should read boundaries.

26     The area studied in the 1973 report included Southwest
       Lincoln  County.  Please contact  the Oregon State Health
       Division for additional  information.
                            233

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 27    Jack Osborne,  Department of  Environmental Quality  (DEQ)

 27    Please contact  DEQ  for  the individual's name.

 27    Due to time requirements we  were  unable to include a map
      of the exact locations  of properties denied septic tank
      permits.  Hopefully, we will be able to prepare such a
      map or include  additional information on this subject
      for the Final  EIS.

 31    We do not have  the  median age of  residents for SWLC, however,
      the figures shown for Lincoln County are sufficient for
      the purpose of  the  EIS.

 32    The District recently reported (April 1976) 1118 total water
      hook-ups.  Of these, 272 are motel units, trailers and tent
      sites (three tent sites constitute one hook-up).  In 1975
      it was reported that of the  total hook-ups 778 are active
      units.  An active unit  is one which used water during the
      year.  EPA's Final  EIS  will  be revised to reflect this
      information.

 33    The assumptions in  this section are the result of a study
      conducted in the project area by  EPA and Gruen and Gruen +
      Associates.

 34    Computations compiled by Robert E. Meyer and Associates
      are detailed in a draft Facilities Plan prepared for the
      SWLCSD.

 35    EPA does not anticipate the need  for a population forecast.
      The projections included  in the  Draft EIS are sufficient
      for our use.  If we find that we  need a forcast at a later
      date it will be prepared.

 40    EPA and Gruen and Gruen + Associates

 40    Owner/operators of the seven motels surveyed.   The names
      are not necessary to our EIS.

 40    The statement represents an observation of three motel
      owner/operators.  Their names are not necessary to our
      EIS.

40    The exact figure is  not available.
                             234

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40    EPA and Gruen and Gruen + Associates

43    The survey includes SWLCSD.  A separate survey was not
      conducted.

46    EPA and Gruen and Gruen + Associates.  February, 1976.

     If we can be of any further assistance please contact our
office.  Substantial comments received on the Draft EIS will be
included in the Final  EIS.  All comments received by June 14, 1976
will be considered.
                             Sincerely,
                             Richard R. Thiel, P.E.
                      Chief, Environmental Impact Section
                           235

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                          MAY 6   1976
H/S 443


Mr. Thor H. Hork
Box 6111 Wakonda Beach Road
Waldport, Oregon  97394

Dear Mr. Mork:

     We are In receipt of your three rnost recent letters regarding
the proposed v/astewater sewerage facilities for the Southwest
Lincoln County Sanitary District.  Two of these letters request
a delay in EPA/s decision for construction grant funds for the
District.  The third letter outlines your'comments on the Draft
Environmental Impact Statement (EIS).  EPA will respond to your
comment letter 1n our Final EIS.

     In your request for delay, you ask EPA to defer Its final
decision beyond the June 14, 1976 date included in the Draft
EIS.  Please note that the June 14 date represents the close of
the comment period on the draft statement, not the date of EPA's
final decision.  Before a final decision can be reached, EPA
must complete the remaining steps required in the EIS process.
These steps include the preparation of a Final EIS which will
Incorporate all substantive comments received on the Draft EIS
along with EPA's responses to those consents.  A recommendation
concerning the best alternative for solving the wastewater problems
within the District will also be included In this Final EIS.  It
should be noted that this recomiTiendation is not the final decision.
EPA, by law, must release the Final EIS to the public for a 30-day
reviev/ period before a decision can be reached.  The following
schedule outlines the remaining steps to be completed before EPA
can announce its fiaal decision.

     Public Hearing                            June 2, 1976
     Close of comment period on Draft EIS      June 14, 1976
     Release Final EIS                         July 26, 1976
     Close 30-day final reviev/ period          August 25, 197C
     EPA's final decision                      August 267$epteniber 1, 1976
                                 238

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     It is further stated in your letter that you believe all
the Information contained 1n the Draft EIS to have been submitted
by particular Individuals from within the District.  This 1s not
correct.  The EIS was prepared by the Entironmental Protection
Agency with consultant assistance.   Individuals contacted within
the District are referenced 1n the document and are listed on
pages 133 and 134.  All the Information contained 1n the Draft
EIS was gathered by the Environmental Protection Agency and
the consulting firm of Jones and Stokes and Associates.  Any
assumptions and conclusions included in the document represent
the views of this agency, unless otherwise stated.

     If we can be of any further asslstence please contact our
office.

                               Sincerely,
                               Richard R.  Thiel,  P.E.
                        Chief,  Environmental  Impact Section
RMOCHNICK:DM:5/6/76

                               239


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Response to Comments from Thor Mork


Letter Received May 4, 1976

 1.  Table 14, page 48, has been changed based on data pre-
     sented by the Lincoln County Planning Department.

 2.  The 2,024 residents should be 815 year-round and 1,225
     part-time residents.

 3.  The figures in Table 4 are based on aerial photo
     interpretation.  The lot size of 85' x 100' is an average
     size.

 4.  The distances on page 7 have been changed.

 5.  Flood hazards typically occur along streams, rivers
     and the ocean.

 6.  Comment noted.

 7.  Comment noted.

 8.  It was felt that the Lincoln County statistics adequately
     reflect the situation in Southwest Lincoln County.

 9.  These figures were corrected.

10.  Comment noted.

11.  Stalls for house trailers and pickup campers are considered
     camping areas.

12.  The figures were based on a survey conducted in 7 motel
     establishments within and adjacent to the study area.

13.  Wording has been changed.

14.  Comment noted.

15.  The comprehensive survey requested by the EPA in this
     preface should conclusively determine project need.


Letter Received May 6, 1976

 1.  The financial plan prepared by the district engineer
     should more clearly identify cost distribution.
                             248

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                      -7
          uir
                         RECEIVED
250

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Response to Comments from Thor Mork
Letter of May 12, 1976

1.   The facilities plan prepared by Robert E. Meyer Engineers,
     Inc. shows aerial photos of the proposed interceptor and
     lateral system.

2.   The EPA is recommending that a comprehensive survey of
     septic systems be conducted in the district in order to
     evaluate the need for a project.

3.   Although there remains a great deal of unplotted land in
     the district, the majority of the parcels are 5 to 20
     acres in size, with few landowners having any major land
     holdings.
Letter Received May 14, 1976

1.   The EIS is not meant to be a total economic analysis, but
     instead is meant to identify some of the likely key impacts,
     The financial plan is designed to completely identify all
     of the economic considerations of the proposed project.
                              251

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-------

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Response to Comments from Thor Mork


Letter Received May 19, 1976

 1.  The draft EIS was released on April 30, 1976 and sent to
     those individuals and groups mentioned on pages xii-xiii of
     the EIS.

 2.  The fact that there will be financial impacts on home-
     owners has been mentioned.

 3.  Please see District Financial Plan for further financial
     description.  The cost allocation and distribution is the
     responsibility of the district and its constituents.

 4.  These are matters to resolve with the sanitary district
     and engineer.

 5.  This fact is presented only as information.  It is not
     of importance in decision making.  The source of the
     statement was from the tentative financial plan regarding
     "Powers of a Sanitary District According to Oregon State
     Statutes".

 6.  At the time of EIS preparation, the draft Financial Plan
     indicated that general obligation bonds would be used to
     pay 25 percent local share.

 7.  The age and capability of the district constituents to
     pay was considered in the impact section page 112-117.

 8.  It would probably be of minor importance with regard to
     EPA decision.

 9.  The question of land use planning and the relationship
     to the sewer district is of major concern and importance
     with regard to the EPA decision.  See comments from the
     Department of Land Conservation and Development.

10.  See page 58 Regionalization for a description of the term.

11.  See Table 17, short-term impacts and letter from Oregon
     Highway Department with regard to timing of construction.

12.  No mitigation measures are needed as it is considered to
     be a beneficial impact.

13.  Mitigation measures are needed and are a condition for
     project grant.
                             254

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14.  These unresolved issues are to make decision makers fully
     aware of some of the questions needing to be resolved by
     the local or state jurisdictions.

15.  That question can only be resolved by the involved local
     and state planning agencies.

16.  EPA has made its decision.  See Preface to this EIS.
                              255

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                                                  P. 0. Box 3^2
                                                  Yachats, Oregon 97^98

                                                  April 28, 1976


                                                                 RECEIVE

Mr. Richard R. Thiel, P.E., Chief
Environmental Impact Section, M/S
U. S. Environmental Protection Agency, Region X                    ,--,.,  -
1200 Sixth Avenue
Seattle, Washington  98101

Dear Mr. Thielt

          Thank you for sending me a copy of the draft of the EIS of the
Southwest Lincoln County Sanitary District.  You and your staff together with
Jones & Stokes Associates, Inc., Don Owen & Associates and Gruen Gruen &
Associates are to be complemented on a job well done.  I have read it
through and feel you have in the short time allowed turned out an excellent EIS.

          I do have a few comments but none are derogative.  In several places
you refer to Agency Creek and the proposed Smelt Sands State Park as being in
the District.  They are both in the Yachats Sewer District.  I think this should
be made clear.  On page 48 listing subdivisions, "Wakeeturn Green" should be
"Wakeetum Green."  Also in front of where I live is a legal subdivision called
Sunset View which is not listed.  It consists of 10 lots, was subdivided in 1970,
2 lots are built on, and 6 lots are locally owned.  This was left off the list.

          I am wondering if, in the treatment plant and outfall costs of
Alternatives 1 and 3, the cost of acquiring the land necessary had been counted
in the stated figures.  An acre of land in any of these areas would be expensive
but also rather hard to find as these areas are quite populated areas.

          In Alternative 5, Waldport, and Alternative 2, Waldport-Yachats, I
think the figures for treatment plant and outfall are too low as the cost of
running the line down between the rock hill and Hwy. 101 by Alsea Bay will be
costly plus obtaining easements for a new outfall across old town Waldport to
the Alsea Bay would be difficult because it is a densely populated area.  Also,
when there are flood tides and a heavy runoff in the Alsea River, the water backs
up into Lint Slough which is across the road from the treatment plant.  This has
already caused problems at the plant.  Also, no mention is made nor consideration
given to the fact that in the not too distant future the area east of Waldport to
Eckman Lake and the Waldport Heights area will be considering sewers.  If and when
that happens, the present plant at Waldport, even if enlarged to accommodate
SWLCSD, would not suffice and there is no room for further expansion at the present
site.

          On page 79, 2nd paragraph, 3rd sentence, another solution that has been
used has been condemnation by the County in areas where there has not been room
for the solutions you have stated.

          Other than these comments, I think that you have done a magnificent job
and have hopes that we may have our sewer in the near future.
                                            ean M. Duckett
jd

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Response to Comments from Jean M.  Duckett
1.   Corrections and additions were made as indicated.

2.   The cost of land for treatment facilities and rights-
     of-way was not included in any of the alternatives since
     land is considered to be 100 percent salvageable in the
     EPA cost effectiveness guidelines.  We do recognize,
     however, that land represents an additive cost to all
     alternatives, but the variation between alternatives is
     relatively minor.

3.   Additions to the text have been made reflecting your
     comments  (page 63).  The specific route of an outfall to
     Alsea Bay would be determined if the ultimate project
     includes a discharge to Alsea Bay.  It appears unlikely
     that such an alternative is recommended due to the con-
     straints placed on discharge to a receiving water having
     such high beneficial uses as does Alsea Bay.

4.   The use of condemnation by the county may be applicable
     in some areas, but cannot be considered an adequate
     solution to the overall problem of sewage disposal in
     the district.
                             257

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Response to Comments from William C. Adams
1.   The alternatives of locating a treatment facility at
     Big Creek were discussed as Alternative 3, page 71.  It
     will be necessary to discharge wastewater as an ocean
     outfall and not into Big Creek.  Because any future
     expansion of Waldport would be difficult at the existing
     plant site, it may be feasible to size a facility at Big
     Creek to support Waldport.  Such an approach would also
     eliminate any discharge to Alsea Bay.  The Yachats
     facility is adequate to handle the needs of the city and
     is a relatively new plant.  In all likelihood, it would
     not be feasible to include them in a Big Creek sewerage
     facility.
                             259

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DALE D. KREBS

     P.O. BOX 616
 WALDPORT, OREGON 97394
                                                   June 10, 1976

Richard R. Thiel, P.E., Chief
Environmental Impact Section, K/S 443                            RECEIVED
U.S. Environmental Protection Agency, Region X
1200 Sixth Avenue                                                J(j|\j i 4
Seattle, Washington 98101

n    <»
Dear Sir:

     Thank you for sending a copy of the draft Environmental Impact
Statement, Southwest Lincoln County Sanitary District, which we re-
quested during a recess of the June 2 hearing at Camp Angell.
     Further study of the document prompts us to congratulate you on
the completeness of the statement, which takes into account almost
every possible aspect of the project and the various possible options
open to the sanitary district.  We would like to express our appreci-
ation of the manner in which the hearing was conducted.  We thought
the moderator was very patient in attempting to keep the meeting "on
the track" and in reminding the audience of its purpose.
     As owners and full-time occupants of a single family residence
in the sewer district, we have already submitted statements favoring
the Yachats (fourth) alternative.  We would like to add that it is
our hope that the Yachats alternative, or one of the first five
alternatives, will be implemented as soon as possible.  We have
seen the impact of inflation upon costs of the Yachats waste water
disposal project and the Waldport secondary treatment plant.  It is
our hope that the grant from the Environmental Protection Agency will
come as soon as possible and that the local bonds can be sold and
the contract let before construction costs go higher, higher and higher.
     The no action alternative seems totally unacceptable to us, since
we walk the beaches south from the Waldport seawall and wade the "streams
we do not care to have our grandchildren play in because of the obvious
pollution from drainfield or septic tank failures.  We would rather have
clean beaches and streams than worry too much about the possible decline
in air quality which the impact statement suggests would follow installation
of sewers (because of increased automobile emissions).  The wind — or well
developed sea breeze — will do much to solve the automobile emission problem
since it blows year 'round.
     As for the seventh alternative, septic tank effluent will still have to
be disposed of somewhere, probably Yachats or Waldport if their plants will
accept it — so it seems unlikely that this stop-gap measure would solve
anything.
     We do not see any great "windfall" profits going to developers as the
result of sewers being installed in the district.  We hope that more homes
will be built so that cost of needed improvements may be spread more
equitably.
                                                 "
       260
                        '
                          Dale D. Krebs

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Response to Comments from Dale Krebs
1.   What alternative is ultimately chosen will be dependent
     upon the septic tank survey and a conclusive show of
     project need.
                             261

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                                                                   RECEIVED

   June 9, 1976                                                   JUN  1 4 1S76

    Richard R.  Thiel, P.E.
    Envir. Impact Section Chief, M/S 443
    US Envir. Protection Agency Region X
    1200 Sixth Ave, Seattle,  WA 98101
    From: Ms. Egan O'Connor, POB 332,  Yachats, OR 97498

    COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR
    SW LINCOLN CY WASTEWATER TREATMENT SYSTEMS              (EPA-10-OR-Lincoln-WWTS-76)

    This environmental impact statement (EIS)  considers 7 alternatives,  of which
    5 are basically the same	a sewer system plus treatment plants,  (page 67).

    It seems to me there are three important alternatives which were  totally
    omitted from the EIS for the SW Lincoln Cy Sanitary District.   Unless there  is
    good reason for their omission, isn't EPA required to consider them in the next
    draft?

    The 3 alternatives whose omission  I do not understand are these:

1.) The alternative of building a much smaller sewage system.   Alternative #4 was
 {  designed to handle the sewage of x 6,700 people (p.68),  which  is  2% times more
 •  people than the District has now (2,740 people including peak-load tourists).

 I  Note: page 32-34 shows the District's 1975 population as follows:  Total = 2,740
 j;        year-round residents	815 people
 4        part-time residents  	  1,225 people
          peak tourist load 	     700 people (pages 33-34)

    The EIS acknowledges over and over that the major environmental impacts of
    the proposed sewer system will come from the increased population  which the
    sewer will permit and even encourage.  Therefore,  it seems to  me  that the EIS
    must present the alternative of building a smaller sewer system which would
    not permit the population to grow  2% times bigger.

    What about the alternative of building a sewer system which could  serve a
    maximum of 3,800 people	or half  of 6,700?  Such a sewer system would permit
    plenty of growth to satisfy all present applicants for building permits and
    to generate more business for local builders and motel owners,  AS  FOLLOWS:

    If we assume a population growth to 3,800, then according to the EIS, we should
    assume that 25% will be transient  tourists, or a peak load of  950  tourists
    compared with a peak load of 700 now.  This means building of  more motel units.

    If 950 are tourists, then 2,850 out of the 3,800 would be permanent  and part-time
    residents compared with 2,040 in the District now.   This means, according to the
    EIS figure of 2.4 people per house, that 337 more homes  would  be built!  That's
    a lot of business and full relief  for the  people who have been denied building
    permits since 1972, plus a lot more.

    Many communities elsewhere in this country have come to  realize recently that
 ;   big growth is not desirable in terms of taxes,  pollution,  traffic, crime,
    ugliness, etc., and such communities have  started  forbidding sewer expansion in

                                      262

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                                                page 2, O'Connor EIS comments


     order to prevent the kind of growth which this proposed sewer for 6,700 people
     would encourage!

     It may be that the residents of this District assume that the ONLY way they can
     achieve proper sewage treatment for the existing way of life plus a modest
    ! expansion, is by building a sewer system which will permit a giant (2% fold)
    I growth and a major change in the kind of community we now enjoy.  I think
    I that EPA should insist that the Sanitary District show that no such misunderstanding
 •    exists, and that the residents themselves chose to build a sewer system much
    I larger than they need.
    I                                                             over age
    •=Cynics might say, but I do not, that the large number of people/^ 65 in this
    1 District do not care what sort of community we have 10 or 20 years from now.
    * I do not believe that, but I am only 38.

     I believe it is right for the present permanent and part-time residents to decide
    i what kind of community they want here	do they basically like it the way it is
    , (with enough activity to keep the existing businesses solvent)?  Or do they agree
     with many real estate people and land speculators that the population should
    ; expand greatly?  Though this District is zoned mostly residential now,
    i commercial expansion will be possible after the sewer just by re-zoning, and
     what would pxKKKfc prevent our part of Highway 101 from looking like Lincoln City?

     I am not talking about LCDC deciding what sort of community we want.  I am
    I talking about our deciding after all the alternatives (including a much smaller
    I sewer system) are presented and discussed.  I believe it is the duty of the
    j EPA to present the smaller-sewer alternative.

 2.) The alternative of using sewage hold-up (storage) tanks at motels and parks
     rather than septic tanks during the wet season, or at any time when the
     sanitarian declares a risk of poor septic tank function.  Wouldn't this
     alternative also permit expansion of the tourist business in this District
     at a much lower capital cost than $5 million?  If so, would the operating costs
     be more or less?

 3.) The alternative of installing, inspecting, and maintaining the clivus multrum
I     (dry) toilets developed in Sweden and now being studied in Oregon by the DEQ.
    . Or other kinds of low-water toilets.  Attached for inclusion in the next EIS
    i draft is an article fromthe Oregonian May 23, 1976 entitled "Clivus Multrum:
    ' Nonflush Alternative Gains Oregon Supporters".

/   i The EIS said that septic tanks are acceptable sac for most of the homes already
_J  '• built, and for future homes on larger lots.  Why isn't the clivus multrum
     toilet considered by EPA for new buildings, and for existing structures where
    ; septic tanks can never function well, and especially for the parks where there
    , is such a problem today?

     Wouldn't this alternative also substantially reduce the demand on the area's water
     supply, and all the costs (dollars and environmental) which will go with expanding
     our water supply for 6,700 people?
                                       263

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H
                                                     page 3, O'Connor EIS comments


        Even if EPA declines to discuss the 3 additional alternatives proposed above,
        I respectfually request that answers be provided in the next draft to the
        5 questions below:

    1.) What would be the environmental impact, relative to alternatives #1 through 5,
        of building a sewer system to serve a maximum of 3,800 people instead of
        6,700 people?

    2.) Just how big is the present health hazard in terms of risk per 100 people/years?
        How many cases of what?  What kind of suffering and cost will this proposed
        $5 million system eliminate?  And what percentage (estimated) of the present
        problem comes from
        a.) the parks
        b.) the motels?

*   3.) Is there good evidence that the clivus multrum dry toilet, or other kinds of
' -      low-water toilets, would function poorly in this District?  What is the nature
 1
        of the evidence?

    4.) What will be the environmental impact (and estimated cost in 1975 dollars) of
        providing water and reservoirsYfor the 6,700 people assumed for Alternatives
   !     #1 through 5 (page 68)?     ?~v ux-t-c-u flv
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               to*-
                                ^
                                                 I I/ I/ L/
Cttvus Multrum
Nonflush   alternative gains  Oregon   supporter;
By CRAIG WALKER
CorTMpondwil, Th* Orvgontan
  COnAGE GROVE -
Ron Davis is  convinced
he  has  found a  better
alternative to  the  (lush
toilet.
  Hailed as a means o(
saving  water, keeping
rivers clean and recycling
wastes,  the Clivus Mul-
trum has found a home
with Davis in Cottage--
Grove.
  The Multrum is a dry
compost toilet developed
in Sweden over the past
15 years. It is basically a
sloping compost box with
a layer of dirt beneath
where human and food
waste sits and decom-
poses. The  natural soil
bacteria acts on the mass.
turning it to a rich fertil-
izer in one to two years.
when it emerges (by
gravity) from the interior
of the tank ready to be
used in a garden.
  Ventilation through the
bottom and a \ent In the
roof  keeps odors from
returning to the house.
  Davis,  33, learned of
the Multrum In a garden-
ing  magazine  in  1970.
Last  September,  he
Installed a unit in a shed
on his farm and now dis-
tributes the units, which
are manufactured in New
Hampshire  under Swed-
ish license Davis has sold
about  six so  far. They
retail lor about $1.000.
  A  spokesman for the
state  Department of
Environmental Quality in
Portland  said  permits
have been granted for
about 10 dry compost toi-
lets, most of them  Mul-
trums.  The  DEQ is
empowered to review
applications for installa-
tion of the experimental
sewage devices.
  The ecological sound-
ness of the  Multrum
branches Into  several
areas, according to Davis.
  Since no water is used
in the process, a family
can save water normally
used by a flush  toilet.
This amounts to 40,000 to
50,000 gallons of water
per year for a family of
four, according to Davis.
  Secondly, the Multrum
does not send sewage to
treatment plants where it
is sterilized, thus elimi-
nating the need for mas-
sive sewage construction
projects  "And there are
no accidental raw sewage
spills into rivers as we
have now," said Davis.
  The DEQ was instruct-
ed by the 1975 Legisla-
U re to study alternative
means of sewage dispos-
al. The Clivus Multruir. is
one of several devices or
systems now   being
experimented with, said
Bob Jackrcan, land qual-
ity specialist for the DEQ
                                                265
in Portland.
   The DEQ would like to
test 100 Multrums, Jack-
man said, but use of the
devices depends  on per-
sons  applying  to  the
department. Would-be
testers must be willing to
pay about $1,500 for the
toilet and Installation and
to provide an appropriate
plumbing system.
   Davis feels there  is a
lot of "red tape," espe-
cially on the county gov-
ernment level, in gaining
approval. However. Jack-
man  said  the   DEQ is
chiefly  responsible for
permitting  the installa-
tion and monitoring the
experimental uses
   Davis would like to see
the DEQ more fully carry
out the intent of the 1975
Legislature's bill on alter-
native sewage systems.
"It's not the staff, but the
structure,"  he  said.  He
feels the DEQ needs more
money for the project.
   Davis  said   lie  has
received more response
from California in regard
to widespread use of the
Multrum than from Ore-
gon officials.
   "Gov. Brown has sug-
gested putting  in out-
houses  because of  the
coming water shortage,"
said Davis, who  received
a reply from the Califor-
nia housing office which
said the state  will  be
rewriting its building
codes "to permit, if not
require, waterless sew-
age disposal."
   Davis  urges such
action in Oregon and is
trying to get interested
persons to write to Gov.
Straub urging more
investigation of the Mul-
trum.
   Davis said there are
about  1,500 in use in
Sweden.
   "Actually,  they've
become  sort of  'avant-
garde.'  They are even
being put  in apartment
houses," said Davis.
   Davis said that mass
use  of the  Multrum
should be implemented in
rocky areas,  such  as
Bend, where normal  sep-
tic tank and sewer  sys-
tems cannot be easily
accommodated.
   "This use  of  the  sys-
tems will allow houses to
be built in places other
than on rich agricultural
ground, where  present
sewer system and septic
tanks must be located "
   Davis is  still  waiting
for gravity to draw the
waste in  his Multrum
down to where  it can be
removed.  But  in  the
meantime, everything
from  human waste  and
dead animals (two dead
sheep were disposed of)
to used dispo!»j!jlp diapers
from Davis' one-year-old
daughter are "on  the way
down" the inclined interi-
or of the Multrum, pre-
paring  to  return  to
nature.

\  I   i      .

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Response to Comments from Egan O'Connor


1.   Based on the district-wide septic tank survey, which the
     EPA will recommend to be done, a phased or staged (i.e.,
     smaller capacity) treatment system may be found to be
     the best approach to take to meet the needs of the district
     (see Preface of this final EIS).  We agree that it is up
     to the community to establish what sort of living environ-
     ment they wish to have in Southwest Lincoln County.   It is
     up to the people to make their thoughts and wants known
     to the county.

2.   It is questionable as to whether the storage tank alterna-
     tive would be significantly less expensive.  It would
     still be necessary to construct a treatment facility to
     handle the wastes pumped periodically from the tanks.  At
     some point in time the operating costs would become
     excessive (when a large number of residents are using
     storage vaults) particularly with regard to fuel consumption
     of the tank trucks.

3.   The Clivus dry toilet would be an acceptable alternative
     for waste disposal; however, it is up to the state and
     Lincoln County to make the necessary changes to laws and
     regulations.  Some sort of septic disposal system would
     still be necessary to handle wash water from sinks,  washing
     machines, showers, etc.  It appears that such a system
     would be a benefit to state parks having no shower facilities,
     There is no doubt that such a system would reduce water
     consumption.

4.   Please see Preface  to this Final EIS and response to
     question #1.

5.   There is no discernible health hazard — only a potential
     one.  The specific septic tank problems are not now known.
     The Comprehensive Sanitary Survey will determine that.

6.   There is no evidence that the Clivus dry toilet would be
     inadequate.   Disposal of wash water must be accomplished
     in some fashion, however.

7.   The impacts and costs of providing a water system have
     not been analyzed.  It has been recognized that the water
     system must be expanded.  Any more detailed evaluation
     could only be determined by a facilities and cost plan
     for the system.
                             266

-------
Sewerage treatment facilities typically now utilize
methane gas for uses within the plant such as heating
the sludge digester.  In most cases this methane fuel
must be supplemented with natural gas or electricity
since the production of methane is highly variable
because of wastewater flow variations.  Methane is also
used as fuel for boiler and internal combustion engines,
which are, in turn, used for pumping sewage, operating
blowers and heating water.  With such a small facility as
one serving the Southwest Lincoln Sanitary District, it
is likely that little excess fuel would be produced.
The use of solar-power would be for space-heating, which
in the case of Wilton, Maine, is of a major expenditure
since all facilities there are enclosed because of the
elements.  Solar-power has yet to be utilized for treatment
processes.
                         267

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        CARL  TROWBRIDGE AND ASSOCIATES, INC.
                                PROFESSIONAL APPRAISERS
                                                      WESTHILLS MALL    SUITE 2O4

                                                      4475 S W. SCHOLLS FERRY ROAD

                                                        PORTLAND. OREGON 97225

                                                         TELEPHONE 292-2691
                            June 9, 1976
Dr. Edwin L. Coate, Director
Environmental Impact Section, M/S 601
U.S. E.P.A., Region X
1200 Sixth Avenue
Seattle, Washington 98101
 RECEIVED

JWU4197S
                            Re:  Draft E.I.S.
                                 S.W. Lincoln  County Sewer District
                                 Waldport,  Oregon
Dear Mr. Coate:
In review of this E.I.S. Draft, and after attending the E.P.A.
Hearing of June 2, 1976, I would like to make some constructive comments
in relation to errors which have been made in the research and  data
gathering process for this report.   Since there are many small  errors,
I will be limiting my comments and corrections to what I consider to
be serious in nature as follows by headings:

Land Planning & Zoning
The E.I.S. Draft states that the S.W. Lincoln County Sewer District
is not in compliance with L.C.D.C. in land planning.  This is a
half-truth, because this part of Lincoln County has  been planned and
zoned since 1969 with the latest up date approved by county commissioners,
March 6, 1974.  These zoning, planning maps and ordinances are on file
in Lincoln County for your confirmation.  The half-truth is that L.C.D.C.
would like to have this data all on One Map -- not the five or six
separate area maps as now exist which permits a larger scale for better
management.

The Draft also recites "Vacant Land" which is incorrect because the
majority of this land has been partially subdivided  and held in small
parcels by separate individuals who can not build upon their site due
to current subsurface sanitation rules by D.E.Q.   Many of these sites  have
been purchased years ago for investment and future retirement, now they
can not use their site as once intended.
                                 268

-------
Study area of the E.I.S.  includes some 2,500 additional  acres  outside
the 3,149 acres of actual district boundaries.   Also  the study fails
to recognize that the study area is adjacent and/or very near  Siuslaw
National Forest which bounds the district on the east.   This creates  a
permanent "green belt" of some 168,758 acres which will  never  be developed.


Existing Zoning  (by Acres)
              Residential
              Rural  Residential
              Tourist Commercial
              Industrial  (one site)
              Natural Resources
              Golf Course
              State Controlled
              Federal Controlled

          TOTAL ACREAGE                3149


Population within the E.I.S.  Study Area is set out as  2684 (2024
permanent and 660 seasonal) which is 0.8523 persons/acre.   Then the
E.I.S relates there will  be unrealistic growth due to  the  sewer, 3145 by
1995 which would be.998 persons/acre.   It should be noted  that this
projected density of 1995   will still  be far less than existing (1976)
densities of Portland, Eugene, Salem or Corvallis today.

Based upon this projected growth, the rate would be 1.06%  compounded
annually over the next 20  years.   Please note that growth  rate within
Oregon is around 3%.

Traffic Patterns on 101

The study would like to infer that increased population densities
will increase congestion and traffic hazards along 101.  State of
Oregon Highway data for 1974 relates the following:

     June - September  — Double  the volume over other eight months.

                       —  82% Oregon Cars

                       —  8% out of State Cars

Beachside State Park is the heaviest, used park in the State of Oregon
based upon number of persons per  trip per park acre.  The  reason for
this useage is because of ocean,  beach and easy access.  Regardless of
state philosophy, the people will travel where they desire.
                                269

-------
It has been my experience that the reason most people are driving on
101 during the tourist season is that they can not find a place to
stop for accomodations.  It is not because they like to drive 101.
I believe a sewer system would permit some needed housing and accomo-
dations within the area and alleviate some of the traffic problems if
there are any to be seriously considered.

Rare & Endangered Wildlife

As outlined by the Federal Rules and Regulations governing E.I.S. for
E.P.A., I can not find where "Rare Species" of any kind are to be
considered or to be included within any E.I.S.  Then to continue along
this same line, your listing of endangered and threatened species are
incorrect.  This is an important area of concern and should be reported
accurately.

       1.  White-footed Vole    -  not listed as of 1/75 by any Federal
                                   list or by Oregon Wildlife Commission
                                   as endangered or threatened.

       2.  Flammulated Owl      -  not on any endangered list, as shown
                                   above.

       3.  Fisher               -  same as # I above.

Again the 168,758 acres of Siuslaw National Forest which abutts this
district and/or within one mile to the east was never considered as
being a refuge for wildlife within the area.   Due to the comparable
size 3149 acres vs. 168,758 acres, it would appear to me to be significant
for wildlife protection.

Beaches & Dunes

On page 127 the report discusses "sand dunes", however, no sand dunes
are shown on Figure 5 (pages 19 & 20) outlining vegetation and land
use maps even though the legend is keyed for sand dunes.  I have driven
this part of the coast many times and have yet to find one "sand dune."


In conclusion I would like to reiterate the same thing I told
Dr.  Clifford Smith in Fall of 1975.   This E.I.S. was a needless waste
of the citizens time and money.   As  shown by this current E.I.S. Draft,
the Yachats plan was correct, well planned, complied with county wide
sewage plan and was approved by the  Southwest Lincoln County Sewer
District voters by a 2 to 1 ratio.  What else is necessary in a democracy!


This was the third such E.I.S.  ever  completed within the State of Oregon
by E.P.A. and I am sure there must be more critical  areas within the
state which are being granted multimillion blocks of money.
                                 270

-------
For instance the Elk Rock sewer line  received approval  in what, one
month or less, but I suppose Portland is  treated  differently  than  small
outlying sewer districts.


The Southwest Lincoln County Sewer District has been  a  "Bureaucratic
Football" long enough, please help these  people get funds needed to
clean up their community.  The 300* citizens who  attended the E.P.A.
Hearing on June 2, 1976, were a good  show of support  for their completion
of the sewer district plans.
Sincerely,
William E. Ware,
General Manager
CARL TROWBRIDGE & ASSOCIATES, INC.
WEW/jm

cc:  Southwest Lincoln County Sewer District

     Lincoln County Commissioners

     Governor Straub

     Russell  Train

     Senator Hatfield

     Senator Packwood

     Representative  AuCoin

     C.E.Q. Washington D.C.
                                271

-------
Response to Comments from William E. Ware,
     Carl Trowbndge & Associates, Inc.


1.   Please see comments from the County of Lincoln Planning
     Department, page 276, and responses to those comments.

2.   The term "vacant land" according to Webster's International
     Dictionary means "being unoccupied", which is true of those
     lands at the present time.  The fact that they are under
     ownership and may have been for years, is moot.

3.   The Siuslaw National Forest was mentioned as a boundary
     to the sanitary district on page 7 in the Present Environment
     section.

4.   At no point in the EIS was the population growth of the
     district projected to be unrealistic.  The projected popu-
     lation density on the Lincoln County coast should in no
     way be paralleled to that of Portland, Eugene, Salem,
     Corvallis or any other city of Oregon.  The examples are
     not comparable nor are the resource values and uses or
     the area attributes of each.

5.   There is nothing to indicate that providing tourist accom-
     modations and more residential development within the
     sanitary district will reduce traffic problems.

6.   The draft EIS was in error as to the presence of the three
     species mentioned.  The final EIS will reflect that
     correction.  The likely impacts of a project on rare and
     endangered species within the study area must be identified
     even though lands outside of the study area are capable of
     supporting those species.

7.   The legend of Figure 5 has been changed to reflect the
     comment.
                             272

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                                                         RECEIVED
June 12, 1976
                                                        JUN 1 7 1976
Richard R. Thiel, P.E.
Erivir. Impact Section Chief, M/S UU3
U.S. Envir, Protection Agency Region X
1200 Sixth Ave., Seattle, ¥A 98101

From:  Garrett Smith, P.O. Box 1*66, Yachats, OR 97l;98

CJMHF.KTS ON THF: UFA?T ENVIRONMENTAL BT/ICT STATEMENT FOR
SV>' LINCOLN COUNT* ^ASTKWAT?,R TREATimMT SYSTEMS
                                               (T5pA-10-OR-Lincoln-*vnfD-76)

This respondent is a home owner in the district undar consideration^
a small business man (a potter) with a residence/studio/store in
the contiguous town of Tachatsj Chairman of the Vachats Planning
Conn.'ssion (though in the^e remarks 1 do not represent that body nor
any position it has adopted).

Before launching into the major comments to be made in response to
the EIS wo would like to endorse the remarks contained in a response
sent to you by Ms Egan O'Connor, dated June 9th.  The concerns and
values she expresses are important.  We, too, respectfully request
that answers to the five auestioris she lists on the third page of her
cotnnants be contained in the next draft EIS.  If the alternative of
t-ie clivus multrun dry toilet is discussed it would also be helpful
to have an enumeration of the standards, if such exist, for the disposal
of household waste water which is not generated by a toilet system.

The major issue not considered in the SIS, in my view, is that of land
use.  It would be a pity if jurisd.ictiona^iisputes between agencies
s:jch as the Land Conservation and Development Commission, the D.^.Q.,
the E.P.A. and various local planning bodies resulted in the glossing
over of land use considerations.  Timetables, too, should not be so
sacrosanct as tc dictate hasty and incompletely considered positions.

Lincoln County, !fats will grow principally to the Forth.  Nine miles
currently separate the two towns.  If, as a guess, the urban growth
boundaries for each town extend two miles toward each other we then
have five male? of -what is currently low density, primarily residential/
roc^- :ctJ.cn.al land,  it would be my argument that this section should

                              273

-------
                                         Page 2, Smith EIS comments
remain land-dominant rather than man-dominant,

If a sewer system were provided along that five mile strip we would be
faced with the very real potential for a thirteen mile linear develop-
ment along US Highway 101.  The "Twenty Miracle Viles" of Lincoln .City
have shown us what an inappropriate development this would be.  The
Oregon Coast Highway is a major scenic and recreational resource of the
State and Nation,  It should be preserved as such. And, parenthetically,
as a small business man I think an emphasis on conservation is good
business.

There is no reason that a self-conscious decision to not build a sewer
shouldn't be used to supplement land use decisions (should they be made)
dictating low-density development.

Given the current low density development of the area in cuestion, a
sewer system would be unreasonably expensive for those persons
currently living in the area.

The EIS does not effectively demonstrate that the failure rate of
existing septic tank systems is serious and non-correctable.  In those
few instances where such a system cannot be made to function adequately,
alternatives do exist.

Negative impacts of building any sewer system are listed in the EIS,
These could be avoided with a decision to retain low density usage
and adequate septic tank systems that were periodically inspected.
It is the responsibility of local jurisdictions to establish land use
plans.  All three affected planning bodies are in compliance with
L,C.D.C. requirements for the completion of their plans,  "What those
plans have to say should be a major element in the decision about a
sewer system for S.¥. Lincoln County,

I respectfully request that the issue of land use plans, timing, and
the appropriate roles of all involved agencies be addressed in the
next draft of the Environmental Impact Statement,
                              274

-------
Response to Comments from Garrett Smith
1.   See response to comments from Ms. Egan O'Connor.

2.   See Preface to this final EIS and letter from the
     Department of Land Conservation and Development.

3.   The EPA has recommended that a comprehensive survey be
     conducted in order to truly determine septic system
     problems.

4.   See letter from the Department of Conservation and
     Development.
                              275

-------
                    '-V-? " --  - - - - -   - ^\/Jf-cJ-Q-1
                    2s?*.      -.  ------ft Cfcs%&&
^^i^:,a^.../,x.  //^^r
                                       PLANNING  DEPARTMENT
                                                  Lincoln County Courthouse
                                                    Newpoi!, Oregon 97365
                                                       503-265-5341

                                                  June  21,  1976
Mr.  Richard R.  Thiel, P.E.  Chief
Environmental  Impact Section, M/S
U.S.  Environmental Protection Agency, Region X
1200 Sixth Avenue
Seattle, Washington 98101

Dear Mr. Thiel:
                                                                    RECEIVED

                                                                   JUN23 1S76

                                                                     EPA-R^
Thank you for  this opportunity to  reviev,- and comment on the
Southwest Lincoln County Sanitary  District  Draft Environmental
Impact Statement.

This  review was  limited  to an investigation of the  accuracy  of
information contained within the Draft E.I.S.  as it pertains to
local land use planning.  'The review brought^ to light numerous
data  errors and  several  misconceptions as to the current status '
of local land  use planning.   In my opinion  the data errors will
require correction and further elaboration  is  needed to alleviate
the possible misconceptions  and to accurately represent the  rela-
tionship of local land use planning to the  1973 Land Use Act
(S.B.100; O.R.S., Ch. 197).

To facilitate  en easier  correlation between the data errors  and
the objectionalle statements, the  error or  statement is presented
first and is followed by our explanatory comments and suggested
revision.
               Local planning authority.  A planning commission consist-
           ing of" nine members from various geographic locations in
           L^ncoli' Covnty 3? .r>npoir>-i-r-ci by the County Board of Commissioners/
           each to serve a four-year term. "The Planning Co:njvd:;sion has
           authority to adopt comprel-ensive plannIng and zoning ordinances
           for it.i "jurisdiction.  A County Planning Director is designated
           by the commission to oversee the operations of the Planning
           Department and serve as the chief administrative arm of the
           County Planning Commission.
               A series of preliminary land use plans have been fcrrr.ulated
           for ureas within Lincoln County including tht Alsea Jay Plan-
           ning Area, which includes part of the Southwest Lincoln Ccunty
           Sanitary District.  A comprehensive land use plan for Lincoln
        2  County has yet to be compactod and an extension has boon
           applied for to allow additional time to comply v/ich I.CDC
          _cioals. Zoning will have to conform to the comprehensive* land
           use planr and this may require significant zoning char.gos for
           some properties.  The current schedule for completion of the
           comprehensive plan is January, 1978 (per conversation, J. Webb).
             PG52
                                276

-------
 Mr.  R.I chard R. Tniel, P.E.  Chief
 Environmental Impact Section,  M/S
 June 21, 1976
 Page 2.

        •
 1.    The' Planning Commission has authority to recommend adoption
      of plans and zoning ordinances.   The County Board  of Commis-
      sioners has sole responsibility to adopt comprehensive land
      use plans and zoning ordinances for its jurisdiction.

'2.    Lincoln County has prepared and adopted local  land use plant;
      dating back to 1964.   The land use plans., instead  of being
      presented in one bulky document.,  is conveniently divided into
      six geographic sub-area plans, four which focus  on the major
      drainages end estuaries  (Salmon,  Siletz, Yaquina and Alsea) ,
      and several special element plans (e.g. transportation, paries
      and recreation, water/sewerage facilities, solid v.'aste uanage-
      ment, etc.).  These plans (land use and special  element),
      which cover all of Lincoln County, were prepared before adop-
      tion of the. LCDC statewide planning goals and  will require re-
      vision.  The adoption  of  coastal  goals  (required under the
      Coastal Zone Management Act)  will require further  refinement
      and the insertion of 'additional land use designations 'within
      the land use plans.

      Adopted land use and special  element plans which encompass  ohe
      area of the Southwest  Lincoln County Sanitary  District have
      yet to be revised to comply with  the L.C.B.C.  goals.  A plan-
      ning extension has been applied for to allow additional time
      to comply with the goals.

      The anticipated completion date for revising the adopted land
      use plan to address the statewide planning goals is June, 1980
      This completion date is based upon the anticipated receipt of
      planning assistance funds from L.C.D.C. during the 3976-1980
      planning period.  If the  planning assistance funds are not re-
      ceived, th3 completion date will  necessarily be  advanced until
      1987.

      This paragraph, rewritten to  incorporate the suggested changes
      is as follows:
                A series of land use plans have been formulated for
           areas within Lincoln County including the Alsea Bay Planning
           Area., which includes part of the Southwest Lincoln County
           Sanitary District.  A comprehensive le^nd use plan, as defined
           by S.B. 100, for Lincoln County has yet to be completed and an
           extension has been applied for to allow additional time to comply
           with L.C.D.C. goals. Zoning will heve to conform to the compre-
           hensive land use plan and this may require zoning changes for
           scrr.e properties.  The current schedule for completion of the
           comprehensive plan is June, 1980.
                                277

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Mr.  Richard R.  Thiel,  P.E.  Chief
Environmental Impact  Section, M/S
June 21,  1976
Page 3
          .       The  impacts on  streams; instead relate  to  secondary effects?
            to be brought about  by increased development in the southwest
            Lincoln County area.  The conversion of land from natural  vege-
            tative to impermeable surfaces wi J1 affect  runoff pattern'; and
            rates. Human activity in the are-i will chc.ngr the quality
            characters' sties of the receiviriq '-;aters and thus affect, stream
            biota. Residential  or conanercial development  in poorly drained
            or flood  hazard areas often times results in the need or der-'ire
            for flood protection and control resulting  in  strf.nm channeli-
            zation projects. Table IS gives an indication of the changes
            in runoff water quality associate*! with various If-.nd use typ^s.
            Under existing conditions, the southwest 1 incolr. County aren,
           - probably  represents  tho non-urban lane? use  type shown on
           ^ Table 18.  The reader can then sea what projected ei;i:sr:jon
            rates would be if land uses were to chan/j-e  to priE'.ari 3y resi-
            dential/commercial or industrial use tvnes.
              (PG9IJ


      Table  l8,  Urban  and Non-Urban Runoff  Emission Rates,  was
      based  on  a study of street  surface contaminants.   The  Draft
      E.I.S.  reports that" unde'r  existing conditions  the Southwest
      Lincoln County area represents the non-urban land use  cate-
      gory.   The Draft suggests  the  reader  draw his own conclusions
      as to  what projected  emission  rates would be after  Installa-
      tion of a  public sewerage  system  and  the placement   of  additional
      residences in the District.   The  data contained  in  Table  18,
      Residential  and  Commercial  category,  was collected   through a
      study  measuring  urban type  conditions,  conditions more urban
      in nature  than the Southwest Lincoln  County  area will,  in most
      probability ever develop.   Major  paving projects, other than
      upgrading  U.S.  Highway  101,  are not projected to  materialize
      during the next  20 years.

                  The planning and sitina of severage facilities has beer.
             deemed an activity  of statewide significance, .requiring a"
             planning and siting action on zb« part of  LCDC to determine
             whether  or not the  project conforms with statewide land use
             planning goals and, in this case, cos.stal  zone management
             00?ls.   Also a detemir.r.ti03- of compliance with tho lo--:al
             comprahensive land  use plan is required.   Since neither the-
             coastal  zone management goals of the State of Oregon nor  the
            4.CQmBr3hensive Plan  for Lincoln County have boon adopted bv
            JjCDC>. the intended  state f01 urn is not operating for the review
             of  the proposed sewerage pl;,nr. and their relationship to  land
             use.  LCDC  officials have slated in a letter to the EPA that
             they, in conjunction with the Oregon Department of Knviron-
             meantal Quality, will  oversee the planning and siting  of this
             project and thereby insure  that no hook-ups will  be allowed
             until a comprehensive  plan  cddressincj land planning issu"  has
             been  filed  with LCDC.   Whether LCDC has  the authority  to
             impose such restrictions  on  local  residents is a  matter whic i
             has yet to  be resolved  and,  no doubt,  will require a  legal
             interpretation of the  applicable statutes be-fore  a resolution
             is reached.   The dcsigmtior of _.j3T_brMj_gj.-owth boundaries ;-a:. r yjiid-
          c Agg the population  cc-^.e_r_ot__K£ij.dj>grt  and Yachgts  on cTTthcii- end
          5 _Pf Inc district and  comprehensive  land u.oe plans  have not "be-in
            jnaj3c_; thus, a determination of  the  orderliness; oi  urbani xaTKm"
            within the  area cannot be made-  in  conformance  with the  state-
            wide adopted  planning goalti.
              (PG 107)
                                    278

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Mr.  Richard R.  Thiel, P.E.  Chief
Environmental Impact Section, M/S
June 21, 1976
Page 4


4.    O.R'.S. 197 does not  authorize,  neither  does it  require
      L.C.D.C. to adopt local comprehensive plans.

5.    The designation of urban growth boundaries iri Lincoln County
      can be made only in  coordination with the incorporated  cities
      and only after consideration of all statewide planning  goals.
      To properly designate  appropriate land  uses a detailed  inven-
      tory of the inter-related natural systems and social activities
      of the area under study must be taken into consideration.
      Lincoln County has requested state land use planning assist-
      ance funds to gather the necessary inventory data to adopt
      Preliminary Growth Boundaries  and Growth Policies by June,
      1977-

      The following re-write is suggested:

                      The designation of urban growth boundaries affecting
           the Southwest Lincoln  County Sanitary District have not been made;
           thus, a determination	

                  In addition  to the two state parks currently being operate:
             in  the district,  the State ir. tsr.ds_to develop for park use_
             its  properties at Smelt Sands  and San Marine (pers.  COIICT.,
           e Larry Jacobson) .  Thesa dovc-13s.T.c-r>t3 would surely add  to' the
             peak tourist population which  has bean steadily increasing  in
             recer'tTvears.  Commercial facilities which cater primarily  to
             the  tourist traffic will, of course, benefit from this
             expansion.  Tourists who partake of the natural amenities of
             the  i.rea gain benefits from having sewered camping and pic-
             nicirig facilities available to them.
               (PGT08)

      The impact of increased tourists resulting from the develop-
      ment of these two park properties 1s at this time unknown.
      The development of Smelt Sands,  3-9 acres arid San Marine,  7-2
      acres, as  day use facilities,  would not appreciably increase
      the overs.1.". total number of tourists visiting Lincoln County.

      The following changes  are suggested to  re-write this paragraph.


                  The State intends to develop day use parks on properties
           at Smelt Sands (3-9  acres) and San Marine (7-2 acres).  ThCoO
           facilities would attract the tourist population v:hlch has I.•;•'.?•
           steadily increasing  in rece>nt years.  Development and ^ewera.--*.:
           of these two facilities would not result in  a significant in-
           creased demand on the Districts sanitary facilities.
                                  279

-------
      Mr.  Richard R.  Thiel,  P.E. Chief
      Environmental Imoact  Section,  M/S
      June 21,  1976
      Page 5
                    o In order to assure .> more orderly p]finninu proc.c.-r.r, in
                         project area an 1 conformant with Mir:
7
               hcnnivp  l']an, s)iotild Lincoln County choose La_t-xc_i:jCLL^jQ-
               j.ts option of es'toblii-il.ing  Inter J i" '/oninq Oi LJinniiCCi_as.
               allowed  under Orccro.? Statutes  (QI'S 215.304) related to
               rcoinprehonsi vtv land use n] arming?
                (PG \27]
        •
7- •   It is  suggested that this  recommendation, which  ic dis-
      guised as a question,  be  deleted from  this  Draft  ivpoi-l
      because interim zoning is  inappropriate where permanent
      zoning currently exists and because  a  building moratorium
      is politically unacceptable where no widespread public
      health hazard  exists.
                       8
                                      Table 14

                     SUBDIVISIONS IH SOUTHWEST LIt!COL?-l SANITARY DISTRICT
Subdivision
Yaquina John Point
Seawood Parks
Sea Brooks
Rolling Hills
Pine Crest
Big Stump.
Edgerfater Shores
Pacific Sands
Wake 3 turn Green
Surf Pines
V.'akonda Beach
Dig Creek Estates
Tillicum Beach
San Marine
Shore Pine Crest
Crab Apple Hill
Raymondville
Aqua Vista
Ocean Crest
Fairway Heights'
Year
Subdivide 5
1930
1945
1950
1964
1960
1968
1970
1960
1970
1970
1920
1971
1920
1920
1969
1965
1920
1920
1920
1970
Aj>prox .
Number
of Lots
Current
250
26
90
58
.18
25
15
15
6
9
300
16
35 •
500
17
750
36
200 •
40
32
Estimated
Current
Build Out
85%
30%
70%
50%
50%
' 95%
95%
80%
80%
1%
70%
50%
50%
30%
75%
30%
75%
70%
60%
10%
"*. Local
Owners
75%
10%
75%
50%
40%
10%
10%
50%
20%
C
50%
70%
50%
40%
25%
20%
20%
60%
50%
80%
                    Source:  Gruen  Gruen + Associar.es from estimates by Miller, no
                    comm.  Acreage  figures not ava'.lnblc.  It should be noted  that
                    the.number of lots given is on\y for the plotted sections  of
                    subdivisions, some of tho subdivisions can expand to adjacent
                    lands, thereby  increasing the number of lots.
                      (F'G48)
                                  280

-------
  Mr.  Richard R.  Thiel, P.E.  Chief
  Environmental  Impact Section, M/S  443
  June 21, 1976
  Page 6
  8,
3
Table  14, supplying data on subdivisions located within
the District was  scrutinized for accuracy and there  were
numerous errors and omissions discovered.  Table Ik  re-
flects 2,443 lots current  and the Assessor's  records show
only 1,379 lots within recorded subdivisions.   To provide
a more accurate representation of the total number of lots
available, Table  14 should list only recorded subdivisions
or provide a more definitive statement as to  exactly what
geographic area surrounding the subdivision was encompassed
when the lot count was taken.  It would also  be appropriate
to graphically present the area encompassed in map form.

A corrected Table 14 follows:
                              Recorded Subdivisions in
                         Southwest Lincoln Sanitary District
              SUBDIVISION
                                    DRAFT
                                    REPORT
                                Approx. Ruir.ber
                                of Lots Current
                 ASSESSOR'S
                  RECORDS
             Actual Kuir.tr-r of
               Platted Lots
       Yaquina John Point
       Seawocd Parks (Sea Woods Park)
       Sea Biooks (does not  exist)
       Rolling Hills
       Pine Crest (Pinecrest Village)
       Big Stump
       Edgewater Shores
  (Nev;) Edgewater
       Pacific Sands
       Wakeeturn Green (Wakeeturn Green)
  (New) Vakeetum Green First  Addition
       Surf lines
       Vakonca Beach
       Big Cieek Estates
       Tillicuin Beach
  (New) Knox /ddition to Tillicuin Beach
       San ME.rine
       Shore Pine Crest (Shoropine Crest
       'Crab ;pp3e Hill
       Raymondville (does not exist)
  (New) Reyno!dsville
       Aqua Vista
       Ocean Crest
       Pairwc-.y Heights
260
 26
 90
 58
 18

 15

 15
  6

  9
300
 16
 35

500
 17
750
 36

200
 40
 32
                                                             61
                                                             28
                                                             18
                                                             10
                                                             12
                                                              6
                                                             58
                                                             10
                                                             16
                                                             116
                                                             35
                                                             129

                                                              38
                                                           1,379
                                    281

-------
Mr. Richard R. Thiel, P.E. Chief
Environmental Impact Section,, M/S 44-3
June 21, 1976
Page 7


¥e sincerely appreciated the opportunity to review and comment on
this Draft report and hope our comments will aid in the clarifica-
tion of the land use issues.
Respectfully,,
James S. Webb
Planning Director

JSW:cs
cc:  Directors}  Southwest Lincoln Sanitary District
     Board of Lincoln County Commissioners
     Jones & Stokes Associates, Inc.
     Gruen Gruen + Associates
                               282

-------
Response to Comments from the Lincoln -
     County Planning Department


1.   Changes were made as recommended — see page 52.

2.   Changes were made as recommended — see page 52.

3.   Table 18 has been eliminated and the text on page 91
     changed.

4.   Changes were made as recommended — see page 106.

5.   The changes were made as requested — see page 107.

6.   See response to comments from Parks and Recreation
     Branch, page 170.

7.   Deletion was made as recommended — see page 293.

8.   Table 14 was changed to reflect the new figures — see
     page 48.
                              283

-------
Table 26
General Letters Received Regarding
A Wastewater Treatment System
Date
Reed
6/11
6/4
6/7
6/7
6/9
6/9
6/9
6/14
6/16
6/17

From
Max C. Rijken
State Representative
W. Stan Ouderkirk
State Senator
Robert L. Johnson
Mr. & Mrs. Earl T. Wilkinson
10
00
Mr. & Mrs. C. Robert
Davidson
Mr. & Mrs. Glen A.
Wilson
W. F. Margrave
Mr. & Mrs. C. R. Brundage
Patrick E. Ball
Lar Romoren

General
Tone
Supports
Supports
Supports
Supports
supports
Supports
Supports
Supports
Supports
Supports

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X
X
X


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Fisheries






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comments on the draft EI5
M and are reproduced earlier
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Ul





























* EPA has received approximately
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Eight letters provide




























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Thor H. Mork, Chairman
Homeowners League
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Table 26
General Letters Received Regarding
A Wastewater Treatment System
Costs
Development
Alternatives
Water Quality
Recreation
Fisheries
Wildlife
Construction Impacts
Secondary Impacts
Archeological
Historical Preservati
Population
Land Use Planning
Air Quality
Water Supply
Transportation
Soils
Effluent
Septic Systems
Federal Policv
Aesthetics
Reserve Capacity
Energy
Sludge Disposal
Health & Sanitation



-------
                 SUMMARIZATION OF GENERAL LETTERS
     During the 45 day review period on the draft EIS, EPA received
many letters voicing opinions on the need for a wastewater treatment
system in Southwest Lincoln County Sanitary District.  Because these
letters neither provide substantive comments on the draft EIS, nor
require a response from EPA, they are not reproduced in this final
document.  EPA believes, however, that the opinions of people residing
or owning property within the District are important to a final deci-
sion concerning a construction grant award.  This section, therefore,
summarizes the major concerns of the letters received.  These letters
are listed individually on the preceding table.

     The most common reasons for support of wastewater treatment faci-
lities are as follows:

     1.  Familiarity with the District and the existing problems
associated with septic tank/drainfield systems.

     2.  Soil conditions within the District which severely restrict
the installation of septic tank/drainfield systems.

     3.  The economic impact on housing development as a result of
septic tank permit denials.

     4.  The influx of summer residents and tourists which add to
existing subsurface sewer system problems.

     5.  The presence of sewage on beaches and the impact on recrea-
tion area due to inadequate sewage treatment.

     Opposition to a sewerage system for the District was primarily
received from the Home Owners League, Thor Mork, Chairman.  EPA re-
quested from Mr. Mork the number of individuals represented by the
Home Owners League; no response was received.   EPA received approxi-
mately 30 letters from Mr.  Mork.   Eight of these letters provided
comments on the draft EIS and are reproduced and responded to
earlier in this chapter.   Salient points raised in the remaining
letters are briefly summarized as follows:

     1.  The proposed sewer system is the result of pressure from
from land speculators.

     2.  The population of the District cannot support a wastewater
treatment system.

     3.  No evidence of failing septic tanks exists except in areas
of small  lot subdivisions.

     4.  There is economic  impact on retired fixed income residents.
The Home Owners League criticized EPA for its  use of 18.7% as the
age of residents 65 and over in Lincoln County.   The League contends


                               286

-------
that approximately 70% of the residents in the District are age 65
and over.

     5.   Proposed method of financing the sewer system is unfair to
the poor and elderly residents in the District.

     6.   The EIS is not a "full  disclosure" document and is based on
falsified facts.

     Both support and opposition for a wastewater treatment facility in
Southwest Lincoln County is recognized by EPA.  Concerns over failing
septic tanks, septic tank permit denials and health conditions were
investigated and discussed in the draft EIS.  Many of the concerns
raised in these letters were also raised in comment letters on the
draft statement.  EPA refers readers to the responses made to these
comments earlier in this chapter and to discussions in the text of
this final EIS.

     Concerns raised by residents opposed to wastewater facilities in
Southwest Lincoln County Sanitary District are also valid.  It should
be noted, however, that any method utilized for financing a sewerage
system is the responsibility of the District.  EPA cannot determine
the ability-to-pay of the residents in the District.  The economic
impact to residents within the District is, however, within the scope
of this EIS.  Discussions are therefore included in this document
which illustrate the existing economic conditions of the District and
the impacts which could be expected as a result of the selection of
any of the seven alternatives analyzed.  Population statistics and
results of failing septic tank surveys are also included in this
final EIS.

     All letters received by EPA were presented to the Regional
Administrator and were considered by him when formulating the recom-
mendation included in the "Preface" of this document.
                             287

-------






























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Supports


















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Jack Postle
Ltncoln County Commissioner
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Shellfish
Alternatives
Water Quality
Recreation
:isheries
Wildlife
Construction Impacts
Secondary Impacts
Archeological
Historical Preservati
'opulation
Land Use Planning
Air Quality
Water Supply
Transportation
Soils
Effluent
Septic Systems
:ederal Policy
Aesthetics
Reserve Capacity
Inergy
ludqe Disposal
ealth & Sanitation


-------






























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Letters Submitted To Public
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Table 27
Public Hearing Testimony
Costs
Shellfish
Alternatives
Water Quality
Recreation
Fisheries
Wildlife
Construction Impacts
Secondary Impacts
Archeological
Historical Preservati
Population
Land Use Planning
Air Quali ty
Water Supply
Transportation
Soils
Effluent
Septic Systems
Federal Policy
Aesthetics
Reserve Capacity
Energy
Sludge Disposal
Health & Sanitation


-------

Date
Reed
6/2
6/14

ro
vo
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Table 27
Public Hearing Testimony
Speakers
Thor Mork (Petition)
Dale D. Krebs
Betty M. Krebs
Marian H. Myss
Gustaf F. Myss
Charles A. Bonnett
Bert Harley
Elaine C. Harley
Ralph C. Carlson
Emma E. Carlson
Elmer Ostling
J. L. & Elva H. Monahan
Maria Ames
Lucille B. Windus


Seneral
Tone
Opposes
Support:
Support:
Support:
Support!
Support:
Supports
Support!
Support!
Support!


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Table 27
Public Hearing Testimony
Costs
Shellfish
Alternatives
Water Qual ity
Recreation
Fisheries
Wildlife
Construction Impacts
Secondary Impacts
Archeological
Historical Preservati
Population
Land Use Planning
Air Qual ity
Water Supply
Transportation
Soils
Effluent
Septic Systems
Federal Policy
Aesthetics
Reserve Capacity
Inerqv
Sludqe Disposal
Health & Sanitation


-------
                      PUBLIC HEARING SUMMARY

     On June 2, 1976 the Environmental Protection Agency held a
public hearing on the draft Environmental Impact Statement for the
Southwest Lincoln County Sanitary District's proposed project.  The
hearing was conducted at the Angel 1 Job Corp Center and was attended
by approximately 180 people.  Because of the length of the official
hearing record and the costs involved, we have not reproduced the
document for this final EIS.  A table is provided, however, which
lists the speakers and the specific areas in which they were most
concerned.  The Public Hearing Record is available for review at the
Southwest Lincoln County Sanitary District Office, the Newport Public
Library and EPA's Region X Office, Seattle, Washington.

     Speakers in support of a wastewater treatment system in the
Southwest Lincoln County Sanitary District were largely concerned
about the inability of property owners to install septic tank/drain-
field systems due to the soil conditions within the District.  These
individuals either own small lots in which they have planned to
construct a retirement home or have larger property interests for
selling lots either as a business venture or to supplement a retire-
ment income.  The issue of failing septic tanks within the District
was also raised by speakers during the hearing.  These individuals
expressed concern over the discharge of sewage on to public beaches
and private property.  Concern about the potential health hazard
these conditions present was also expressed.

     Opposition to wastewater facilities in the District primarily
focused on the cost of the facilities.  The Homeowners League,
Thor Mork Chairman, expressed the concern that the estimated costs
of the sewers would create an economic hardship on the many retired
people residing in the District.   The League also conducted a private
survey within the District to determine the most desirable alterna-
tive for providing sewer service in the District.  Mr. Mork indicated
that 70% of those surveyed favored Alternative 7.  When questioned
as to the number of people participating in the survey, Mr.  Mork
stated that the Homeowners League had not decided whether or not to
release the information.   Mr. Mork also criticized the accuracy of
much of the data contained in the EIS.

     Comments from Jack Postle, Lincoln County Commissioner con-
sisted of reading a letter dated November 13, 1972 from Governor
Tom McCall to the Lincoln County Commissioners (See Preface pg i).
Egan O'Connor asked for additional study by EPA of the individual
dry sewage system presently being studied by the Department of
Environmental Quality.

     EPA wishes to thank each of the participants at the public hearing
for expressing their views and concerns.   Additional  information as
a result of the hearing has been added to this final  EIS.   The hearing
record along with all other comments were considered by EPA in
formulating the recommendation contained in the Preface to this
document.
                               292

-------
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-------
                    IX.   UNRESOLVED ISSUES


     During the course of report preparation, it became clear
that there were numerous questions and issues relative to a
district sewerage project.  Several of those issues were iden-
tified in the introduction of this draft impact statement and
were further discussed throughout the report.  The resolutions
to several of the issues are institutional problems that must
await further political and social actions.  The following
important issues must be dealt with by constituents of the
sanitary district, county officials and state agencies having
responsibilities in Lincoln County.

     • How will the approval and construction of the sewerage
       facilities relate to the Coastal Goals finally estab-
       lished by the Oregon Coastal Conservation and Develop-
       ment Commission (OCCDC) and Land Conservation and
       Development Commission (LCDC), particularly as these
       goals relate to those coastal environments to be most
       affected:  a) estuarine resources, b) shorelands and
       shorelands boundaries, and c) beaches.

     • Should the subdivision and degree of development of
       land, secondary to the construction of a sewerage
       system, be allowed to preclude the implementation of
       planning options by Lincoln County?  For example, if
       a particular area is subdivided prior to completion of
       the County Comprehensive Plan, this would effectively
       eliminate some potential management classification of
       the land such as natural resource conservation areas,
       etc.

     • Should LCDC designate the planning and siting of a
       sewerage system in the project area, a matter of state-
       wide significance as allowed for in ORS 197.400?
                              293

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An unresolved question relates to the designation of
urban growth boundaries in southwest Lincoln County.
The LCDC guidelines require local planning authorities
to distinguish between urban and rural lands in the
county planning effort.

There may be an inequity of cost distribution based on
lot size.  The proposed sanitary district ordinances
will favor small, single-family residence lot owners
over large, single-family residence lot owners, which
increases density and may be contrary to the preser-
vation of open space values on the coast and to any
attempt to zone areas with a large minimum lot size,
i.e., AG-1 or 5.

While it has been recognized in the EIS that landowners
should achieve some level of monetary benefit resulting
from increases in property value, the actual degree of
benefit to be derived is unknown.  Numerous factors,
including the demand for property, will dictate the
degree of benefit.  At present, only those lots which
have failing septic tanks or cannot obtain permits for
septic tanks are strongly disadvantaged and would
obviously benefit monetarily from a common sewerage
system.  Other considerations in the pricing of property,
make any determination of monetary benefits for the
majority of district property unestimateable.

What legal assurance will there be from LCDC that no
new sewer hookups will take place prior to the comple-
tion of a Comprehensive Plan for the southwest Lincoln
County area?
                      294

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                        BIBLIOGRAPHY
American Birds.  1975.  The seventy-fifth Christinas bird
     count, vol. 29, no. 2.

Battelle, Pacific Northwest Laboratories.  1973.  The impact
     of travel on the Oregon economy and visitor use of tourist
     serving facilities.  Prepared for the Bureau of Municipal
     Research and Service.

Beckham, Stephen D.  1973.  Historical and archeological site
     inventory:  preliminary report.  Oregon Coastal Conservation
     and Development Commission.

Clark and Groff Engineers, Inc.  1970.  Lincoln County regional
     water and sewerage plan.  Prepared for Lincoln County
     Board of Commissions.

Dorsey, F. Owen.  1890.  The gentile system of the Siletz
     tribes.  Journal of American Folklore, 3: 227-237.

Drucker, Philip.  1939.  Contributions to Alsea ethnography.
     University of California Publications in American
     Archaeology and Ethnology, 35(7): 81-102.

Federal Register.  1975.  Environmental Protection Agency -
     preparation of environmental impact statements, final
     regulations.  April 14, 1975, 40(72):  16815-16827.

Franklin, J. F. and C. T. Dyrness.  1969.  Vegetation of Oregon
     and Washington.  U. S. Forest Service Research Paper
     PNW80.  216 pp.

Goumer, Thomas, D. Demorg and L. Osis.  1973.  1971 Alsea River
     estuary resource use study.  Oregon Fish Commission.  29 pp.

HGE, Inc.  1974.  A comprehensive water sewerage and solid waste
     management plan, Lincoln County Oregon, vol. 1, introduction
     and projected development, vol. 2, water facilities develop-
     ment plan, vol. 3, sewerage facilities development plan.

Ingles, Lloyd G.  1965.  Mammals of the Pacific states.  Stanford
     University Press.  506 pp.

Lincoln County.  1965.  Economic trends and population changes.
     Prepared by the Bureau of Municipal Research and Service.

             1969.  Lincoln County long range planning report.
                              295

-------
Lincoln County.  Health Department.  1971-1974.  Individual
     site evaluation for subsurface sewage.

Lincoln County.  Planning Commission.  1964.  Land use plan
     for the Lincoln County coast.  A preliminary report.

Lincoln County.  Planning Department.  1967.  A preliminary
     comprehensive plan for the Lincoln County coast.
             1971.  Transportation plan.

             1972.  Alsea Bay regional land and water use plan.
             1973.  Overall economic development plan, Lincoln
     County, Oregon, 1973.

Metcalf & Eddy, Inc.  1972.  Wastewater engineering - collection,
     treatment, disposal.  McGraw-Hill.  782 pp.

Robert E. Meyer Engineers, Inc.  1974.  Southwest Lincoln County
     Sanitary District, financial plan, December, 1974.
             1974.  Southwest Lincoln County Sanitary District,
     sewerage study, September, 1974.
	.   1975.  Supplemental appendix to the facilities
     plan - southwest Lincoln County Sanitary District, April,
     1975.

Mooney, James.  1928.  The Aboriginal population of America
     north of Mexico.  Smithsonian Miscellaneous Collections
     80: 7.

State of Oregon.  1973.  Environmental geology of Lincoln County,
     Oregon.  Department of Geology and Mines Industries Bulletin
     #81.  171 pp.

Oregon Coastal Conservation and Development Commission.
     1974.  Economic survey and analysis of the Oregon coastal
     zone.
	.  1974.  An identification of areas suitable for
     urbanization in the coastal zone.

Oregon.  Department of Environmental Quality.  1975.  Area review
     report - Waldport to Yachats.  3 pp. + attachments.
             1975.  Regulations relating to water quality control
     in Oregon.  Oregon Administrative Rules, chapter 340.
                               296

-------
Oregon Employment  Division,  Department of  Human  Resources.
      1974.  Occupational manpower  trends in  the  State  of
      Oregon,  1970-1980.

Oregon Land Conservation and Development Commission.   1974.
      Oregon land use handbook.

Oregon State  Game  Commission.   1973.  Oregon State Game Commission
      Bulletin, January 1973, 29(1).

Oregon State  Health Division.   1973.  Lincoln County survey.

University of Oregon.  Bureau of Governmental Research and
      Service.  1965.  Economic  trends and  population changes.
             1969.  Preliminary land use plan for the Yaquina
     Bay area, 1969.

Peterson, Roger T.  1961.  A field guide to western birds.
     Houghton-Mifflin Company, Boston.  309 pp.

Schaeffer, Claude.  1959.  Indian tribes and languages of the
     old Oregon country.  Map prepared for the Oregon Historical
     Society.

Sharp, W. C. and T. E. Adams, Jr.  1974.  Erosion control
     symposium proceedings.  U. S. Soil Conservation Service.
     134. pp.

Smith, A. K. and J. E. Lawman.  1972.  Fish and wildlife resources
     of the middle coast basins and their water requirements.
     Oregon State Game Commission.  98 pp.

Southern California Coastal Water Research Project (SCCWRP).
     1973.  The ecology of the southern California bight -
     implications for water quality management.  SCCWRP TR104.
     531 pp.

Stebbins, R. C.  1966.  A field guide to western reptiles and
     amphibians.   Houghton-Mifflin Company, Boston.   279 pp.

Swanton, John R.   1952.   The Indian tribes of North America.
     Smithsonian Institution Bureau of American Ethnology
     Bulletin 145.

DMA Nortec,  Inc.   1974.   Solid waste management plan, Lincoln
     County, Oregon.

U. S. Bureau of the Census.  1915.  Indian population in the
     United  States and Alaska,  1910.
                               297

-------
             1950, 1960 and 1970.  Decennial census reports,
     Oregon.
             1962 and 1972.  County business patterns.
U. S. Department of Commerce.  1974.  Climatological data -
     Oregon, annual summary 1974, 80(13).

U. S. Department of Interior.  1973.  Oregon, population,
     employment and housing units projected to 1990.
             1973.  Threatened wildlife of the United States.
     Resource Bulletin 114.  286 pp.
             1974.  Agriculture and food processing, Pacific
     Northwest, projections of production, employment and
     energy consumption to 1990.

U. S. Environmental Protection Agency.  1975.  Compilation of
     air pollutant emission factors.  U. S. E.P.A. AP-42.

U. S. Soil Conservation Service.  1972.  General soil map -
     Lincoln County, Oregon.

Yocom, C. and R. Dasmann.  1965.  The Pacific coastal wildlife
     region.  Naturegraph Company.  117 pp.
                              298

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                   PERSONAL COMMUNICATION

ALERE, WILLIAM.  Floodplain Management U. S. Army Corps of
     Engineers, Portland, Oregon
BALDWIN, HENRY, JR.  President, Southwest Lincoln County
     Sanitation District, Yachats, Oregon
BROOKHYSER, PAUL.  Lincoln County Planning Department,
     Newport, Oregon
CARTER, GLEN.  Oregon Department of Environmental Quality,
     Portland, Oregon
CLEMENS, GENE.  Lincoln County Sanitarian, Newport, Oregon
COLLETT, LLOYD.  U. S. Forest Service, Waldport Ranger
     Station, Waldport, Oregon
DEMORY, DARRELL.  Oregon State Fish Commission, Newport, Oregon
DENNISON, DENNIS.  Planner, Lincoln County Planning Department,
     Newport, Oregon
DOBEY, EMMETT.  Lincoln County Sanitarian, Newport, Oregon
DOWNS, STEVE.  Water Quality Specialist, Department of Environ-
     mental Quality, Salem, Oregon
DUCKETT, JEAN.  Secretary, Southwest Lincoln County Sanitary
     District, Yachats, Oregon
FORTUNE, JOHN.  Oregon State Fish Commission, Newport, Oregon
CONOR, SUSAN.
HANKS, JOHN.  Traffic Department Planner, Oregon State Highway
     Division, Salem, Oregon
JACOBSON, LARRY.  Oregon Parks and Recreation, Salem, Oregon
JOHNSON, JAMES.  Planner, Lane County Planning Department
JOHNSON, RAY.  Oregon Department of Environmental Quality,
     Air Quality Division, Portland, Oregon.
LOFQUIST, ED.  Water Coordinator, Newport, Oregon
LONG, EDWARD.  State Historic Preservation Office, Salem, Oregon
MCDUFFY, RAY.  Private citizen
MILLER, JOE.  Chief pilot, Newport Airport, Newport, Oregon
MILLER, ROSS.  Chief Appraiser, Lincoln County Assessors
     Office
NEWBAUER, EUGENE.  Assistant Superintendent, Lincoln County
     School District
OLIVER, LEON.  Real Estate Salesman, Cox Realty
OSBORNE, JACK.  Oregon Department of Environmental Quality,
     Portland, Oregon.
PEER, RON.   Sanitation Engineer, Yachats, Oregon
POWELL, LEWIS.  Robert E. Meyer Engineers,  Inc., Beaverton, Oregon
POWERS, DAVID.  Oregon Department of Parks  and Recreation,
     Salem,  Oregon
RIGDON, MELVIN.  District Conservationist,  U. S. Soil Conservation
     Service, Newport, Oregon
RILEY, HERBERT.  Deputy Director, Oregon Land Conservation and
     Development Commission
ROSS, RICHARD, Ph.D.  Anthropologist, Oregon  State University,
     Corvallis, Oregon
ST.  LOUIS,  DAVID.  Noise  and Air Quality Specialist, Department
     of Environmental Quality, Salem, Oregon

                            299

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SCHWAB, TOM.  Planner, Oregon Department of Highways, Salem, Oregon
STORM, ROBERT, Ph.D.   Oregon State University (amphibians/
     reptiles), Corvallis, Oregon
STRAND, ALBERT.  Commissioner, Lincoln County Board of
     Commissioners
STURGIS, HAROLD.  Oregon State Wildlife Commission, Corvallis,
     Oregon
SWAN, ELIZABETH.  Proprietor, The Three Swans Gift Shop
WATT, PETER.  Land Conservation and Development Commission,
     Newport, Oregon
WEBB, JAMES.  Lincoln County Planning Director, Newport, Oregon
YOSHINAKA, MARV.  U.  S. Fish and Wildlife Service, Portland,
     Oregon
                             300

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                         APPENDICES
APPENDIX A  —  BIOTIC RESOURCES

    A-l         Common Vegetation of the Biotic Environment

    A-2         Terrestrial Vertebrates of the Southwest
                Lincoln County Study Area

    A-3         Common Biotic Resources of the Marine Environment

    A-4         Common Freshwater and Anadromous Fish of the
                Study Area Streams

    A-5         Correspondence from the Oregon Department of
                Fish and Wildlife


APPENDIX B  —  ARCHEOLOGICAL RESOURCES

    B-l         Correspondence from Oregon State Highway
                Division

    B-2         Correspondence from Richard E. Ross, Oregon
                State University


APPENDIX C  —  WATER QUALITY STANDARDS

    C-l         Water Quality Standards of Surface Waters of
                Oregon

    C-2         Drinking Water Quality Standards and
                Recommendations


APPENDIX D  —  EPA COST EFFECTIVENESS EVALUATIONS
                              301

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   APPENDIX A
BIOTIC RESOURCES
        A-l

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                         APPENDIX A-l

       COMMON VEGETATION OF THE TERRESTRIAL ENVIRONMENT
Common Name
Scientific Name
Beach pine
Bearberry
Sand strawberry
Sand verbena
Sitka spruce
Douglas fir
Rhododendron
Cascara
Western red cedar
Black huckleberry
Salal
Oregon grape
Alder
Salmonberry
Sand binders
Pinus contorta
Arctostaphylos uva-ursi
Frageria chilensis
Abronia latifolia
Picea ¥itchensis
Pseudotsuga menziesii
Rhododendron macropfiylum
Rhamnus purshiana
Thuja plicata
Vaccinium ovatum
Gaultheria shallon
Mahonia nervosa
Alnus rubra
Rubus spectabilis
Poa macrantha
Festuca rubra
Source:  Franklin and Dyrness, 1969.
                            A-2

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                         APPENDIX A-2

          TERRESTRIAL VERTEBRATES OF THE SOUTHWEST
                  LINCOLN COUNTY STUDY AREA
Common Name
Scientific Name
                           Mammals
Dusky shrew
Pacific shrew
Vagrant shrew
Townsend mole
Little brown bat
California myotis
Striped skunk
Spotted skunk
Snowshoe hare
Brush rabbit
Mountain beaver
Douglas squirrel
Beaver
Deer mouse
Oregon meadow mouse
Black-tailed deer
Bobcat
Roosevelt elk
Black bear
Mountain lion
Sorex obscurus
S. pacXficus
£3. vagrans
Scapanus townsendii
Myotis Tucifugus
M. californicus
Mephitis mephitis
Spilogale putorius
Lepus americanus
Sylvilagus bachmani
Aplodontia rufa
Tamiasciurus douglasii
Castor canadensis
Peromyscus maniculatus
Microtus oregoni
Odocoileus hemoinus columbianus
Lynx rufus
Cervus canadensis
Ursus americanus
                            Birds
Common loon
Horned grebe
Double-crested cormorant
Brandt's cormorant
Great blue heron
American wigeon
Pintail
Lesser scaup
Surf scoter
Red-tailed hawk
Marsh hawk
Black oystercatcher
Surfbird
Black-bellied plover
Black turnstone
Least sandpiper
Dunlin
Gavia immer
Podiceps auritus
Phalacrocorax auritus
P. penicillatus
Ardea herpdia"i~
Anas americana
Anas acuta
Aythya affinis
Melanitta perspicillata
Buteo jamaicensis
Circus ayaneus
Haematopus ba"chmani
Aphriza virgata
Pluvialis squaTEarola
Arenaria melanocephala
Calidrfs" minutilla
C. alpina
                              A-3

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Common Name
Scientific Name
                      Birds (continued)
Sanderling
California gull
Band-tailed pigeon
Steller's jay
Common crow
Chestnut-backed chickadee
Golden-crowned kinglet
Starling
Brewer's blackbird
Dark-eyed junco
White-crowned sparrow
Mountain quail
Blue grouse
Crocethia alba
Larus californicus
Columba fasciata
Cyanocitta stelleri
Corvus brachyrhynchos
Parus rufescens
Regulus satrapa
Sturnus vulgaris
Euphagus cyanocephalus
Junco hyemalis oreganus
Zonotrichia leucophrys
Oreortyx picta
Dendragapus obscurus
                         Amphibians
Pacific giant salamander
Olympic salamander
Brown salamander
Rough-skinned newt
Ensatina
Dicamptodon ensatus
Rhyacotriton olympicus
Ambystoma gracile
Taricha granulosa
Ensatina eschscholtzi
Western red-backed salamander Plethodon vehiculum
Tailed frog                   Ascaphus truei
Pacific treefrog              Hyla regilla
Northern red-legged frog      Rana aurora
Bullfrog                      R. catesbeiana
                          Reptiles
Northern alligator lizard
Pacific rubber boa
Red-spotted garter snake
Northwestern garter snake
Gerrhonotus coeruleus
Charina bottae
Thamnophis sirtalis
T. ordinoides
                             A-4

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                         APPENDIX A-3

      COMMON BIOTIC RESOURCES OF THE MARINE ENVIRONMENT
Common Name
         Scientific Name
            Sandy Beaches - Exposed and Protected
Razor clam
Beach hopper
Sand crab
Polychaete worms

Surf smelt
Redtail surfperch
         Siliqua patula
         Orchestoidea sp.
         Emerita analoga
         Nainere'is sp.
         Nereis sp.
         Hypomesus pretiosus
         Amphistichus rhodoterus
Softshell clam
Piddock clam

Littleneck clam
Gaper clam
Cockle
Butter clam
Dungeness crab
Staghorn sculpin
Shiner perch
Starry flounder
Rock greenling
Chinook salmon
Coho salmon
Bay mussel
Ghost shrimp
Mud shrimp
Walleye surfperch
English sole
Surf smelt
Bays and Estuaries

         Mya arenaria
         Zirfaea pifsbryi
         Penitella penita
         Venerupis staminea
         Tresus capax
         Clinocardium nuttallii
         Saxidomus gTganteus
         Cancer magister
         Leptocottus armatus
         Cymatogaster aggregata
         Platichthys stellatus
         Hexagrammos lagocephalus
         Oncorhynchus tshawytscha
         O. kisutch
         Mytilus edulis
         Callianassa californiensis
         Upogebia pugettensis
         Hyperprosopon argenteum
         Parophrys vetulus
         Hypomesus pretios"us
Source:  Gaumer, et.al., 1973.
                              A-5

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                         APPENDIX A-4

            COMMON FRESHWATER AND ANADROMOUS FISH
                  OF THE STUDY AREA STREAMS
Common Name	Scientific Name	

Pacific lamprey*              Lamptera tridentata
Black-nosed dace              Rhinichthys atratulus
Long-nosed dace               R. sp.
Redside shiner                Richardsonius balteatus
Squawfish                     P tychoc he i1us oregonensis
Coho salmon*                  Oncorhynchus kisutch
Cutthroat trout*              Salmo clarki
Steelhead trout*              Salmo gairdneri
Buffalo sculpins              Enophrys bxson
Staghorn sculpin              Leptocottus armatus
* Anadromous


Source:  Smith and Lauman, 1972,
                             A-6

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ROBERT W. STRAUB
    GOVERNOR
                                 APPENDIX A-5
               DEPARTMENT OF
               FISH  AND WILDLIFE
NORTHWEST REGIONAL OFFICE

ROUTE 5,  BOX 325,  CORVALLIS,  OREGON   97330   PHONE  757-4186



                                       February 24, 1976
        Jonathan Ives
        Jones & Stokes Assoc.
        453 Capitol Mall
        Sacramento, California  95814

        Dear Mr. Ives:

        My apologies for the delay in responding to your request.   The
        comments that follow are general in some respects,  but do  reflect
        the current status of wildlife in the area of the project  you're
        dealing with, from Newport to Yachats,  and attempt  to portray
        some possible consequences.

        Wildlife-oriented recreational values are substantial in this
        coastal strip.  The chief "uses" of wildlife are viewing,  bird-
        watching, and photography.  The abundant birds,  in  particular, add
        much to the experience of the recreationist and  traveler.   Hunting
        is a minor use.  Occasional  clearouts which lie  east of Hwy 101
        short distances do provide some deer hunting, but in the zone
        immediately adjacent to the  highway there is little to attract
        hunters and few areas in which hunting is an appropriate activity.
        The Beaver Creek marsh may be lightly hunted for waterfowl.

        Some 145 species of birds,- mammals, reptiles, and amphibians share
        the shorepine-spruce vegetation of the coastal strip, making it
        the richest of all coastal vegetation types in total species
        present.  An additional 20 species of shorebirds occur on  the
        adjacent beaches numbering many thousands of individuals during
        the wintering period.

        Unique or "sensitive" habitats and animal populations are  few,
        but merit protection where they occur.   The following have been
        identified:

             - saltmarsh present along lower Beaver Creek
             - an active heronry in  SW% NE% Sec.l, T14S, R12W, in  Reynolds
               Creek
             - two nesting populations of the rare Snowy Plover, one at
               South Beach, south of the south jetty at  Newport, and one
               at Bayshore, on the north spit of Alsea Bay.
                                     A-7

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Ives
Page 2
2/24/76


A precise evaluation of the impacts of the proposed project is not
possible, as the degree of change which may result cannot be
determined, but some general observations may be made, assuming
that the trend toward increasing development will continue.

     - impacts on hunting will be negligible near Highway 101;
       if development progresses inland, some deer-hunting
       opportunities may be reduced or eliminated.

     - a certain amount of clearing in the dense shorepine -spruce
       vegetation can benefit wildlife—principally  song birds and
       small mammals--bycreating an artificial meadow-forest edge;
       this is evident in may low-density residential areas along
       the coast; benefit can be assumed only if stands of native
       vegetation remain interspersed.

     - development densities comparable to the residential and
       commercial patterns seen in and near the communities of
       Yachats, Waldport, and Newport are obviously inimical to
       maintaining abundant wildlife; substantial areas of native
       vegetation are sacrificed, and with it, adapted species;
       particularly vulnerable are large conifers which in a deca-
       dent condition provide essential habitat for the cavity-
       nesting birds and mammals and the raptors, as these are
       rarely left standing where they are a potential danger to
       life or property.

     - harassment of nesting Snowy Plovers during the April-June
       period probably occurs at current levels of beach use and
       can be expected to intensify with increases in human activity,

I hope this will be of use to you in your evaluation.  If we can
provide more assistance, please contact us.


                              Sincerely Yours,
                              Harold Sturgis'
                              District Wildlife Biologist
                             A-8

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      APPENDIX B
ARCHEOLOGICAL RESOURCES
          B-l

-------
ROBERT W. STRAUB
    GOVERNOR


    F. B. KLABOE
   Administrator and
  State Highway Engineer
                                       APPENDIX B-l
                  OREGON STATE
                  HIGHWAY  DIVISION

                  300 HIGHWAY BUILDING
         SALEM,  OREGON    97310
February 10, 1976
                  Mr. Jonathan H. Ives
                  Jones & Stokes Associates,  Inc.
                  Suite 835 - 455 Capitol  Mall
                  Sacramento, California   95814

                  Dear Mr. Ives:

                       The proposed sewage systems  along  the  Lincoln County
                  coast between Newport and Yachats,  Oregon will be likely
                  to encounter archeological  sites.   I  am, therefore, for-
                  warding a copy of the EIS Task Order  with maps to Prof.
                  Richard Ross of Oregon State  University.  Dr. Ross has been
                  conducting a survey of coastal sites  for this office and
                  his input will be valuable.   In addition, I am sending a
                  second copy of the Task  Order and maps  to Prof.  David Cole
                  of the Oregon Museum of  Natural History in  Eugene.  The
                  Museum is the repository of official  site surveys and reports
                  and should also provide  valuable  input.

                       I am enclosing a copy of all listings  on the Statewide
                  Inventory for Lincoln County.  I  have marked the sites located
                  within the survey area with a red check.  There may be other
                  sites affected which are not  on this  list.  There are at
                  present no sites in the  project area  which  are listed on the
                  National Register.

                       Our office would like to suggest that  Archeological and
                  Historical sites be located by hiring competent  professionals
                  to do ground surveys.
                                             B-2
 Form 81-734-3122

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Mr. Jonathan H. Ives
February 10, 1976
Page 2
     If we can be of further assistance, please feel  free to
contact us.

                           Sincerely,
EL:ko

Enc.
                           Edward T.  Long
                           Preservation Specialist/Archeologist
                           State Historic Preservation Office
                          B-3

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                         APPENDIX  B-2
Department of
 Anthropology
Oregon
. .State .,_
University
Corvallis, Oregon 97331   (503) 754-1515
18 February 1976
Mr. Jonathan H. Ives
Jones & Stokes Associates, Inc.
Suite 835 - 455 Capitol  Mall
Sacramento, California 95814

Dear Mr. Ives:

Edward Long has forwarded a copy of your EIS Task Order on the sewage
systems between Newport and Yachats, Oregon.  This part of the coast
line includes several areas that are sensitive in terms of archaeological
resources.  As a rule of thumb for the Oregon Coast, the estuaries and
the area at the mouth of major rivers and streams, usually include a
high percentage of archaeological sites.  In the designated area of the
EIS, several rivers and streams have their outfall.  The Yaquina estuary
has known sites around the edges, and several are known from the southern
bank.  The Waldport area at the mouth of the A! sea has been known for
quite some time as having quite a number of sites.  The Yachats area
is also known to have a large number of sites.  One of the most important
areas, particularly in view of the alternative plan #4 (proposed project)
is the area around Seal Rock.  Ethnographic sources suggest that Seal
Rock was the northernmost village of the Alsea Indians.  Oregon State
University has conducted archaeological excavations in the vicinity, and
we have reports of several other sites in the area located on private
property.  This would be a very sensitive area for archaeological re-
sources.  There are several other individual sites located between New-
port and Yachats which are fairly large and important but are not part
of a cluster.

Once the site of the plant and the route of the lines has been decided
on I would suggest an intense survey of the right of way be done by an
archaeologist.  In terms of planning it might be more feasible to survey
before final plans are made since the location of sites influence the
placement of the lines themselves.

If you need other information please contact me.

Sincerely, ,
Richard E. Ross
Associate Professor

c: Ted Long
   Dave Cole
                               B-4

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      APPENDIX C
WATER QUALITY STANDARDS
          C-l

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                             APPENDIX  C-l

   WATER  QUALITY  STANDARDS  OF  SURFACE  WATERS OF OREGON


              DEPARTMENT OF ENVIRONMENTAL QUALITY
                             CH. 340
               Division 4

          WATER POLLUTION

                 Subdivision 1

 STANDARDSOF QUALITY FORPUBLIC
 WATERS OF OREGON AND DISPOSAL
 THEREIN OF SEWAGE AND INDUSTRIAL
                  WASTES
  [ED.  NOTE:  Unless  otherwise speci-
fied, sections 41-005 through 41-070 of this
chapter  of  the  Oregon  Administrative
Rules  Compilation  were  adopted by the
Sanitary Authority June 1, 1967, and filed
with the Secretary  of State June 1, 1967
as Administrative Order  SA Z6. Repeals
Administrative Order SA 8.]

  Statutory Authority: ORS  449.080; 449.
                      086

  [NOTE:  Effective  July 1, 1969, theSani-
tary Authority was replaced by the Depart-'
ment of Environmental Quality, consisting
of a  Department and of  a  Commission,
known  as the Environmental Quality Com-
mission. Where Sanitary Authority is pre-
sently  used in these  regulations, it should
be  noted  by readers of these  rules that
Department  of  Environmental  Quality
should  be  substituted unless the context
or  statutes  clearly  require the  use  of
Environmental Quality Commission.]

  41-005  DEFINITIONS. As used in this
subdivision unless otherwise required by
context:
  ( 1 ) "Sewage" means the water-carried
human or  animal waste  from residences,
buildings,  industrial  establishments  or
other  places  together  with such ground
water  infiltration and  surface  water  as
may  be  present.  The   admixture  with
sewage  as  above defined  of  industrial
wastes  or wastes,  as  defined  in  sub-
sections ( 2 ) and ( 3 ) of this section,  shall
also be considered  "sewage"  within the
meaning of this  division.
  ( 2 )  ' Industrial waste" means any liq-
uid,  gaseous, radioactive  or solid  waste
substance  or a  combination thereof re-
sulting  from  any process  of  industry,

2-15-70
manufacturing, trade or business, or from
the development or recovery of any nat-
ural resources.
  ( 3)  "Wastes"  means sewage,  indus-
trial wastes, and all other liquid, gaseous,
solid,  radioactive,  or  other  substances
which  will or may cause pollution or tend
to cause pollution  of any waters  of  the
state.
  (4)  "Pollution" means  such contam-
ination or other alteration of the physical,
chemical or biological  properties  of  any
waters of. the state,  including  change in
temperature,  taste, color, turbidity,  silt
or odor  of  the waters, or such  discharge
of any liquid, gaseous, solid, radioactive
or  other substance  into any  waters  of
the  state  which  either  by  itself  or  in
connection with any other substance pre-
sent,  will or  can reasonably be expected
to create  a  public  nuisance or  render
such waters harmful,  detrimental  or in-
jurious to public health, safety or welfare,
or to  domestic,  commercial , industrial,
agricultural, recreational or other legiti-
mate   beneficial  uses  or  to   livestn. K,
wildlife, fish  or other aquatic life or th*>
habitat thereof.
  (5)  "Waters  of the state"include lakes,
bays, ponds, impounding reservoirs,
springs, wells,  rivers, streams, creeks,
estuaries,  marshes,  inlets, canals,  the
Pacific Ocean within the territorial limits
of the  State of Oregon and all other bodies
of suri'ace or  underground waters, natural
or artificial,  inland  or coastal, fresh or
salt, public or  private (except those pri-
vate  waters  which  do  not  combine or
effect  a  junction  with natural  surface or
underground  waters),  which  are  whollv
or partially within or bordering the state
or within its jurisdiction.
  (6)  "Marine  waters" means all oce-
anic, offshore waters  outside of estuaries
or bays  and within the territorial limits
of the  state of Oregon.
   (7)  "Estuarine waters" means all mix-
ed fresh and  oceanic waters in estuaries
or bays  from the point  of oceanic water
intrusion inland to  a line connecting  the
outermost  points of  the   headlands or
protective jetties.
  (8)  "Standard" or "standards" means
such measure of quality or purity  for  any
waters in relation to their reasonable  and
                                    C-2

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     J X)
ORhGON ADMINISTRATIVE RULES
lu-cessary use as may  be  established by
the Sanitary  Authority  pursuant  to ORS
i .v.;,t»-r  44V.
  ( 9 )  "fish and other aquatic life" means
all beneficial fishes, Crustacea, mollusks,
plankton, higher aquatic plants, and water-
fowl.
  41-010 HIGHEST  AND BEST PRACTI-
CABLE  TREATMENT  AND  CONTROL
REQUIRED.  Notwithstanding the general
and special water quality standards con-
tained in this subdivision, the  highest and
best practicable treatment and/or control
of wastes,  activities and flows  shall in
every  case  be provided so as  to maintain
dissolved oxygen and overall water quality
at the highest possible  levels  and  water
temperatures, coliform bacteria concen-
trations, dissolved  chemical substances,
toxic  materials, radioactivity, turbidities,
color, odor and other deleterious factors
at the lowest possible levels.
  41-015  RESTRICTIONS  ON THE  DIS-
CHARGE OF SEWAGE AND INDUSTRIAL
WASTES  AND  HUMAN ACTIVITIES
WHICH  AFFECT WATER QUALITY  IN
THE WATERS OF THE STATE. No wastes
shall be  discharged  and no activities shall
be  conducted such  that said wastes or
activities either alone or in combination
with other wastes or activities will violate
or  can reasonably be expected to violate,
any of  the genei-al or special water quality
standards  contained in this subdivision.
  41-020 MAINTENANCE OF STANDARDS
OF QUALITY.  (1) The  degree  of waste
treatment  required to  restore and main-
tain the  above standards  of quality shall
be determined in each instance by the De-
partment of  Environmental Quality and
snail be  based upon the following:
  (a) The  uses which are or may likely
be made of the receiving stream.
  (b) The  size  and nature of flow of the
receiving stream.
  (c) The quantity and quality of the sew-
age or wastes to be treated, and
  (c) The  presence  or  absence  of  other
sources  of pollution on the same water-
                   shed.
                     (2) All sewage shall receive a minimum
                   of  secondary  treatment  or equivalent
                   (equal to at least  85% removal of 5-day
                   biochemical oxygen demand and suspend-
                   ed  solids) and shall be effectively disin-
                   fected before  being discharged  into any
                   public waters of the state.
                     (3) All industrial waste  shall  receive,
                   after maximum  practicable  inplant con-
                   trol,  a minimum of secondary treatment
                   or  equivalent  control  (reduction of sus-
                   pended solids and organic material where
                   present in significant quantities, effective
                   disinfection where bacterial organisms of
                   public health are present, and control of
                   toxic or  other deleterious substances)be-
                   fore being discharged into  any public wa-
                   ters of the state.

                     Hist:  Amended   5-24-71 by  DEQ   28
                      41-022 IMPLEMENTATION OF TREAT
                   MENT  REQUIREMENTS  AND  WATE
                   QUALITY  STANDARDS.  Waste treatmfc;
                   and  control  requirements prescribed un-
                   der  41-010,  41-015  and  41-020 and such
                   other waste treatment and controls as may
                   be necessary to insure compliance with the
                   standards  contained  in  this  subdivision
                   shall  be  provided  in   accordance with
                   specific permit conditions for those sour-
                   ces  or activities for which permits are
                   required and the following implementation
                   program:
                      (1) For  new  or expanded waste loads
                   or activities, fully approved treatment or
                   control facilities or both shall be provided
                   prior  to  discharge  of  any  •wastes from
                   the  new or  expanded facility or  conduct
                   of the new or expanded activity.
                      (2) For  existing  waste  loads or acti-
                   vities  necessary treatment or control fa-
                   cilities or both  shall be provided in ac-
                   cordance  with a  specific  program and
                   timetable  incorporated  into the waste
                   discharge  permit for the individual dis-
                   charger or activity. In developing treat-
                   ment  requirements  and  implementation
                   schedules  for existing installations or ac-
                   tivities, consideration shall be given to the
                   impact  upon  the  overall  environmental
                   quality  including  air,   water,  land use
                   and  aesthetics.

                                                 8-15-72
                                      C-3

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                   OKPAKTMLNT OF ENVIRUNMLNTAL DUALITY
                              CH. 340
  Hist: Filed 5-24-71 as DEQ 28
        Amended 6-15-72 by DEQ 46
  41-023  MIXING ZONES.(1) The Depart-
ment may suspend the applicability of all
or  part of the  water  quality standards
set forth in this  subdivision, except those
standards  relating to aesthetic conditions,
witb'r. a defined immediate mixing  zone of
very   limited  size  adjacent  to  or  sur-
rounding the point ol wastewater discharge.
  (2) The  sole  method   of   establishing
such  a mixing  zone shall be by the De-
partment defining same in a   waste  dis-
charge permit.
  (3) In establishing a  mixing zone in  a
waste  discharge permit the Department:
  (a) May define the limits of the  mixing
zone  in terms of distance from the point
of the  wastewater discharge  or  the area
or  volume of the receiving water  or any
combination thereof,
  (b) May set other less restrictive water
quality. standards to be  applicable  in the
mixing  zone   in lieu   of  the suspended
standards; and
  (c) Shall limit the mixing  zone  to that
which in all probability, will
  (A)  not interfere with  any biological
community or population of any important
species to a  degree which ib damaging
to the  ecosystem; and
  (B) not adversely affect any other bene-
ficial use  disproportionately.

  Hist: Filed  7-2-73 as DEQ 55
   41-024 TESTING METHODS. The analyt-
ical testing methods for determining com-
pliance  with the water quality  standards
contained  in this subdivision shall be in
accordance with the most recent  edition
of Standard  Methods for the Examination
of. Water and Waste Water published joint-
ly by the American Public Health Associ-
ation, American Water Works Association,
and  Water Pollution Control  Federation,
unless the Department has published an
applicable superseding method, in which
case testing shall be  in accordance with
the superseding method; provided however
that testing  in  accordance with an alter-
native  method   shall  comply  with  this

8-15-73
section if the Department has  published
the method or  has approved the method
in writing.

  Hist: Filed  7-2-73 as DEQ 55
  41-025  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 Stan-
dards  applicable to specifically designated
waters of the state.  No wastes  shall be
discharged  and no  activities shall be con-
ducted which either alone or in combination
w:<-h other wastes  or  activities will cause
in a^y waters of the state:
  (1)  The  dissolved  oxygen  content of
surface  waters  to be less than six ( 6 )
milligrams  per  liter  unless   specified
otherwise by  special standard.
  ( 2 )   The  hydrogen-ion concentration
(pH) of the  waters to  be outside the range
of  6.5 to 8.5  unless  specified otherwise
by  special standard.
  ( 3)  The  liberation of dissolved gases,
such  as carbon-dioxide, hydrogen sulfide
or  any other gases, in sufficient quantities
to  cause  objectionable  odors  or  to  be
deleterious to fish or other aquatic life,
navigation,  recreation,  or other  reason-
able uses made of such waters.
  { 4)  The  development  of fungi or other
growths  having  a  deleterious  effect  on
stream bottoms, fish or other aquatic life,
or  which are injurious to health, recreation
or  industry.
  ( 5 )  The  creation  of  tastes  or  odors
or  toxic  or  other  conditions  that  are
deleterious  to fish or other  aquatic life
or  affect the  potability of drinking water
or  the palatability  of  fish or shellfish.
  ( 6)  The formation of appreciable bottom
or  sludge deposits or the formation of any
organic  or inorganic deposits deleterious
to  fish or  other  aquatic life or  injurious
to  public health, recreation or  industry.
  ( 7 )  Objectionable  discoloration,  tur-
bidity, scum, oily  sleek or floating solids,
 or coat  the  aquatic  life  with oil films.
  (8) Bacterial  pollution   or  other con-
ditions  deleterious  to waters  used for
domestic  purposes,  livestock watering,
irrigation,  bathing,  or shellfish propaga-
                                       C-4

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CH. 340
OREGON ADMINISTRATIVE RULES
tion,  or be otherwise  injurious to public
health.
  ( 9 ) Any measurable  increase in tem-
perature  when the receiving water tem-
peratures are 64°F. or greater; or more
than 0.5 F. increase due to a single-source
discharge when  receiving  water temper-
atures  are  63.5°F. or  less; or more than
2"F. increase due to all sources combined
when receiving  water temperatures are
62°F. or less.
  (10) Aesthetic  conditions offensive to the
human  senses of  sight, taste, smell or
touch.
  (11) Radioisotope concentrations to ex-
ceed  Maximum  Permissible Concentra-
tions (MFC's) in  drinking water,  edible
fishes  or shellfishes,  wildlife, irrigated
crops,  livestock and  dairy  products or
pose  an external radiation  hazard.
  (12) The concentration of totaldissolved
gas  relative to atmospheric  pressure  at
the point of  sample  collection to  exceed
one  hundred  and  five  percent (105%)  of
saturation, except when stream flow ex-
ceeds the 10-year, 7-day  average flood.

  Hist: Amended 4-5-72 by DEC 39
        Amended 7-2-73 by DEQ 55

  41-030  BENEFICIAL USES OF WATERS
TO BE PROTECTED BY SPECIAL WATER
QUALITY STANDARDS. The Special Water
Quality Standards  contained in this sub-
division  are  adopted for the  purpose  of
protecting, together with pertinent general
water  quality standards,  the  beneficial
uses  of specified waters  of the state as
set forth  in  Table A and to conserve the
waste assimilative capacity of the waters
so as to accommodate maximum develop-
ment and  utilization of the resources of the
state.
  41-035   SPECIAL   WATER  QUALITY
STANDARDS FOR  PUBLIC  WATERS OF
GOOSE LAKE  IN  LAKE COUNTY.  The
provisions  of  this  section  shall  be in
addition to and not in lieu of the General
Water Quality Standards contained inSec-
tion  41-025,  except   where  this  section
imposes  a conflicting  requirement with
the   provisions  of  Section  41-025,  this
section shall  govern. No  wastes shall be
                   discharged  and  no  activities  shall  be
                   conducted which either  alone or in com-
                   bination  with other wastes or activities
                   will  cause in the waters  of  Goose Lake:
                     (1) Dissolved  Oxygen (DO).  DO  con-
                   centrations  to be less than 7 milligrams
                   per liter.
                     ( 2 ) Organisms of the Coliform Group
                   Where  Associated  with Fecal  Sources.
                   (MPN  or equivalent MF  using  a repre-
                   sentative number  of samples)  Average
                   concentrations  of   coliform  bacteria  to
                   exceed   1000  per  100  ml,  with 20%  of
                   samples  not to  exceed  2400  per 100 ml.
                     ( 3 ) Hydrogen  Ion Concentration  (pH).
                   pH  values  to be  outside the  range  of
                   7.5 to 9.5
                     (4) Temperature. Daily average  tem-
                   peratures to  exceed  70° F.  or  the  daily
                   mean ambient air  temperature,  which-
                   ever  is  greater.
                     41-040  SPECIAL WATER QUALITY
                   STANDARDS FOR  PUBLIC  WATERS OF
                   THE MAIN STEM KLAMATH RIVER. The
                   provisions  of  this  section  shall  be in
                   addition  to  and  not in lieu of the General
                   Water Quality Standards contained in Sec-
                   tion 41-025, except  where this section im-
                   poses a  conflicting requirement with the
                   provisions of Section 41-025, this section
                   shall  govern. No  wastes shall  be dis-
                   charged  and no  activities shall be con-
                   ducted  which either  alone  or  in  com-
                   bination  with other wastes  or activities
                   will cause in the waters  of the Klamath
                   River:
                     ( 1)  Dissolved Oxygen (DO).
                     ( a ) (Main stem  Klamath  River  from
                   Klamath Lake  to  Keno  Regulating Dam
                   located approximately 16 river miles above
                   the  Oregon-California  border).  DO con-
                   centrations  of surface  waters to be less
                   than 5 milligrams per liter unless caused
                   by natural conditions.
                     (b) (Main stem  Klamath  River  from
                   Keno Regulating  Dam to Oregon-Califor-
                   nia  border).  DO  concentrations  to  be
                   less than 7 milligrams per liter.
                     ( 2 ) Organisms of the  Coliform Group
                   Where  Associated   with  Fecal  Sources.
                   (MPN or equivalent MF  using  a repre-
                   sentative  number  of  samples). Average
                   concentrations  of  coliform  bacteria to

                                                8-15-73
                                     C-5

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                          APPENDIX C-2

 DRINKING WATER QUALITY STANDARDS AND  RECOMMENDATIONS
                         USPHS
OSBH
AWWA
Color (units)                15
Turbidity Otu)               5
Total Solids (mg/1)          500
Hardness (mg/1)             —
Bicarb. Alkalinity (mg/1)      -
Sulfate (mg/1)              250
Nitrates (mg/1)              45
Iron                       0.3
Fluoride (mg/i)               I*
Chloride (mg/1)            250
Magnesium (mg/1)            —
Manganese                  0.05
Aluminum (mg/1)
  15
   5
500

 120
250
  45
   0.3
   1*
250
 125
   0.05
   3
   0.1
 200
  80
  **
 250

   0.05
   1*
   0.01
   0.05
USPHS   U. S. Public Health  Service (standard)
OSBH    Oregon State Board of  Health (standard)
AWWA    American Water Works Association (recoratiendation)

*  Varies with tenperature.
** Not to change more than 1.0 mg/1 in distribution system or in
   12 hours at 130°F in  closed plastic bottle.
                                C-6

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          APPENDIX D
EPA COST EFFECTIVENESS EVALUATIONS
               D-l

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                               APPENDIX D

        To compare the monetary cost of project alternatives, EPA requires
that costs be compared using  the  EPA Cost-Effectiveness Guidelines, as
published in the "Federal  Register", Vol. 39, No. 29, February 11, 1974.
These guidelines have been utilized in the following cost-effectiveness
guidelines, with the exception that an interest rate of 6-1/8% was utilized,
per EPA instructions.
        According to these guidelines, a  20-year planning period must be
utilized for sizing of interceptor, treatment, and outfall facilities.
This criteria does not, however,  restrict the actual sizing of facilities to
only that required for a 20-year  population growth if the EPA Regional
Administrator approves a larger size as being more cost effective.
        To determine treatment capacity for the 20 year period from 1977
(the probable year that construction would be initiated) to 1997, the estimated
1997 peak population of 4460  was  multiplied by 140 gallons per capita per day.
This resulted in a required 1997  capacity of 625,000 gallons per day, which
was rounded off to 650,000 gallons per day.  Treatment capacities used  in
the cost calculations were:

        Alternative 1   -   Waconda Beach               0.35 mgd
                           San Marine           •       0.30 mgd
        Alternative 2   -   Waldport                     0.35 mgd
                           Yachats                "     0.30 mgd
        Alternative 3   -   Big Creek               .     0.65 mgd
        Alternative 4   -   Yachats                      0.65 mgd
                                     D-2

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        Alternative 5   -   Waldport                     0.65 mgd
        Alternative 6   -   No action alternative,  i.e., no facilities
        Alternative 7   -   Aerobic digestion facilities only

        Interceptor costs were based upon costs  presented in the  Facilities
Plan.  Interceptors were sized according  to  DEQ  requirements of 250 gallons
per capita per day, a minimum velocity of 2  feet per second, and  a  minimum
diameter of 8 inches.
                                     D-3

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                     20-YEAR  COST-EFFECTIVENESS ANALYSIS
                             ALTERNATIVE NO. 1
CAPITAL COSTS
COST OR VALUE
        Initial  1997 Costs
             Interceptors &  Pump Sta.   $1,497,100
             Treatment Plants           $1,619,000
             Outfalls                  $  900,000
        1997 Salvage Value              $1,708,500
                                           SUBTOTAL
       1977
  PRESENT WORTH
FOR 20-YEAR PERIOD
                       $1,497,100
                       $1,619,000
                       $  900,000
                     - $  520,300
                       $3,495,800
ANNUAL COSTS
        Average Cost/Year  -  1977-1997
            Interceptors & Pump Sta,
            Treatment Plant
        1987 Replacement Costs
            Treatment Plant
   $  8,000/yr
   $ 30,000/yr

   $ 30,000
       SUBTOTAL
   $  90,800
   $ 340,600

   $  16,600
   $ 448,000
                    TOTAL  1977  PRESENT WORTH
                       $3,943,800
      NOTE:  Interest rate  =  6-1/8%
                                    D-4

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                     20-YEAR COST-EFFECTIVENESS ANALYSIS
                              ALTERNATIVE NO. 2
CAPITAL COSTS
        Initial 1997 Costs
            Interceptors & Pump  Sta.
            Treatment Plant
            Outfall
        1997 Salvage Value
COST OR VALUE

$ 1,725,600
$ 1,328,400
$   108,000
$ 1,317,800
      SUBTOTAL
      1977
  PRESENT WORTH
FOR 20-YEAR PERIOD
   $1,725,600
   $1,328,400
   $  108,000
-  $  401.300
   $2,760,700
ANNUAL COSTS
        Average Cost/Year  -  1977-1997
            Interceptors & Pump Sta.
            Treatment  Plant
        1987 Replacement Costs
            Treatment  Plant
$  8,000/yr
$ 30,000/yr

$ 30,000
      SUBTOTAL
   $   90,800
   $  340,600

   $   16.000
   $  447,400
                       TOTAL 1977 PRESENT WORTH
                       $3,208,100
            NOTE:   Interest rate = 6-1/8%
                                    D-5

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                     20-YEAR COST-EFFECTIVENESS ANALYSIS
                               ALTERNATIVE NO. 3
CAPITAL COSTS
        Initial  1997 Costs
            Interceptors  &  Pump  Sta.
            Treatment Plant
            Outfall
        1997 Salvage Value
COST OR VALUE

$1,497,100
$1,011,600
$  450,000
$1,255,700
     SUBTOTAL
      1977
  PRESENT WORTH
FOR 20-YEAR PERIOD
   $1,497,100
   $1,011,600
   $  450,000
-  $  382.400
   $2,576,300
ANNUAL COSTS
        Average Cost/Year -  1977-1997
            Interceptors  & Pump  Sta.
            Treatment Plant
        1987 Replacement  Costs
            Treatment Plant
$   8,000
$  26,000

$  17,000
      SUBTOTAL
   $  90,800
   $ 295,200

   $   9,400
   $ 395,400
                        TOTAL  1977  PRESENT WORTH
                    $2,971,700
        NOTE:   Interest rate  =  6-1/8%
                                     D-6

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                     20-YEAR COST-EFFECTIVENESS ANALYSIS
                               ALTERNATIVE  NO. 4
CAPITAL COSTS
        Initial 1997 Costs
            Interceptors & Pump Sta.
            Treatment Plant
            Outfall
        1997 Salvage Value
COST OR VALUE

$1,765,200
$  828,000

$1,095,900
       SUBTOTAL
      1977
  PRESENT WORTH
FOR 20-YEAR PERIOD
   $1,765,200
   $  828,000

 - $  333,700
   $2,259,500
ANNUAL COSTS
        Average Cost/Year -  1977-1997
            Interceptors  & Pump Sta.
            Treatment Plant
        1987 Replacement  Costs
            Treatment Plant
$   8,000
$  26,000

$  17,000
      SUBTOTAL
   $  90,800
   $ 295,200

   $   9,400
   $ 395,400
                       TOTAL 1977 PRESENT WORTH
                       $2,654,900
        NOTE:   Interest  rate = 6-1/8%
                                     D-7

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                     20-YEAR COST-EFFECTIVENESS ANALYSIS
                             ALTERNATIVE NO. 5
CAPITAL COSTS
      •  Initial 1997 Costs
            Interceptors  &  Pump  Sta.
            Treatment Plant
            Outfall
        1997 Salvage Value
COST OR VALUE

$1,643,400
$  828,000
$  108,000
$1,089,000
      SUBTOTAL
      1977
  PRESENT WORTH
FOR 20-YEAR PERIOD
   $1,643,400
   $  828,000
   $  108,000
   $  331,600
   $2,247,800
ANNUAL COSTS
        Average Cost/Year -  1977-1997
            Interceptors  & Pump  Sta.
            Treatment Plant
        1987 Replacement  Costs
            Treatment Plant
$
$
$

8,000
26,000
17,000
SUBTOTAL
$
$
$
$
90,800
295,200
9,400
395,400
                        TOTAL  1977  PRESENT WORTH
                       $2,643,200
        NOTE:   Interest rate  =  6-1/82
                                     D-8

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                     20-YEAR COST-EFFECTIVENESS ANALYSIS
                              ALTERNATIVE  NO.  7
                                                                    1977
                                                                 PRESENT  WORTH
CAPITAL COSTS                                COST OR VALUE     FOR  20-YEAR  PERIOD
        Initial 1977 Costs
            Treatment Plant (Aerobic
              digestion and sludge  dewatering)   $  220,000         $ 220,000
            Outfall
        1997 Salvage Value                      $   82,500         $  25,100
                                                     SUBTOTAL     $ 194,900
ANNUAL COSTS
        Average Cost/Year -  1977-1997
            Pumper Truck  & Driver             $  30,000/yr        $ 340,600
            Sludge Treatment Facilities       $  15,000/yr        $ 170,300
        1987 Replacement  Costs
            Treatment Plant
            NOTE:   Interest rate = 6-1/8%
                                                  SUBTOTAL       $ 510,900
                       TOTAL 1977 PRESENT WORTH                  $ 705,800
                                     D-9

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