EPA 910/9-75-013
JANUARY 1976
EPA-IO-IDA-FREMONT-ISLAND PARK AREA-WWTW-75
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FINAL
ENVIRONMENTAL IMPACT STATEMENT
NORTH FREMONT COUNTY
WASTEWATER FACILITIES
EPA Project No. C-160186-01
Prepared by
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
SEATTLE, WASHINGTON 98101
January 1976
Cliffor/i^. Smith, Jr.", Ph.D.
Administrator
Date:
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Ill
PREFACE
On September 19, 1975 EPA released to the public a draft EIS
on a project proposal by Fremont County, Idaho to provide sewerage
facilities for four sub-areas in the Island Park Area. The EPA
"significant action" requiring this EIS is the approval of the
County's facilities plan and the subsequent awarding of Step II de-
sign and Step III construction grant funds. During the public com-
ment period, 13 letters were received commenting on the draft EIS.
Three of these were from individuals living in the Yale Creek por-
tion of the I.P. Bill's Island sub-area, the remainder from State
and Federal agencies and the League of Women Voters. These letters
and EPA's response are contained in a new Chapter VIII in this final
EIS, entitled "Comments to the draft EIS and Responses". Where re-
quired, changes have also been made to the body of the EIS; these
changes have been minor in nature.
This EIS is being written utilizing a trial concept called the
"layering approach", wherein the draft EIS is built upon the faci-
lities plan as a base. The draft EIS for this project actually was
bound together with the County's facilities planning study. The
advantage of this technique is the savings in time and expense of
producing the EIS, and the ease with which the public can assimilate
the information necessary for decision-making. The EIS is therefore
shorter, non-duplicative of the environmental assessment contained
in the facilities plan, and issue-oriented. This final EIS, however,
is being published as a separate document without the facilities
planning study that accompanied the draft. We expect that this will
not present a problem, since our distribution list is the same as
for the draft. Cost of producing the entire document again would
have been prohibitive.
The principal concern prompting this EIS was the possibility
of the proposed project resulting in significant secondary impacts
on the natural resources in the Island Park area; that is, the pro-
ject might encourage excessive residential, commercial, and recre-
ational development that would have significant adverse effects on
wildlife, water quality, and aesthetic and recreation values. Re-
sponses to the draft EIS did not indicate this to be a common con-
cern. Rather, supporters of the project felt that the long-term
water quality benefits and the possibility of controlling future
development far outweighed potential adverse impacts. EPA also
concluded that the project as proposed was basically acceptable
environmentally, had immediate and long-term significant water qual-
ity benefits, and was necessary to protect and enhance existing en-
vironmental quality. EPA, therefore, concurs in the proposed pro-
ject, with conditions as specified in the following discussion.
Both the Idaho Historical Society and the President's Advisory
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IV
Council on Historic Preservation declared the coverage of historical,
architectural, cultural and archaeological features of the project to
be inadequate. EPA, therefore, contracted with Professor Robert
Butler, Acting Chairman of the Idaho State University Department of
Anthropology, for the conduct of an archaeological survey of the
Island Park area. A final report of this survey's findings is in-
cluded in this final EIS as Appendix A. It suggests that artifacts
may exist in the project area and suggests the location of test pits
prior to sewerage system excavation. EPA is therefore recommending,
as a mitigative measure, the following grant condition:
Fremont County shall, prior to the commencement of construction
excavation activities in the project sub-areas, comply with the
recommendations contained in the Final Report of Archaeological
Survey by Prof. B. Robert Butler, dated December 23, 1975.
Test pit excavations shall be made and they shall be evaluated
by the Idaho State Historical Society, which will provide recom-
mendations regarding further development.
Several letters of comment on the draft EIS expressed the con-
cern that inadequate evaluation was given to the use of private
lands for waste treatment and disposal facilities as compared to
the use of "low cost" public lands under control of the U.S. Forest
Service or Bureau of Land Management. The County's consultant has
agreed to further cost-effectiveness evaluation of treatment and
disposal sites. EPA, therefore, suggests the following grant con-
dition:
Prior to final approval of the facilities plan, the County
shall present the results of cost-effective evaluation of
private and public lands for sub-area treatment and disposal
sites, using actual site costs whenever available. Prior ap-
proval of the appropriate agency shall be obtained for pro-
posed use of any specific sites located on public lands.
Finally, the area of concern which EPA feels to be the key
consideration in the avoidance of future adverse secondary impacts
associated with growth and development within the project area is
the extent to which Fremont County develops, adopts and implements
an effective comprehensive land use plan with necessary zoning or-
dinances. It is our conclusion that the growth projections suggested
by the County are reasonable, and that this growth will occur with
or without the project. In the absence of sewers, growth will occur
in a more haphazard and less controlled fashion, and perhaps over a
longer period of time. Effective land use planning and zoning then
becomes a key component in controlling growth. With this management
tool properly utilized, EPA feels that the provision of a sewerage
system can actually help to insure that development occurs in an
orderly fashion that helps protect environmental quality. The
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County should be assisted in the development and implementation of
land use planning by agencies having land use management responsi-
bilities and the technical expertise for evaluating the carrying
capacity of the Island Park natural, physical, human and related
resources. EPA feels the following grant condition to be necessary:
Fremont County shall, in accordance with the State of Idaho
Local Planning Act of 1975 (Chapter 65, Title 67, Idaho Code),
develop and properly adopt a comprehensive land use plan and
implementing zoning ordinances applicable to the project area.
The comprehensive plan shall include the participation of land
use management agencies in its formulation, implementation, and
regular review and evaluation. Agencies considered for parti-
cipation shall include such agencies as the Idaho State Land
Board; the Idaho Department of Fish and Game; the Forest Service,
U.S. Department of Agriculture; and the Bureau of Land Manage-
ment, U.S. Department of Interior. This condition shall be
applicable to the Step II design grant and, as the project
progresses, shall be carried over to apply to the Step III
construction grant award. Payment beyond 80% on the Step III
construction grant shall be contingent upon the satisfaction
of this condition.
EPA submits this final EIS for a public review period of 30 days,
during which time comments are invited. Following this review period,
the Regional Administrator of EPA will make a determination concerning
approval of Fremont County's facilities plan and eligibility of the
project for subsequent design and construction grants.
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TABLE OF CONTENTS
CHAPTER
II
III
IV
V
VI
VII
VIII
Summary Sheet
Distribution List
Background and Description of
Proposed Action
Project Alternatives
Environmental Impacts of the Proposed
Action
Adverse Impacts That Cannot Be Avoided
Relationship Between Local Short Term
Uses of Man's Environment and the
Maintenance and Enhancement of Long
Term Productivity
Irreversible and Irretrievable Commit-
ments of Resources to the Proposed
Action Should It Be Implemented
Outside Participation
Comments to the draft Environmental
Impact Statement and Responses
Appendix A
Bibliography
PAGE
ix
xi
1
17
23
27
31
33
35
37
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IX
SUMMARY SHEET
NORTH FREMONT COUNTY, IDAHO
WASTEWATER FACILITIES
E.P.A. PROJECT NO. C-16 0186-01
ENVIRONMENTAL IMPACT STATEMENT
Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
1. Type of Statement: Draft ( ) Final (x)
2. Type of Action: Administrative
3. Brief Description: The EPA administrative action necessitating
this Environmental Impact Statement is the awarding of grant funds to
Fremont County, Idaho, for the design and construction of sewerage
facilities serving the Island Park area.
3. Summary of Impacts: The project would result in the elimina-
tion of septic tank discharges of inadequately treated domestic sewage
to surface and groundwaters. There is currently documented contamination
of these waters with levels of fecal coliform in excess of State and
Federal standards, in some cases constituting significant health hazards.
Provision of collection, interceptor, and treatment facilities would have
the effect of accelerating recreational demand, with associated secondary
effects such as increased noise, traffic, and recreational pressure.
The provision of facilities phased over time in specific sub-areas
should serve to help control growth and reduce undesired sprawl.
4. Alternatives Considered:
Treatment Processes: Chemical-Biological
Physical-Chemical
Physical-Chemical with Biological pre-
treatment
Non-aerated Facultative Lagoon
Aerated Lagoon
System Configuration: Regionalization
Sub-Areas (six)
Sub-Area Zones
Treatment Sites
No project (or delayed action)
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5. Distribution: The agencies, groups and individuals
on the mailing list for this environmental impact statement
are attached.
6. Availability: Date this Final EIS made available
to CEQ and the Public: |^v; j 9
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XI
U.S. Dept. of Agriculture
State Conservationist
Soil Conservation Service
8th and Bannock
Boise, Idaho 83702
Area Conservationist
Soil Conservation Service
Bennett Avenue
Idaho Falls, Idaho 83401
Department of the Army
Corps of Engineers
Walla Walla District
City County Airport
Walla Walla, WA 99362
Mr. Bruce Blanchard, Dir.
Office of Environmental
Project Research
The Interior Building
Washington, D.C. 20240
District Conservationist
Soil Conservation Service
U.S. Dept. of Agriculture
115 East Main
St. Anthony, Idaho 83445
Fish and Wildlife Service
Bureau of Sport Fisheries
and Wildlife
550 West Fort
Boise, Idaho 83702
Off. of Fed. Activities
(A-104)
Env. Protection Agency
1750 K St., N.W., Rm 440
Washington, D.C. 20460
Off. of Legislation (A-102)
Env. Protection Agency
Room 3105, WSM
Washington, D.C. 20460
Off. of Pub. Affairs (A-107)
Env. Protection Agency
Room 3014, WSM
Washington, D.C. 20460
Exec. Office of the President
The Council on Environmental
Quality
722 Jackson Place, N.W.
Washington, D.C. 20006
Office of the Secretary
U.S. Department of Agriculture
Coordinator of Environmental
Quality Activities
Washington, D.C. 20250
U.S. Department of Agriculture
Attn: Mr. Stanley I. Trenhaile
Regional Representative
Room 4034, Federal Office Bldg.
Seattle, Washington 98101
Fish and Wildlife Service
L. Edward Perry, Actg. Reg. Dir.
1500 N.E. Irving Street
Portland, Oregon 97208
Regional Environmental Officer
Dept. of Health, Ed. & Welfare
Arcade Plaza Bldg.
1321 Second Avenue
Seattle, WA 98101
John Merrill, Asst. Reg. Admin.
for Community Plan. & Mgt.
Housing & Urban Development
1321 2nd Ave., Arcade Plaza
Seattle, WA 98101
Donald Samuelson, Reg. Rep.
Dept. of Transportation, Reg. X
Arcade Plaza Bldg.
1321 Second Avenue
Seattle, WA 98101
Oil & Special Materials Div.
Water Prog. Operations (WH-548)
Environmental Protection Agency
Room 2106, Waterside Mall
Washington, D.C. 20460
The Post-Register
333 Northgate Mile
Idaho Falls, Idaho 83401
Attn: Chris Dunagon
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xii
Bills Island Association
Bills Island
Island Park, Idaho 83429
Ernest E. Sligh, Director
Env. Impact Div., F.E.A.
New Post Office Bldg.
12th & Pennsylvania Ave. N.W.
Washington, D.C. 20461
John D. McDermott, Director
Off. of Review & Compliance
Adv. Council on Hist. Preserv.
P.O. Box 25085
Denver, Colorado 80225
Forest Supervisor
Targhee National Forest
430 North Bridge Street
St. Anthony, Idaho 83401
U.S. Dept. of Agriculture
Forest Service
Targhee National Forest
Island Park Ranger Station
Island Park, Idaho 83429
Adv. Council on Hist. Preserv.
Office of Arch. & Env. Pres.
Suite 430, 1522 K St., N.W.
Washington, D.C. 20005
Mr. Clayter Forsgren
Forsgren, Perkins & Assoc.
350 North Second East
Rexburg, Idaho 83440
Mr. G.A. Lang
Henry's Lake
Mack's Inn, Idaho 83433
State of Idaho
Department of Agriculture
4696 Overland Road
Boise, Idaho 83705
State of Idaho
Dept. of Fish & Game
600 S. Walnut St., Box 25
Boise, Idaho 83707
State of Idaho
Dept. of Parks & Recreation
2263 Warm Springs Avenue
Boise, Idaho 83720
State of Idaho
Bureau of Mines & Geology
2121 College Blvd.
Boise, Idaho 83706
State of Idaho
Soil Conservation Commission
801 Capitol Boulevard
Boise, Idaho 83720
State of Idaho
Water Resource Board
373 West Franklin
Boise, Idaho 83720
State of Idaho
Dept. of Public Lands
Beeches Corner
Idaho Falls, Idaho 83401
State of Idaho
Dept. of Fish and Game
1515 Lincoln Road
Idaho Falls, Idaho 83401
State of Idaho
Department of Fish and Game
St. Anthony, Idaho 83445
Mr. Edward Torey
Izaak Walton League of America
1621 Filmore Street
Caldwell, Idaho 83605
Dr. Lee Stokes, Administrator
Division of Environment
Dept. of Health and Welfare
The Statehouse
Boise, Idaho 83720
Mr. Henry Moran, Supervisor
Division of Environment
Dept. of Health and Welfare
636 Pershing Street
Pocatello, Idaho 83201
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xiii
Mr. Bruce Arnell
Dept. of Health & Welfare
District Seven Health Dept.
P.O. Box 213
Rexburg, Idaho 83440
Fremont County Commissioners
Fremont County Court House
Box 248
St. Anthony, Idaho 83445
Fremont County Planning
Commission
Fremont County Courthouse
Box 248
St. Anthony, Idaho 83445
Idaho Conservation League
Attn: Marcia Pursley
P.O. Box 844
Boise, Idaho 83701
County Attorney
Fremont County Courthouse
Box 248
St. Anthony, Idaho 83445
Mr. Russell Brown
Idaho Environmental Council
P.O. Box 1708
Idaho Falls, Idaho 83401
Mr. Richard Schwarz
Idaho Wildlife Federation
P.O. Box 2363
Boise, Idaho 83401
Mrs. Marjorie Slotten
Idaho League of Women Voters
P.O. Box 815
Twin Falls, Idaho 83301
Mrs. Doli Obee
Environmental Quality Committee
329 South Phillippi Street
Boise, Idaho 83705
Dr. Kenneth Cameron
Northwest Steelheaders Council
of Trout Unlimited
910 North Curtis Road
Boise, Idaho 83702
Mr. Justin Naderman
Sierra Club, N. Rockies Chapter
409 Whitman Hall
University of Idaho
Moscow, Idaho 83843
Mr. Darrell Gallup
Soil Conservation Society of America
Room 345, 305 North 8th Street
Boise, Idaho 83702
Mr. William Meiners
The Wildlife Society, Idaho Chapter
7717 Ustick Road
Boise, Idaho 83704
Rexburg Boat Club
Bill's Island
Island Park, Idaho 83429
Mr. Art Fransen
Mack's Inn
Mack's Inn, Idaho 83433
Mr. & Mrs. O.K. Shoemaker
2905 Greentree Lane
Idaho Falls, Idaho 83401
Mrs. Z.L. Eaton
355 East Elm
Shelley, Idaho 83274
Mr. and Mrs. Clark Kesler
Island Park
Idaho 83429
Mr. and Mrs. Bryce Adkins
Island Park
Idaho 83429
Mr. and Mrs.
Island Park
Idaho 83429
Carl A. Krah
Mr. and Mrs. Smith Orgill
Island Park
Idaho 83429
Mr. Thomas Murdoch
Mack's
Idaho
Inn
83433
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XIV
Mr. Ken Groom
Mack's Inn
Idaho 83433
Mr. Les Vandozer
Mack's Inn
Idaho 83433
Mr. George Harriot
Mack's Inn
Idaho 83433
Mr. and Mrs. O.A. Thomas
Henry's Lake
Mack's Inn, Idaho 83433
Mr. and Mrs. Norman Hillam
Bill's Island
Island Park, Idaho 83429
Mr. Donald B. Todd
Island Park
Idaho 83429
Mr. W.P. Gentry
Island Park Lodge
Island Park, Idaho 83429
Mr. I.P. Bills
Bills Island
Island Park, Idaho 83429
Mr. Harold A. Cummings
Bills Island
Island Park, Idaho 83429
Henry's Lake Lodge
Mack's Inn
Idaho 83433
Mr. and Mrs. Jack Thomas
Pinehaven
Island Park, Idaho 83429
Mr. and Mrs. J.P. Longwell
Pinehaven
Island Park, Idaho 83429
Big Springs Resort
Mack's Inn, Idaho 83433
Mack's Inn Resort
Mack's Inn, Idaho 83433
Pond's Lodge
Island Park, Idaho 83429
National Marine Fisheries Service
NOAA
Department of Commerce
P.O. Box 4332
Portland, Oregon 97208
National Wildlife Federation
1412 16th Street, N.W.
Washington, B.C. 20036
State of Idaho
Department of Lands
Room 119, The Statehouse
Boise, Idaho 83720
Division of Environment
Dept. of Health and Welfare
Region Seven
1655 South Woodruff Ave.
Idaho Falls, Idaho 83401
Mr. and Mrs. Rex T. Moore
251 Wayne Avenue
Pocatello, Idaho 83201
Mr. Richard G. Hackworth
247 N. 12th
Pocatello, Idaho 83201
Mr. and Mrs. W.H. Shiflett
330 W. Chubbuck Road
Comeloh Estates #36
Pocatello, Idaho 83201
Prof. B. Robert Butler
Box 8183
Idaho State University
Pocatello, Idaho 83209
Idaho State Planning & Community Affairs
Division of Budget Policy Planning &
Coordination
Room 122
Statehouse
Boise, Idaho 83720
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CHAPTER I
BACKGROUND & DESCRIPTION OF PROPOSED ACTION
Background & History
On June 3, 1974, EPA Region X's Idaho Operations Office received
from the State of Idaho, Fremont County's application for financial
assistance for wastewater facilities planning. The application requested
approximately $75,000 in Federal funds and $15,000 in State funds to
perform the $100,000 "Step I Facilities Planning" Study of water
quality problems in the Island Park area. Processing of the applica-
tion was completed and the grant awarded to Fremont County on July 31,
1974. The firm of Forsgren, Perkins, & Associates, Consulting Engineers
in Rexburg, had already been retained to accomplish the work. A first
draft of the report was published in November 1974, followed by meetings,
public hearings, and additional field study. The final draft was com-
pleted in June 1975; additional public hearings were held in St. Anthony
on July 2 and in Island Park (Mack's Inn) on July 19. The final North
Fremont County Sewer Facilities Planning Study was released on July 28,
1975.
EPA's Environmental Responsibilities and Activities
The National Environmental Policy Act of 1969 (NEPA), Public Law
91-190, required all Federal agencies to, ". . . utilize a systematic,
interdisciplinary approach which will insure the integrated use of the
natural and social sciences and the environmental design arts in planning
and in decision-making which may have an impact on man's environment . ."
Section 102(2)(C) of that Act also requires the agency to prepare an
environmental impact statement (EIS) on, ". . . major Federal actions
significantly affecting the quality of the human environment ..."
This is to be accomplished in consultation with the Council on Environ-
mental Quality (CEQ), established by Title II of the Act.
One of the major EPA programs involving actions which are candidates
for EIS's is the construction grants program as authorized by Title II -
Grants for Construction of Treatment Works, Section 201(g)(l), of the
Federal Water Pollution Control Act Amendments of 1972 (FWPCA), (Public
Law 92-500). The Act authorizes the Administrator, EPA, ". . . to make
grants to any State, municipality, or intermunicipal or interstate
agency for the construction of publicly owned treatment works ..."
The Regional Offices, in turn, have been delegated the authority to
fund State-approved wastewater treatment projects. Concurrent with all
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of these authorities is the responsibility to assure Federal funds will
produce a project which will have maximum beneficial effects on the
environment and minimum adverse effects.
The Public Laws quoted above, along with the CEQ and EPA Regula-
tions, constitute the authority and responsibility for the preparation
of environmental impact statements on w^stewater treatment works or
facilities or areawide wastewater management plans when deemed necessary
by the Regional Offices of EPA. Final regulations for the preparation
of environmental impact statements by EPA were published in the Federal
Register, Volume 40, No. 72 on 14 April 1975. Under these regulations,
an "environmental impact statement is a report prepared by EPA, which
identifies and analyzes in detail the environmental impacts of a pro-
posed EPA action and feasible alternatives." With regard to Fremont
County, municipalities and local agencies are required, when planning
for construction of publicly owned treatment works, to evaluate the
environmental impacts of the construction and subsequent operation of
the treatment works and to prepare an environmental assessment. This
assessment was presented in the Facilities Plan. EPA must review the
assessment, collect corroboratory evidence when necessary and, ultimately,
issue a negative declaration or, if the project is expected to have
significant adverse primary or secondary effects or to be highly
controversial, prepare an environmental impact statement, as has occurred
in this case.
In the case of Fremont County's proposed project for the Island
Park area, EPA actively participated in the review of the County pro-
posal. The need for a thorough environmental assessment was discussed
with the grantee and their consultant in pre-application meetings held
on March 27 and May 12, 1974 in the project area. The possibility of
controversy, the nature of the sensitive environment, and the potential
for significant land use changes identified this project from early on
as a candidate for an environmental impact statement (EIS). Field
inspections of the project area were made on several occasions by Region
X EPA staff. As EPA conducted its environmental review as required by
the April 14, 1975 Regulations, the grantee's assessment contained in
the Facilities Plan was evaluated and determined to be generally satis-
factory from a technical and environmental standpoint. Although signi-
ficant public controversy was not demonstrated by the public hearings
or during following comment periods, careful review of the criterion
contained in 40 CFR 6.510 clearly indicated an EIS to be required.
Principal concerns are:
1. The extent to which continued recreational development will
impact the area resources;
2. The extent to which the availability of sewerage facilities
will induce land use changes or rate changes?
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3. The absence of local land use planning which might serve to
control development or mitigate adverse impacts; and
4. Significant adverse secondary effects on ecosystems in gen-
eral and especially on fish and wildlife habitat.
EPA Region X, therefore, issued a Notice of Intent to Prepare an
EIS on August 18, 1975. This document is that EIS, and constitutes
an independent evaluation by EPA of the social, economic, environmental,
and engineering aspects of the project. In an effort to keep the EIS
as short as possible, the County's Sewer Facilities Planning Study dated
July 28, 1975, was attached to the draft EIS as a part of the EIS, with
reference to the Study throughout the text. All references to text,
figures, and tables made in this final EIS also will be to the County's
Sewer Facilities Planning Study unless otherwise stated.* Other plan-
ning documents, engineering reports, and correspondence received on the
project have also been taken into consideration in preparing this EIS.
The Study Area
The Study area includes the entire north half of Fremont County,
more generally referred to as the "Island Park Area." The City of
Island Park actually has corporate boundaries running from the Last
Chance - Pond's Lodge area on Highway 20 in the south some 29 miles
north to the Valley View Ranch north of Mack's Inn on Highway 20, al-
though most of the area included is restricted to the property immediately
adjacent to the highway. The entire Study area is best shown on Figure 3,
and consists of State-owned lands, public lands managed by the U.S. Forest
Service (Targhee National Forest) and Bureau of Land Management, and
private land.
Actual sub-areas selected for detailed study are as follows:
Figure 4 - Henry's Lake
Figure 5 - Mack's Inn - Island Park Lodge
Figure 6 - Big Springs - Moose Creek
Figure 7 - I.P. Bill's Island - Yale Creek
Figure 8 - Last Chance - Pond's Lodge
Figure 9 - Pinehaven
For the purpose of this Study, these sub-areas comprise the project
area described as the "Island Park Area," since they are principally
centered around the town of Island Park and Island Park Reservoir. They
represent the principal areas of development now experiencing water
quality problems suggesting a need for sewerage facilities. These sub-
areas were further divided into zones to facilitate the cost-effective
analysis.
* Because the mailing list of this final EIS largely duplicates that
of the draft EIS, and because of the cost of again reproducing the
County's Sewer Facilities Planning Study, readers are requested to
refer to Attachment 1 of the Fremont County draft EIS for these references.
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The Study
Authorization & Need: On March 10, 1970, the County authorized
Forsgren, Perkins, & Associates to prepare the Comprehensive Sewer and
Water Plan, completed in November of 1971. Although this Study covered
the general need for sewerage facilities in the Study sub-areas described
above, the sources of pollution had not been adequately identified.
Little specific water quality data had been collected for parts of the
sub-areas, particularly for chemical constituents. During the same time
period, Federal requirements relating to the type of studies which needed
to be performed in support of applications for financial assistance were
changing fast, particularly with passage of the Federal Water Pollution
Control Act Amendments of 1972, P.L. 92-500. The County, therefore,
authorized preparation of the North Fremont County Sewer Facilities
Planning Study,
Objectives & Scope: The stated objectives of the Study were:
1. To make an inventory of environmental conditions.
2. To provide guidelines for correction of environmental problems
identified in the Study.
3. To accurately define water quality problems through an in-depth
investigation designed to identify types and sources of contamination.
4. To determine if sewage treatment facilities are needed in the
Study area; and, if so, where to locate them.
5. To determine the most practical and environmentally sound waste
management system, if such were deemed necessary.
6. To provide baseline data to measure the effects of corrective
action, and to serve as a reference source for future growth and develop-
ment within the Study area.
The parameters of the investigation were:
1- Identification of contaminant types alleged to be in the
waters of the Study area.
2. Identification of sources of any contaminants located.
3. Identification of existing environmental conditions to include
topography, climate, geology, soils, hydrology, water quality and
quantity, land use, sensitive areas and organisms and the biology of
the area.
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Areas of possible recommendations were to include:
1. To recommend areas where corrective measures may be needed.
2. To recommend the most sound types of corrective measures.
3. To recommend the parameters of the economics involved.
4. To recommend an assessment of the action's impact upon present
and future environmental requirements.
Environmental goals included:
1. Preservation of high quality surface waters.
2. Protection of groundwater resources.
3. Preservation and enhancement of fish and wildlife and their
habitat.
4. Preservation and development of the recreational capacity of
Island Park.
Procedures: The framework within which water quality studies were
performed was the State of Idaho Water Quality Standards, Federally-
approved and enforceable under the National Pollutant Discharge Elimina-
tion System contained in P.L. 92-500.
Test methods were those specified in Standard Methods for the
Examination of Water and Wastewater, 13th Edition (1971). The membrane
filter method of bacterial analysis was used for all surface and domestic
water tests, with multiple tube analysis performed for shallow well
samples due to excess turbidity.
A comprehensive network of sampling stations was designed to pin-
point problem sources and trace their movements throughout the surface
and groundwater systems in the Island Park area. A detailed discussion
is contained on pp. 37-47, Figures 11-17, and Appendix B of the Study.
Some 61 stations were used for surface water sampling. New shallow wells
were drilled; and individual domestic and commercial water supplies were
sampled.
Analysis included fecal coliform and streptococcus, biochemical and
chemical oxygen demand, nutrients, solids, and complete chemistry
including toxicants. In an attempt to determine whether the coliform
bacteria source was from animal or human sources, a method of comparing
the ratio of fecal coliform to fecal strep count was used, as discussed
on p. 47 of the Study. Although this method has certain limitations as
mentioned, it is considered to be a valid method for making general
conclusions.
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The sampling period for this Study was May-September of 1974.
This covers the heaviest period of recreation use and also the high
and low runoff periods. Although there is some influence due to flow
variations, the effect is minimal due to the reservoir and lake level
controls and the constant background water quality conditions that exist
naturally.
Findings; The Study showed quite conclusively that;
1. Fecal coliform bacteria from human sources are entering surface
waters in the following sub-areas: Henry's Lake; Moose Creek; Mack's
Inn; I.P. Bill's Island; Pond's Lodge; and Last Chance. Problems were
not indicated in the Henry's Lake Flats; Big Springs; Yale-Hotel Creek;
and Pinehaven areas.
2. Most shallow wells sampled had fecal coliform present at least
once during the study, indicating poorly functioning subsurface disposal
systems. One well sampled in the Mack's Inn area showed significant
contamination levels during most of the sampling period.
3. Domestic wells supplying drinking water were contaminated in the
Mack's Inn (all sectors), Pond's Lodge; and Last Chance areas.
4. Chemical analyses showed high nutrients present in nearly all
samples from every area, although attempts to correlate phosphorus levels
with population centers were inconclusive. Shallow well data did, however,
support the conclusion that population centers are contributing to
nutrient loadings. The Henry's Lake, Mack's Inn, and I.P. Bill's
Island areas demonstrated higher than normal biochemical oxygen demand
levels.
In summary, severe surface water quality problems attributed to
inadequate sewage disposal systems are indicated in the Henry's Lake
north shore area; Henry's Fork of the Snake River adjacent to Mack's
Inn, McCrea's Bridge, and Last Chance developments; and the Buffalo
River adjacent to the Pond's Lodge complex. Also, groundwater and
domestic well tests indicate considerable contamination of subsurface
water by septic tank drainfield effluents. The flow of these contaminated
groundwaters into rivers, lakes, and domestic water supplies constitutes
a major problem.
Existing Treatment Facilities
The U.S. Forest Service owns and operates the only "community"
treatment facility now existing in the Study area. This is a small
non-overflow (complete retention) evaporative lagoon serving the Forest
Ranger Station in the Pond's Lodge area. All other treatment units in the
Study area are of the individual home septic tank with drainfield type.
There is a high rate of "failure" of these individual systems due to the high
groundwater table found in most areas. Where filter field capacities
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are adequate, there is conclusive evidence of septic tank effluent
being carried into streams and domestic wells on neighboring property.
Study Recommendations
The Study justifies the provision of individual collection, inter-
ceptor, and treatment facilities for each of the sub-areas as follows:
1. The north shore of Henry's Lake, Zone 1 only.
2. Mack's Inn - Island Park Lodge, Zones 1-4.
3. I.P. Bill's Island - Yale Creek, Zones 1, and 3-5.
4. Last Chance - Pond's Lodge, Zones 1-4.
The Study also indicates that expected growth may require inclusion
of the following zones before the end of the design period (1994):
1. Henry's Lake, Zone 2.
2. Mack's Inn - Island Park Lodge, Zone 7.
3. I.P. Bill's Island - Yale Creek, Zone 2
Although high phosphorus levels in surface waters could not generally
be traced to human sources, high levels were found in shallow wells but
not in deep wells. This is evidence of the contribution of septic tanks
to nutrient overloads, but is not necessarily justification for employing
advanced waste treatment prior to discharge, at this time. However, the
recommended treatment method - land disposal of disinfected effluent from
aerated lagoons by spray irrigation - will preclude nutrients from
reaching ground or surface waters and, in effect, does represent advanced
waste treatment.
Description of the Proposed Project
Since the studies indicate that the waters in this area are being
contaminated through the use of inadequate subsurface sewage disposal
systems, the proposed sewage treatment systems are intended to accomplish
the following:
1. Provide facilities, in those areas of significant existing or
foreseen future development, which will prevent further contamination
of the waters by eliminating the existing inadequate systems.
2. Allow the waters to recover their former natural conditions
through natural assimilative action.
3. Preserve the beneficial uses for which the waters have been
designated. (The waters of Henry's Lake and Island Park Reservoir are
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classified as "Class Aj" Waters. All rivers and streams are classified
as "Class A2*' Waters.)
The proposed project includes the collection system (not eligible
for Federal participation), interceptors, aerated lagoon, winter storage,
chlorination facilities, and spray irrigation system for each of the
following areas:
1. Henry's Lake, Zone 1
2. Mack's Inn - Island Park Lodge, Zones 1, 2, 3, 4
3. I.P. Bill's Island - Yale Creek, Zones 1, 3, 4, 5
4. Last Chance - Pond's Lodge, Zones 1, 2, 3, 4
The lagoon method of treatment followed by stream discharge does
not generally meet secondary treatment requirements. Therefore, spray
irrigation was selected as a means of achieving secondary treatment with
the added benefit of nutrient removal.
Development is expected to increase in the following zones to a
level where treatment facilities may be required before the end of the
design period of 20 years for this project:
1. Henry's Lake, Zone 2
2. Mack's Inn - Island Park Lodge, Zone 7
3. I.P. Bill's Island - Yale Creek, Zone 2
Facilities for these latter zones are included within the scope of
this project. The treatment facilities will be designed with capacities
for these areas, but the collection systems will not be installed until
needed. The treatment facilities will be designed with capacity for the
following average daily summer flows:
1. Henry's Lake 51,400 gallons
2. Mack's Inn - Island Park Lodge 175,500 gallons
3. I.P. Bill's Island - Yale Creek 247,900 gallons
4. Last Chance - Pond's Lodge 104,200 gallons
The summer flows were used for design because of the higher summer
population. For further information concerning design flows, see
Table 21, on page 117 and pp. 81-84 of the Study.
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It was noted during the review of the Study that several discrepancies
existed between the recommendations contained on pp. 74-80 and design
data contained in Table 21 on pg. 117. After discussions with the
consultant the following conclusions were reached:
1. Pg. 76 - Mack's Inn, Zone 7, was not discussed. Development
in the area indicates that contamination problems will occur prior to
1994 and later provision should be made.
2. Pg. 77 - I.P. Bill's Island - Yale Creek, Zone 2 - The Study
indicates that sewer service is not recommended for this zone. Future
development, however, is expected to increase to a point where service
will be required prior to 1994.
3. Pg. 79 - Last Chance - Pond's Lodge, Zone 6 - This zone should
have been included with the discussion of Zone 5 which does not recommend
service.
4. Pg. 117 - Table 21 - In accordance with the above, the following
changes should be made:
(a) I.P. Bill's Island - Yale Creek - Remove Zone 2 from the
column indicating zones to be served initially.
(b) Last Chance - Pond's Lodge - Remove Zone 5 from both columns
indicating zones to be served. The population in this zone is so small
that the criteria for design loads would change only slightly.
Existing development in the remaining zones of the study area is
light and is not expected to increase significantly within the design
life of the project. Therefore, the installation of collection and
treatment facilities for those areas is not included in this project.
Further information concerning the rationale for selecting the zones
to be included in this project can be found on pages 74 through 80 of
the Study.
Present planning calls for construction of facilities at Mack's Inn -
Island Park Lodge under the first phase. The facilities for Last
Chance - Pond's Lodge, Henry's Lake, and I.P. Bill's Island - Yale
Creek will be constructed under later phases. The phasing of the
construction is based upon the severity of the contamination problems,
the density of development for financial feasibility, and the availability
of funds for the project. For further discussion of the funding problems,
see Chapter V of this statement.
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10
Conditions Without The Project
The County's Study presents a complete description of existing
environmental conditions. The purpose of this section will be to merely
summarize the environmental setting and list significant conclusions.
Climate: The climate of the study area can generally be described
as "moderately severe." The winters are long and cold with heavy snow-
fall; summers are short but pleasant wi|:h a growing season of approxi-
mately 50 days in the Island Park vicinity. The average monthly tempera-
ture ranges from 13°F in January to 60°F in July, with the annual average
at 36°F. Precipitation varies from 1.4 inches in July to 5.0 inches in
January, with the annual average at 31.8 inches. The average annual
evaporation is estimated at 27 inches; this being less than the precipi-
tation means that an evaporative lagoon is not feasible without seepage
or discharge of some sort (see discussion on treatment alternatives).
Topography: With only a few exceptions, the majority of the study
area is relatively flat, with slopes of less than 5 percent. This is
especially true of developable areas. Ground surface elevations are
around 6,300 feet above mean sea level.
Geology & Soils: The study area is generally characteristic of a
glaciated area, with major glaciers having created Henry's Lake and
leaving massive fluvial outwash plains. Streams easily cut their way
through this material. Richer soil nutrients and organics were deposited
in valley bottoms, with side slopes more gravelly in nature. The
County's 1971 Comprehensive Sewer and Water Plan contains a good dis-
cussion of soils throughout the study area, emphasizing their suitability
for septic tank filter fields, pipe bedding, water retention structures,
and sanitary landfill (pp. 11-18 to 11-20). The soil profile in the
study sub-areas generally consists of 3 or more feet of sandy loam with
some gravel, underlain by a more permeable sandy material. Large gravel,
cobble, or fractured volcanic bedrock is normally found at four or five
feet. There are, however, exceptions as normally found in most any
large area.
Generally, soils limitations for septic tank use can be summarized
as follows:
Henry's Lake area: No areas suitable for continued septic
tank use due to high groundwater table.
Mack's Inn area: Only southeast section of the Island Park
subdivision can support continued septic tank use; other sections have
a high groundwater table or inadequate distances between adjacent
filter fields.
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11
I.P. Bill's Island - Yale Creek area: Very few acceptable
areas due to high groundwater table.
Last Chance - Pond's Lodge area: Unsuitable throughout due
to high groundwater.
Interestingly, the report mentions a "severe" earthquake, ground
breakage, rock slide, and earth flow hazard in the Henry's Lake area.
Further review indicates this hazard is not of a magnitude that would
suggest special design considerations for sewage systems. It could
have significance for the design of large dams or high-rise structures,
but not for minor sewerage systeqis.
Hydrology
Henry's Lake has a mean depth of 25 feet, surface area of 9.5 square
miles, and stores 90,300 acre feet; discharge is into the Big Springs
flows, which constitutes the headwaters of the North, or Henry's Fork,
of the Snake River. The next major body of water in the system is
Island Park Reservoir, which has a mean depth of 13 feet, area of 13
square miles, and stores 143,000 acre feet. Flows of the Snake River
and other major tributaries in the study area are as follows:
Big Springs 180 CFS
Henry's Lake Outlet 53 CFS
Snake River below Reservoir 590 CFS
Buffalo River at Pond's Lodge 200 CFS
Moose Creek 70 CFS
Yale Creek 8 CFS (approx.)
Hotel Creek 30 CFS (approx.)
None of these streams causes any flooding problems.
Groundwater
Only preliminary unpublished groundwater data are available, but
it appears that essentially all groundwater movement in the study area
is toward and into surface water courses. Groundwater levels are generally
within five feet of the surface. Except in the immediate vicinity of
development, groundwater is of good chemical quality, low turbidity and
color, and high in dissolved oxygen.
Water Quality
A 1973 study by the EPA demonstrated significant temperature,
dissolved oxygen, phosphorus and ammonia nitrogen problems in Island
Park Reservoir. It is generally concluded that domestic sources of
pollution contribute to the problems, but the extent is unknown. The
County's Study clearly shows deteriorating quality adjacent to commercial
and private development, especially bacteriologically, as previously
discussed. Wells are significantly affected by fecal coliform contamina-
tion due to "failing" septic tanks. The reader's attention is directed
to the Study for detailed quality data.
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12
Air Quality
Air is of the highest quality in the study area, as recreationists
will quickly attest. Point sources of hydrocarbons are limited to motor
vehicles and heating devices (including fireplaces). Periodically the
open burning of slash in forested logging areas causes some nuisance.
Noise
Although no sound studies or measurements have been performed, noise
levels would generally be considered satisfactory. There are no major
"point sources" of noise, but rather those generally associated with
traffic and residential and commercial establishments.
Plants
An excellent discussion of the plant community is contained on
pp. 20-26 of the Study. The diversity is fairly well established, except
for the predominance of lodgepole pine for natural forested areas. The
Rocky Mountain Pine Beetle and dwarf mistletoe are causing significant
pine damage. There is evidence of damage due to development, mainly
resulting from tree and cover removal. The concluding statement of the
Study, however, is that the forest area and type appear well-adapted to
absorbing added human population, providing that increases are carefully
planned.
Animals
There is, indeed, a unique and desirable diversity of animal species
in the study area, which is probably representative of the neighboring
regions of southwest Montana and Northwest Wyoming also. The reader is
again directed to the Study, pp. 27-32, and Appendix A. Of special
interest are moose, mule deer, elk, antelope, bear, and sasquatch for
the larger animals; ducks, geese, sandhill cranes, and trumpeter swan
for birds; and cutthroat, rainbow, and eastern brook trout, coho and
kokanee salmon for fish species. The only "threatened" species is the
grizzly bear (18 to 20). The Rocky Mountain Wolf (1 or 2 five-animal
packs) and prairie falcon (infrequent) are "endangered" species.
Unique species include the trumpeter swan, sandhill crane, northern bald
eagle, golden eagle, osprey, ferruginous hawk, marten, and fisher.
The U.S. Department of the interior has been consulted regarding
possible impact of the proposed project on the "threatened" species, in
accordance with the requirements of EPA's EIS Regulations, 40 CFR
6.214(a) (6), and Section 7 of the Endangered Species Act of 1973
(P.L. 93-205). It should be noted that there has been detrimental impact
on threatened species habitat noted in the past, due to the development
that has already occurred.
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13
Socio-Economic
Scenic-Recreational: It would be redundant for anyone familiar with
the Island Park area to say that the area offers unique scenic, aesthetic,
and recreational opportunities. The area has experienced steadily
increasing recreational pressure, both in the summer and more recently
for winter snowmobiling. The close proximity to Yellowstone National
Park contributes to this pressure. In 1970, the U.S. Forest Service
estimated "People at One Time" (PAOT) usage and anticipated annual
growth in recreation as follows:
1970 PAOT Annual Growth
Area
Mack's Inn - I.P. Lodge 2,150 7%
Last Chance - Pond's Lodge 2,000 10%
I.P. Bill's Island - I.P. Reservoir 1,200 20%
Henry's Lake 920 5%
Big Springs 390 4%
Moose Creek 25 40%
Shot Gun Village - Yale Creek 180 28%
Pinehaven 100 35%
TOTALS 6,965 11% (avg.)
/
Had this growth been realized, the 1975 PAOT would have been 10,715.
The Study on p. 85 shows a 1974 PAOT estimate of 7,733, but this figure
does not include all of the areas and campgrounds included in the above
table. It appears, then, that the 1970 Forest Service projections were
realistic. Interest in snowmobiling has snowballed the last few winters.
Pond's Lodge, for example, was only open summers five years ago. Now,
not only is its summer trade higher than ever, 40% of its annual receipts
are reported to be from winter trade. The recreation properties real
estate trade continues to prosper, with condominiums now being added.
With the exception of a small increase in St. Anthony, the Island Park
area was the only part of Fremont County experiencing growth during the
last 10 years, shown by the U.S. Census Bureau to be 60% during the period
1960-70. Needless to say, the economic impact of this growth is con-
sidered by the County to be most favorable.
From the social standpoint, the elimination of the health hazard from
water supplies is of serious concern to the County and residents. The
recent outbreak of intestinal disorders associated with the drinking
water at Crater Lake National Park could perhaps occur at Island Park
at a modified scale, since not all drinking water supplies are public.
In some cases, developers and real estate salesmen complain of losses in
property values due to sanitary sewage problems. Although there are
no documented medical records, the State Health Office in Rexburg has
some letters on file from various cabin owners who have complained that
their wells are contaminated and that members of their families get
intestinal problems following each visit to their cabins where well
water was consumed.
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14
Historical-Archaeological
There are no known historical, cultural, or archaeological sites
within the study area, nor are there any sites felt to be eligible for
inclusion on the National Register. Big Springs, which is not recom-
mended for sewerage service, is a National Geological Site listed on
the Register. Appendix A gives the results of a special survey of
archaeological sites conducted during the EIS process.
Land Use
Current land use in the study area consists of recreation, log-
ging, and agriculture, with recreation being notably the most important.
Logging of commercial timber is under the supervision of the U.S. Forest
Service. The only area with any significant agricultural operations
is the Henry's Lake area, where there are approximately 200 acres
under cultivation for wild hay. There are no other agricultural crops
found in any of the other sub-areas. Cattle are grazed on much of the
private lands and some of the surrounding Forest Service lands. A
small geothermal area (KGRA) has been identified immediately adjacent
to the west boundary of Yellowstone National Park. This is not anti-
cipated to have any impact on the proposed project at this time.
Of the approximately 600,000 acres in the study area, most of the
current ownership is public, administered by the U.S. Forest Service or
U.S. Bureau of Land Management. Ownership is shown in general on Figure
2, and in detail for each sub-area on Figures 4-9. The State Land Board
also administers appreciable holdings, approximately half as much area as
is in private ownership. The 1971 County Comprehensive Sewer and Water
Plan showed 46 recorded private subdivisions as of 1970 totaling 2,296
acres. The estimated PAOT capacity of these subdivisions was 11,982
persons. The current study lists 43 platted subdivisions in 1974
(Figure 3); no acreage is given, but it is assumed to be approximately
the same as in 1970, or 2,300 acres. It is estimated that at present,
some 25% of the platted subdivisions are developed; however, it is also
estimated that from 80 to 90% of the lots in these subdivisions are sold.
In the way of a gross estimate, then, land ownership might break down
as:
Public 596,000 acres*
State 1,700 acres
Private 2,300 acres
TOTAL 600,000 acres
*Page II-8 in the 1971 Comprehensive Sewer and Water Plan lists
3,777 acres of recreation sites located on U.S. Forest Service lands.
From these figures, as approximate as they may be, if it is
assumed that over the life of the proposed project all of the Forest
Service recreation sites, State land, and private land will be developed,
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15
this amounts to 7,777 acres, or 1.3% of the total study area. This
comparison may be of interest in the consideration of loss of wildlife
habitat as development in the Island Park area occurs.
Population
The following table of existing and projected population is extracted
from the 1971 County Comprehensive Sewer and Water Plan, based on 1970
U.S. Census information:
Island Park Division
Permanent
Summer Homes & Gov't.
Camping Facilities
Tents & One-Day Visitors
TOTALS
1960
232
1970
371
5,000
5,000
1975
450
15,000
8,000
232 10,371 23,450
1980
500
25,000
12.000
37,500
1990
600
50,000
15,000
65,600
The basis for projecting population is always a matter of special
concern in the environmental evaluation of a proposed project. Unfor-
tunately, in a fast growing recreation area, a valid basis for making
projections is difficult, at best, to develop. The projections used by
the County for the current project design are based on U.S. Forest
Service records, real estate records, commercial establishment records,
and current growth trends observed locally. This has resulted in the
following projection summarized from Table 12 (PAOT basis):
Study Sub-Area
Henry's Lake
Mack's Inn - I.P. Lodge
Big Springs - Moose Creek
I.P. Bill's Island - Yale Creek
Last Chance - Pond's Lodge
Pinehaven
TOTALS
Present
1974
Proposed
1994
2,078
5,701
315
8,343
3,436
340
20,213
This represents a 20-year overall projected growth of 160%. Although
this appears optimistic, recent experience in recreational development
and associated growth in the Island Park area would suggest this projec-
tion to be realistic.
Land Use Controls
The Fremont County Planning and Zoning Commission was organized in
August of 1969. They currently have not developed or implemented a
formal land use plan or zoning ordinance. However, such a program is
now underway. The County does have a Subdivision Resolution, the purpose
of which is ". . . facilitating the orderly growth and development of
the County; lessening congestion in the roads or streets; preventing
the overcrowding of land; avoiding undue concentration of population;
securing economy in County expenditures; facilitating adequate provisions
for transportation, water, sewerage, schools, parks and other public
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16
requirements; stabilizing the value of property; and increasing the
security of home life."
The requirements of this Resolution regarding sanitary facilities
plus policy which the County has developed has resulted in the County
Planning Commission not allowing platting of development unless all of
their criteria are met, including:
1. Final engineering of proposed development completed prior to
submission of plan.
2. Completion and recording of covenants.
3. Approval of sewage systems by the Department of Health.
Currently, sites located in areas of high groundwater cannot use
individual septic tanks and filter field disposal systems, and permits
are denied by the Department of Health. Both the U.S. Forest Service and
the Idaho State Land Board exercise land use controls in effect as they
administer their own systems of permits, easements, etc.
Other Agency Programs or Projects
The only other agency, program, or project which affects the
provision of sewerage facilities is the U.S. Forest Service. As
previously mentioned, they now operate a complete retention lagoon
serving their Ranger Station. This facility would be abandoned and
their collection system tied directly into facilities constructed by
the County. The Forest Service has indicated its willingness to
fully cooperate in the provision of centralized sewerage facilities,
and has funds reserved for their participation now through their
A-81 budgeting process. The Forest Service has some plans for later
construction of collection systems to serve their recreation sites,
such as the Flat Rock campground, and funds are also reserved for
this purpose.
The Forest Service currently hauls all wastes generated at its
facilities (other than its Ranger Station) to State-approved treat-
ment facilities by contract.
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17
CHAPTER II
PROJECT ALTERNATIVES
Treatment Process Alternatives
The alternatives investigated by the applicant for primary-secondary
treatment were:
1. Mechanical - Biological Treatment.
2. Physical - Chemical Treatment
3. Physical - Chemical Plant with High Rate Activated Sludge
(HRAS) Pretreatment
4. Non-Aerated Facultative Lagoon
5. Aerated Lagoon
In addition, the alternative of no action, or continuation of the
existing condition, was discussed. Alternatives for nutrient removal,
or tertiary treatment, were also investigated. The need for this addi-
tional level of treatment is discussed at the end of the section entitled
"Study Recommendations" in Chapter I of this statement. These alterna-
tives were:
1. Nitrogen Removal
a. Nitrification - Denitrification
b. Ammonia Stripping
c. Removal by Soil - Plant System
2. Phosphorus Removal
a. Chemical Coagulation - Filtration
b. Land Sprinkling
(1) Spray Irrigation
(2) Overland Flow
(3) Rapid Infiltration Ponds
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18
The preliminary analysis of the alternatives was based on the
goals and constraints pecular to North Fremont County. The goals were:
1. Preservation of high quality surface waters.
2. Protection of groundwater resources.
3. Preservation and enhancement of fish and wildlife and their
habitats.
4. Preservation and development of the recreational capacity of
the area.
The constraints were:
1. Local climate (long, cold winters).
2. Available land suitable for recreational development.
3. Forest Service management plans.
Additional restrictions were:
1. Extreme flow variations.
2. Treatment of flows containing only sanitary wastes.
The mechanical - biological treatment system (activated sludge)
is the most common method used. It consists of the removal of large
pieces of debris and grit, the settling of smaller solids, and the bio-
logical removal of organic material. This is followed by chlorination
and disposal. Sludge treatment and disposal is also required. This
process does not operate efficiently under extreme flow variations.
Physical - chemical treatment consists of the removal of grit and
debris followed by chemical coagulation and filtration through activated
carbon or sand. This process may include non-chemical sedimentation as
a primary step. Disinfection and sludge handling are also required. This
process can also accomplish nutrient removal.
Physical - chemical treatment with HRAS greatly increases the
efficiency of the physical-chemical system and may eliminate the need
for activated carbon absorption. It is essentially a combination of
the first two alternatives.
A non-aerated facultative lagoon is simply a pond of sufficient
depth to provide a top aerobic layer and a bottom anaerobic layer. The
particular type investigated is the complete retention type, meaning
that evaporation and percolation into the soil occur over time at the
same rate as sewage enters the lagoon.
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19
The aerated lagoon has oxygen introduced mechanically to the pond
rather than relying on surface-air contact and wave action. An anaerobic
bottom layer still results from the settling of solids. The effluent from
the pond is subjected to further sedimentation and disinfection prior to
disposal.
The no-action alternative would be the continuation of septic tanks
with drain fields. This has proven to be unsatisfactory for the health
and social reasons presented in Chapter I.
Nitrogen removal through nitrification-denitrification is a two-
step process. The ammonia is converted to nitrate by aerobic bacteria.
Anaerobic bacteria then act on the effluent to convert the nitrate to
nitrogen gas. Ammonia stripping is accomplished by raising the pH of
the effluent through the addition of lime and subjecting it to high rates
of aeration. The use of the soil-plant system is the same as land dis-
posal and is discussed under phosphorus removal.
The chemical coagulation-filtration system for phosphorus removal
is essentially the same method as physical - chemical treatment. Removal
of nutrients by the soil - plant system, or land sprinkling, consists
of the placement of the effluent on the soil to allow filtration by the
soil and nutrient uptake by vegetation and soil particles.
The alternative treatment methods, both primary-secondary and
tertiary are described in more detail in Chapter VIII of the Study.
Based on the constraints listed, the alternatives meriting further
consideration were limited to:
1. Physical chemical plant
2. Non-aerated lagoons
3. Aerated lagoons
The following table is a summary of the analyses performed on the
alternatives together with the principal reasons for rejection.
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Alternative
Major Advantages
ANALYSIS OF ALTERNATIVES
Major Disadvantages
Re leeted
Principal Reasons
A.
Primary-
Secondary
1. Physical-
Chemical
2.
3.
Non-aerated
Lagoon
Aerated
Lagoon
1. Small land-require-
ments
2. High efficiency
3. Nutrient removal
1. No effluent
2. Simple operation
1. Smaller land area
than non-aerated
lagoon
2. Odor-free
3. Simple operation
4. Handles extreme flows
1. Requires highly qualified
operator
2. Most Expensive
3. Must be designed for peak
daily flow
1. Large land area requirements
2. Odor problems
1. More land than Physical-
Chemical plant
2. Requires nutrient removal
Yes
Yes
No
1. Cost
2. Flow fluctuations
Land requirements
B. Tertiary
1. Nitrifica-
tion-Deni-
trification
2. Ammonia
Stripping
1. 90% removal
efficiency
1. Can be used in
physical-chemical
plant that uses lime
2. High efficiency
1. Not adaptable to flow fluc-
tuations
2. Complex operation
3. High cost
1. High costs
2. Complex operation
Yes
Yes
1. Cost
2. Flow fluctuation
1. Costs
2. Not practical for
lagoons
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3. Chemical-
Coagulation
Filtration
Usable with aerated
lagoons
Same as physical
chemical
High efficiency
1. Requires winter storage
2. High costs
3. Complex operation
Yes
1. Costs
2. Operation
4. Land
Disposal
a. Overland
Flow
b. Rap id
Infiltra-
tion Pond
c. Sp ray
Irriga-
tion
Used in areas of low
soil permeability
Less land require-
ments
Highest efficiency
Optimizes removal of
bacteria and viruses
Easiest to operate
Increases crop
productivity
1. Less efficient than spray
1. Requires six months rest
Period
2. Less efficient than spray
1. Requires more land
2. Requires winter storage
Yes
Yes
No
Efficiency
Efficiency
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22
The following table is a summary of costs for the three systems,
including storage and tertiary treatment.
Alternative
Physical-Chemical Plant
Non-aerated Lagoon
Aerated Lagoon
Total Estimated
Present Worth
$361,500
$257,300
$192,600
The environmental effects of the alternatives are presented on
page 78 of the Study. In essence, the proposed action is preferable.
Site Alternatives
For each of the study sub-areas, at least two alternative sites
were considered. These are discussed in Chapter IX of the Study,
and the general area of the preferred sites are indicated on figures
18-21. The following table summarizes the estimated costs of the
proposed system, together with the principal reasons for selection.
ANALYSIS OF FACILITY SITES
Sub-Area
Selected
Alternative
Site Number
Estimated
Cost
Principal Reasons
for Selection
Henry's Lake
Mack's Inn -
Island Park Lodge
I.P. Bill's Island
Yale Creek
Last Chance -
Ponds Lodge
$204,000 1. Area suitable for
spray irrigation
2. No development pres-
sure in area
3. Least environmental
impact
$234,800 1. Situated between two
principal developed
areas
2. Low development induce-
ment
$749,600 1. Most suitable topo-
graphically
2. Area suitable for
spray irrigation
3. Low development induce-
ment
$440,100 1. Area suitable for spray
irrigation
2. Close to existing
development
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23
CHAPTER III
ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION
Water
The construction of sewage treatment facilities under this project
will decrease the input of human fecal contaminants to the waters of
the area. Those sub-areas and zones for which facilities are not being
provided under this project will continue to use septic systems which
may not be adequate. The study, however, indicates that development in
those areas is light and the amount of contaminants reaching the waters
will be small. The improved quality of the waters resulting from this
project will increase the assimilative capacity of those waters. As
development in the unserved areas increases, it is expected that other
projects will be initiated. The removal of inadequate septic systems
should improve the quality of groundwater as a drinking water source.
Some of the nutrients in the waters will be removed by means of
the spray irrigation process. Phosphorus concentrations in the waters
resulting from high phosphorus content of the geological formations
(see p. 62 of the Study) will continue. The quality of water in Henry's
Lake and Island Park Reservoir with respect to phosphorus content should
be improved by the removal of that contaminant in the treatment process.
There is expected to be some increase in development in the area
induced by the construction of the proposed treatment facilities. This
will result in increased wastewater flows and some erosion and runoff
which is associated with development. This will be limited, however, to
the areas served by the proposed treatment facilities. The induced
development is discussed further under "Secondary Impacts" below.
Some erosion and turbidity of the water will result from the
construction process, but this will be partially controlled by reseeding
and the use of proper construction procedures. The impacts of the
construction are expected to be generally of a temporary nature.
Air Quality
The service area experiences no existing or pending air quality
problems. During the construction of the facilities, some air pollution
from dust and exhaust from the construction equipment can be expected.
This will be partially controlled through proper construction practices
and will be temporary.
Some increase in pollution from the heating systems and exhaust
from vehicles and snowmobiles can be expected to result from the develop-
ment induced by the proposed facilities. The impacts caused by the
induced development are discussed under "Secondary Impacts" below.
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24
Some odors may be detected at times of sudden overload or at spring
breakup of ice conditions on the lagoons. The aeration process should
prevent the ice conditions and maintain the aerobic status in the lagoon
so that only rarely would odors result, and these would be of short
duration.
The effluent from the lagoons will be chlorinated prior to disposal
through the spray irrigation process. Therefore, there should be no
transfer of bacteria through the spray process. The spray equipment
is designed to produce larger droplets, thus reducing the likelihood of
transmission of bacteria or viruses in aerosols.
Some local mist or fog may result from the temperature differentials
between the surrounding air and the lagoons or effluent sprayed in the
air. Since the areas are mainly screened from the winds, these conditions
would be confined to the immediate area and would be of short duration.
Noise
During operation of the facility, little noise is expected to
result. The pumps for the transfer or spray of the liquid wastes and
for air in the aeration process would cause some noise. Since this
equipment is usually confined in a building to protect it from weather,
the noise is not expected to be audible outside the property lines. All
other noises associated with the operation of the facility are expected
to be negligible.
During construction some noise from blasting and construction
equipment is expected. Such noises are unavoidable but will be kept to
a minimum.
The development and increased activity in the area induced by the
existence of the proposed facility may cause increased noise from the
increased use of autos and snowmobiles. Much of the development would
result regardless of whether this project is constructed. Once the
treatment facilities are installed, some increase in development is
unavoidable. This is discussed under "Secondary Impacts" below.
Aesthetics
In selecting the sites and designing the facilities, the impacts
on vegetation and wildlife have been considered. Disruption of vege-
tation and habitats will be kept to a minimum. The facilities are
located adjacent to areas already committed to development, Impacts
on rare, endangered or unique species are considered negligible.
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25
The facilities will not be located on any known areas of historical
or archeological interest (see Chapter I).
The facilities will consist of lagoons and spray field which in
many cases will be screened from view. Those portions which will be
visible are generally pleasing in appearance.
There is some question whether sprinkler irrigation will have an
adverse impact upon trees in the vicinity (see p. 110 of the Study).
The planned phasing of construction will permit the option of experiment-
ing at one site without committing the other sites to adverse conditions;
or to the selection of sites free from timber. Timberless sites were
included in the site alternatives considered for each area.
Secondary Impacts
The use of the snowmobile and winter sports activities has prompted
seasonal residents to winterize their summer homes in the area and has
attracted others to move to the area. There is considerable pressure
for increased development. Of those platted subdivisions which have
been developed, approximately 90% have been sold.
The County Planning Commission will not allow the platting of further
subdivisions unless (1) engineering is completed, (2) covenants are
completed, and (3) the State Department of Health has approved the
sewage system. Most of the presently developed areas are located along
rivers or lakes where the groundwater tables are high. The Health
Department will not approve septic tanks or other individual home treat-
ment systems in these areas. The developers are then forced to provide
community type treatment systems for their developments or to locate
their construction on land with lower groundwater tables. Most of
such lands are controlled by the U.S. Forest Service or the Bureau of
Land Management, however. If the developers should locate their sub-
divisions on lands away from present populated areas, this would create
a sprawl into environmentally sensitive areas with serious adverse
impacts on the vegetation, wildlife habitats, and degradation of waters
from erosion and runoff. Since the County has no zoning or other
similar land use regulations, there would be little, if any, control
over this type of spread.
Since the developers are aware that approval of the proposed project
appears imminent, they have been reluctant to construct treatment
facilities for their subdivisions. As a result, new construction has
been delayed. This delay combined with the present contamination of
the waters has caused a decrease in property values.
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26
Construction of the proposed treatment facilities will allow
the developers to construct new homes which have been delayed because
of the current ban on individual systems. There is every indication
that such growth would have occurred with or without the project, but
will occur more rapidly once the proposed facilities are installed.
The rate of such growth will decrease as the needs caused by the delay
actions are satisfied. Once the restrictions on development have been
removed and the quality of both surface and underground waters improves,
property values should increase. This will either partially or totally
offset the cost of the proposed facilities borne by the residents.
The provision of sewage collection and treatment facilities result-
ing in improved water quality when combined with the decrease in
development restrictions and increased property values will induce some
population growth above the level which would occur without the project.
The amount of this growth directly attributable to the project cannot
be predicted since some growth would occur regardless of whether the
project is undertaken. This growth will, in turn, result in increased
air pollution from vehicle exhaust and heating units. This air pollu-
tion is not expected to reach a level where it would exceed standards.
Some traffic congestion and increased background noise levels will
result, but are not expected to cause any serious problems. The addi-
tional growth will be reflected in increased camping, hiking, and
snowmobile activity. Such activity would tend to restrict the movements
of wildlife, particularly the moose, trumpeter swans, and geese.
The use of snowmobiles has been recognized as a problem requiring
action. The State of Idaho has formed a committee to study the problems
of all "off road vehicles" (ORV's) and recommend necessary action to
control their use. Executive Order 11644, dated February 9, 1972,
requires Federal agencies to develop plans for the control of the use of
ORV's on Federally controlled lands. Regulations and administrative
procedures have been developed by the U.S. Forest Service. The imple-
mentation of these controls will partially mitigate the adverse impacts
which these vehicles have on the wildlife in this area.
The provision of smaller treatment systems to serve the problem
areas of greatest development, as opposed to a single regional system
with connecting interceptors tends to limit growth to the areas
previously committed to development rather than encouraging sprawl
along interceptor routes or into environmentally sensitive areas, thus
serving as a limited land use control. The concept of concentrating
the facilities to areas which have demonstrated the potential for
greatest development was not extended to providing a separate facility
for each zone. This would not have been economically feasible.
Thus the recommended design provides, in effect, a regional system
for each of the four sub-areas included in the proposed project. Such
planning prevents a proliferation of small systems which provide less
efficient treatment and are more difficult to monitor.
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27
CHAPTER IV
ADVERSE IMPACTS WHICH CANNOT BE AVOIDED
Construction Impacts
The construction activities will produce some noise and dust
which cannot be avoided. Proper construction practices will reduce
this to a minimum. There will be some disruption of traffic, particularly
during the installation of the collection system which usually follows
existing streets and roads, thus avoiding the acquisition of additional
rights-of-way for the lines.
The lagoons and spray fields are to be located in areas which are
sufficiently remote from existing development and screened from view
so that the impacts of construction would pose only minor problems to
the residents. These sites are sufficiently close to existing popula-
tion centers that the wildlife in the service area will experience only
minor interference.
Construction activities will remove some of the vegetative cover
and some wind or water erosion will occur before such cover can be
restored. The construction contractor will be required to exercise
construction practices which will limit this erosion and will also be
required to reseed and restore the vegetative cover as soon as
possible. Some increased water turbidity will result from this erosion
in the interim before the area can be reseeded.
Construction impacts are usually temporary in nature and can
generally be corrected.
Operation Impacts
Few adverse impacts directly related to the operation of the
facilities are expected. Some pump noise will be generated but should
not be audible beyond the property lines of the facilities.
Most of the facilities will not be visible to the public. Land-
scaping will be employed to shield the lagoons and spray fields from
view. Pump houses and other units which cannot be concealed will be
designed to conform to the surroundings as much as possible.
There is some question whether the spray irrigation system will have
an adverse impact on trees adjacent to the site to the point where some
of the trees are killed. Where possible, commensurate with other
considerations, these spray fields will be located away from trees
which could be affected.
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28
Some local fog or mist from temperature differentials between the air
and the sprays or lagoons will occur. Since these sites are, in most
cases, protected from winds, this fog or mist will be Confined to a
small area. The effluent from the lagoons will be chlorinated prior
to spraying, and the spray heads are designed to use large droplets,
thus reducing to a minimum the potential for transmitting pathogens
through aerosols.
Some insects may be encountered at times near the lagoons and
spray fields. Proper operation using insecticides may effectively
reduce or eliminate this problem. Some odors may occur at times of
sudden increases in lagoon loading or at spring ice breakup before
aerobic conditions can be restored. Since the systems employ aerated
lagoons, the turbulence caused by the air bubbles should prevent ice
from forming except in rare cases. The aeration facilities should also
more quickly restore aerobic conditions at times of shock overloads.
The aerated lagoon system was selected because of its ability to recover
from sudden changes in loading.
The lagoons will be lined in accordance with the State design
standards, thus effectively preventing percolation into groundwaters.
Secondary Impacts
There will be some population growth and development activity in
the area which is directly related to the installation of the proposed
facilities. This growth and development will be in addition to such
activity which would occur regardless of whether the facilities are
installed. The County has no effective land use controls with which
to regulate the growth, but has formed the Fremont County Planning
and Zoning Commission to develop such controls. A report on existing
conditions is being prepared as part of this program. The grant award
for the design and construction of the facilities described in Chapter
III of this environmental statement will be conditioned upon the develop-
ment of suitable land use controls.
In the meantime, the design of the proposed facilities provides
within itself some controls. The location of separate facilities for
each sub-area considered in lieu of a single regional plant with long
connecting interceptors tends to limit development to the locality
served by the individual collection system. The facilities are designed
so that the capacity can be increased to meet the needs of growth which
may occur in the future. This concept reduces the excess capacity provided
in the initial installation. The immediate availability of excess
capacity has in other locations provided an incentive to induce growth
in an area. Such a tendency has largely been avoided in this case.
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29
The growth which will be induced by these facilities has been
limited to some extent by the design and requirements mentioned above.
Such growth as will occur despite such control will cause some traffic
congestion, noise, air pollution, land commitments and impacts upon
vegetation and wildlife mentioned in the preceding chapter.
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31
CHAPTER V
RELATIONSHIP BETWEEN LOCAL SHORT TERM USES OF MAN'S ENVIRONMENT AND
THE MAINTENANCE AND ENHANCEMENT OF LONG TERM PRODUCTIVITY
Trade Offs
Construction Impacts versus Improved Water Quality; The environ-
mental impacts from the construction and operation of the proposed
project will be minor. Approximately four acres will be required for
each lagoon site, not including spray fields, which will be near to
already developed areas and not on agriculturally productive land.
Some noise and dust will occur, as well as a minor amount of vegeta-
tion removal and animal life disruption. A small amount of blasting
for the collection systems is expected. No odors are expected, with
the possible exception of a two-week period during the spring breakup
of any ice cover that may form. Designing a large droplet size spray
system with chlorination will preclude transmission of airborne pathogens.
These minor impacts are contrasted with the improved water quality
resulting from the project. Contamination of well and surface waters
will be abated, both from bacteria and nutrients. This will eliminate
the existing health hazard, protect the aquatic habitats, and improve
the recreational capacity of the area.
Improved Water Quality versus Induced Growth: The improved water
quality resulting from the project will be a benefit to the present
population of the area, and to the aquatic life. It will also, however,
remove the reasons for a ban on additional individual development and
for the avoidance of commercial businesses due to reports of contaminated
water. This will result in an increase both in permanent and tourist
populations.
Indications are that commercial development of recreational facilities
would occur regardless of the ban on septic tanks. Developers would
construct their own facilities to comply with Health Department
requirements. They have decided not to do so, however, since publicly
owned facilities are planned. This will serve to confine the future
development to the present areas of concentration. The secondary
impacts and mitigative measures are discussed in more detail in Chapters
III and IV of the statement.
Implementation versus Delay (Including No Action): The four sub-
areas requiring treatment facilities have been assigned a priority and
an anticipated construction schedule. Only the first, Mack's Inn -
Island Park, is on the State priority list for this year (for a Step 2
grant). The projects cannot all be constructed at the same time simply
because State and local funding is not available. The possibility
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32
exists that State and Federal funding will not be available at the same
time as the proposed construction schedule. This could occur because
(1) the State priority list may not rate the project high enough and/or
(2) Federal funding under P.L. 92-500 expires by June 30, 1976, barring
any additional Congressional action. Discussions with the State indi-
cate that the projects are of such a nature as to warrent inclusion on
the priority lists. Beyond next year, however, they cannot make a
prediction. Also, indications are thaif additional Federal monies will
be made available to meet the goals of P.L. 92-500.
In the event that the projects are not constructed within the
proposed time frame, several results are possible. First, the delay
would provide time to study the impacts of the initial phase on water
quality, growth, and recreation. This would either justify or preclude
the need for the other projects. Second, private developers may locate
only in that area where municipal facilities exist. This would alter
the population forecasts for all areas, and exaggerate the impacts of
both the project and no-action areas. Third, developers may decide not
to wait for municipal facilities and construct their own. This would
place the burden of control on the Health Department and local land
use controls.
Regardless, a commitment has been made to fund Mack's Inn - Island
Park, and funding constraints force a phasing of the others. A demon-
stration of need for treatment facilities has been made, and a delay
or no-action would continue to degrade the water quality and lower the
property values. The proposed action allows flexibility while achieving
the local goals.
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33
CHAPTER VI
IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES
TO THE PROPOSED ACTION SHOULD IT BE IMPLEMENTED
Land Use
Construction of the treatment facilities will not greatly alter
the land use in the immediate area. Approximately four acres will be
required for each lagoon, and it will be confined to areas near develop-
ment and where the land disposal will be compatible with existing uses.
The proposed project does not commit the area to a single waste manage-
ment system. Lagoons could be abandoned, the land reclaimed, and a
regional system developed at a future date.
The service areas will likely change from a resort-type area to one
of a more congested urban nature. This is expected to occur even if the
projects are not built. More winter tourism is anticipated as a result
of the projects, as well as an increase in commercial development. Also,
industrial activities are possible, although not envisioned at this time.
Real estate values are expected to increase with the elimination of the
contaminated water conditions.
Water Use
Recreational water activities, such as swimming and fishing, are
expected to increase with the implementation of the proposed action.
This is a secondary impact, as it will result from the improvement of
the conditions responsible for the development of the area. Drinking
water quality will be improved, which is a further stimulant to growth.
The facilities will not constitute a consumptive use of water inasmuch
as the water will be returned to the ground through land disposal.
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35
CHAPTER VII
OUTSIDE PARTICIPATION
Public Hearings
Public hearings and presentations have been held at various stages
of the planning process. These began with the November 1971 presen-
tation of the Comprehensive Sewer and Water Plan, and continued through
July 1975 with discussions on the attached North Fremont County Sewer
Facilities Planning Study. Generally, the meetings have resulted in
agreement with the assessment of the problem and with the proposed course
of action. Very little opposition has been evident, although some concern
over cost and service area boundaries has been expressed. A summary
of public participation through April 1975 is found on pages 120 and 121
of the applicant's assessment. Reports of the public hearings of
July 2, 1975, and July 19, 1975, are in Appendix F of the Study. The
results of the hearings indicate agreement that a pollution problem
existed and that correction was necessary.
Citizen Input
Letters have been received by the Fremont County Commission
displaying support for the proposed project. Also, letters are on file
with the State Health Office from citizens in the project area complaining
of contaminated wells and intestinal problems resulting from fecal
contamination of drinking water.
Other Federal, State and Local Agencies
Comments have been received from the U.S. Forest Service, the U.S.
Geological Survey, the Idaho Fish and Game, and the Rick's College
Biology Department. These agencies have all indicated a serious problem
in the surface and groundwaters resulting from human contamination. In
addition, the Idaho State Health Department is denying permits for
individual disposal systems as a result of the problem.
The U.S. Forest Service is also cooperating with the project, both
financially and technically. This cooperation is explained in more
detail in Chapter I of this statement.
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37
CHAPTER VIII
COMMENTS TO THE DRAFT ENVIRONMENTAL IMPACT STATEMENT
AND RESPONSES
This section contains letters of comment from individuals and
groups to the draft EIS on North Fremont County (Island Park, Area)
Wastewater Facilities. These letters have been printed as received
by EPA, Region X. Wherever a response is required of EPA to a letter,
a response page follows that letter.
The following table is a listing of the comment letters received,
the page in this chapter on which they can be found, and a general
category listing of their contents. Comment categories are shown
in an attempt to indicate those aspects of the proposed action about
which the commentors were most interested and concerned. This may
serve to direct the interested reader to those sections of the docu-
ment which he may wish to restudy.
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.
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Response to Rex Moore Letter
Sewer service is not planned to the Yale Creek (Pack Addition)
portion of the Island Park Bill's Island — Yale Creek sub-area.
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vided for the Shotgun Summer Homesite development in Zone 4.
Interceptor and force mains would, however, be sized to handle
flows from Yale Creek so that the area could be served if war-
ranted in the future.
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Response to Rex Moore Letter
Sewer service is not planned to the Yale Creek (Pack Addition)
portion of the Island Park Bill's Island ~ Yale Creek sub-area.
During the initial project phases, service would only be pro-
vided for the Shotgun Summer Homesite development in Zone 4.
Interceptor and force mains would, however, be sized to handle
flows from Yale Creek so that the area could be served if war-
ranted in the future.
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41
DEPARTMENT OF THE ARMY
WALLA WALLA DISTRICT, CORPS OF ENGINEERS
BLDG. 602, CITY-COUNTY AIRPORT
WALLA WALLA, WASHINGTON 99362
NPWEN-PL 9 October 1975
Mr. Richard R. Thiel, Chief
Environmental Impact Section, M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Thiel:
As requested by the form letter 10A from Clifford V. Smith, Jr., Ph.D.,
dated 17 September 1975, we have reviewed the Draft Environmental Impact
Statement on the North Fremont County (Island Park Area), Idaho, Waste-
water Facilities, EPA Project C-160186-01.
In general, it appears that the proposed wastewater management system will '
not have any effect on navigation or flood control activities of the Corps
of Engineers. It should be noted, however, that detailed siting of faci-
lities should be done in such a manner as to avoid the possibility of
flood hazards or flood damage. At the time you are preparing detailed
plans for the sewage facilities, we will be pleased to provide more
information and/or comments regarding the flood plain and flood hazard
potential as these relate to specific facility design elevations.
In addition, you should be aware that construction in and across the
streams of the area may be subject to a permit from the Corps of Engineers,
under the requirements of Section 404 of the Federal Water Pollution Control
Act. Prior to construction, the County should check with us again con-
cerning the possible permit requirements. You may wish to forward copies
of the inclosed booklets to the County. The names of those Corps' offices
and people to contact in Walla Walla District for more information regard-
ing permits are listed in the back of the booklet.
In review of the water quality aspects of the Draft Statement, we note
several specific comments. These water quality comments are shown on the
attached sheet for your consideration.
RECEIVED
OCT141975
EPA-R'S
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42
NPWEN-PL 9 October 1975
Mr. Richard R. Thiel
Thank you for the opportunity of reviewing and commenting on the Draft
Environmental Impact Statement for this project.
Sincerely yours,
i
2 Incl W. E.
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43
CaMENTS
1. Page 6: In the entire report, there was no delineation of the
phosphorus deposits located in the vicinity. There was no correlation
of phosphorus levels to population centers; therefore, it seems that no
conclusion can be made concerning the population center contribution of
nutrients to the surface water systems in the area.
2. Page 7: One would expect higher concentrations of phosphorus in
the shallow wells (see page 64 of the A/E's report). The wells tested all
show excess turbidity, a situation which normally would not occur in a
domestic well. One would expect some outside source of the turbidity and,
logically, would expect an increase in phosphorus. Chloride, a good
chemical indicator of fecal pollution, does indicate (pp. 64-68 of A/E's
report) that some of the wells may be receiving human waste.
3. Page 7: Spray irrigation water applied to the land will enter
the groundwater along with some nutrients, depending on the treatment
rates. There is no information presented to show that the soil condi-
tions present in the proposed spray areas will be able to take the amount
of water expected to be applied. Further, assuming the sprayed area will
be "harvested" of its crop every seven to eight years (page 115 of A/E's
report), there is no mention of the problem of solids buildup on the
individual plants as the spray is applied, as occurs in a spray type of
treatment system. If a "Christmas tree" operation is to be used, the
solids question will be very important if there is to be a commercial
market for the trees.
4. Page 21: The word "efficiency" is misspelled.
5. Page 23: Considering the relatively low populations involved in
the area and the relatively "high phosphorus content of the geological
formations", there is question that there will be a significant increase
in the water quality of the two lakes. There will still be a threshold
value of phosphorus to cause algal blooms, due to the geologic formations.
6. Page 24: Spray effluent, although chlorinated, will still carry
virus. Considering the possible high suspended solids of the lagoon
effluent, unless sufficient contact time is allowed with the chlorine
bacteria will not be destroyed. There are documented cases where solids
interfere with chlorination. If mists occur, there is every possibility
that disease organisms can be carried out of the immediate spray area
unless the solids concentration is controlled.
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44
Response to Department of the Army (Corps of Engineers) Letter
Following this response is a copy of EPA's letter to Fremont
County forwarding the Corps' suggestions on Flood control and con-
struction permits.
Its interesting to note that the Department of Housing and Urban
Development in their letter of comments indicates that Fremont County
is not identified under their flood insurance program as having any
special flood hazards. They state that, therefore, there is no need
for land use controls with respect to potential flooding.
In response to numbered comments:
1. We agree. The planning study on page 62 states, "Attempts to
associate total phosphorus load on the surface water courses
with major population centers in the study area are inconclu-
sive in all areas except possibly Henry's Lake." Also, "Nitrate
analyses provide no conclusive information concerning the source
and extent of water quality problems." However, shallow well
data does provide some support for the conclusion that the pop-
ulation centers are contributing phosphorus to the surface
waters.
2. Again, we agree. There is no apparent conclusive explanation
for this phenomenon. The turbidity may well have been due to
the sampling technique. However, a substantial number, rather
than "some" of the wells, do appear to be receiving human wastes,
as do surface water courses in many locations.
3. Although not specifically presented in the planning study, soil
samples were taken at all of the alternative spray field sites
considered. With a few exceptions, all of these samples in-
dicate the subsurface soils to be light, friable, well-drained
material with little or no clay being present. Based on in-
formal discussions with the USDA Agricultural Research Service,
Kimberly Station, this would suggest that there should be few,
if any, problems encountered with compacting soils or solids
build-up. These soils should be able to accommodate the phos-
phates, and the surface vegetative cover should accommodate the
nitrate. However, careful maintenance, operation, and testing
will be required to help insure that this problem does not occur.
4. This misspelling has been corrected.
5. Again, we agree; however, recent history would indicate in
certain areas eutrophication is reaching advanced stages.
Meanwhile, there has been no apparent increase in the contri-
bution of phosphorus from natural sources. Although the re-
moval of nutrients from surface waters due to septic tanks may
not significantly increase the water quality of lakes, it should
prevent this accelerating rate of eutrophication.
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45
6. Aerosol transmission of viruses has not been shown to be a
health hazard, based on the evaluation of existing spray dis-
posal projects across the country. Following the aeration
and settling in ponds, in the vicinity of 20-60 milligrams/
liter of suspended solids would be expected. Although this
will require an increased dosage of chlorine for proper dis-
infection-, it should not be significant in view of the relative
small size of these treatment systems. Winds are not a par-
ticular problem in this area and there are no habitations lo-
cated close to the sprayfield sites. On the other hand, dis-
charges of viruses to surface courses for a treatment and dis-
charge process could present more of a problem in view of the
heavy recreational use that now exists for these waters. Use
of the larger droplet size should preclude significant aerosol
dispersion.
As a point of interest, aerated lagoons are used for domestic
waste treatment at the following Idaho communities: Richfield,
Inkom, Lava Hot Springs, Rigby, Page, Smelterville, Kootenai-Ponderay
S.D., Bonners Ferry, Glenns Ferry, Horseshoe Bend, Marsing, and
McCall. Although Wendell is the only Idaho community now utilizing
spray irrigation for effluent disposal, this technique is used by
four industries: Burley Processing at Aberdeen, Non-Parallel Corp.
at Blackfoot, Idaho Supreme at Firth, and Rogers Bros, in Rexburg.
Informal discussions with State Health personnel suggest no known
aerosol dispersion problems caused by these plants, and no reported
cases of virus infections attributed to them.
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46
RECEIVED
FRA
Cctober 11, 1975
U. S. Environment
Region X
1200 Sixth Ave.
Seattle, Washington 98101
Project - No C-l 601 86-01
Island Park Area
North Fremont County
Idaho
Dear Sirs :
I am a property owner concerned with good and necessary ecological
changes necessary to the preservation or our environment. Therefor I am
calling your attention to a very unnecessary proposal that will cause
severe and unwarranted damage to esthetic qualities in a particular area
at Island Park Idaho. My reference is to a sewage proposal project for the
general area of Island Park Idaho as proposed by the Engineering Firm of
Forspren and Perkins.
Facts :
1, There undoubtedly is Contamination of streams and lakes from
human fecal matter in some parts of Island Park, Idaho.
2. The Forsgren Perkins report inferred that they made no attempt to
determine who's properties are dumping sewage into the rivers
and lakes.
3. The Forsgren Perkins report does not indicate any effort on their
part to evaluate the quality or performance of private disposal
systems along the rivers and lakes.
4. Some private disposal systems consist of a couple of 55 gallon
drums. These are contrary to modern minimum standards.
5. Some private sewers dump directly into the streams. Some of these
openings are hidden under boat docks.
6. The Forsgren Perkins report has excluded some property from the
sophisticated proposed system. These exclusions pertain to
properties where lot sizes are comparative to a postal stamp in
size as related to the larger acreages which have been included in
the proposed system. Also these exclusions are much closer to
the streams and on much higher water tables than property that
have been included in the proposal.
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page 2
47
7. Some of the property owners who have been included for the
disposal system can't help but think they are being used by
developers to help pull the developers out of a bind they
have been caught up in because the ground they want to develop
is broken down to very small parcels and sitting on high
water tables with poor percolation results.
8. The Forsgren Perkins report indicates adverses to environment
will be minor.
Reasons for My opposition:
1. Zone $k in the I.P.Bill's Island Park - Yale Creek sub area
encompasses too large an area.
2. The Yale Creek sub area contains 622 acres which is broken down
to 422 lots. Out of these 422 lots the following facts are
evident.
a, one owner purchased and fenced approximately 38 acres for
his home and privacy and not to re-sell.
b. Many owners purchases adjacent lots to their home site
strictly for their own privacy and not to re-sell.
c. If people mentioned in a and b above had not purchased
additional lots for their privacy, the average lot, size is
still over one acre. Because of a and b situation the
ground per cabin is well over one acre in size.
d. Most all lots were plotted as one or two acre lots by the
developer.
e. Well in excess of 90$ of the ground involved (Yale Creek
division) is of a very rocky nature with huge boulders near
and on the surface, dense with lodge pole pine, fir trees,
and beautiful forrest foilage. The area is characterized
by steep elevation differences.
f. Mechanical earth moving equipment has to be supplemented
with blasting during construction of footings for cabins,
power lines and disposal systems.
g. Culinary wells in this area average a depth down to first
water well in excess of 100 feet. Many wells are over
250 feet in depth.
h. We are concerned with the effect blasting for the collection
line on the proposed sewer system will have on our wells.
Also the destruction on the surface environment.
i. The Yale Creek area is a recent development (less than
10 yrs old) and during this period the State Health
department has diligently inspected all of our disposal
systems.
j. Page 53 CF<) of the Forsgren Perkins report states "bacteria
counts observed on Yale - Hotel Creek were of non-human
origin. There are other references in the report which
tend to discount a need for the proposed system in this
area.
3. If the report sees fit to exclude lots or sections in other areas
that are close to the river and which are less than 1/3 acre in
size and are sitting on higher water tables and the development
transpired prior to the more stringent sewage disposal requirements
for private systems then surely our Yale Creek area certainly
qualifies for the SAME CONSIDERATION.
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page 3
48
Conclusion:
I have studied the Forgren Report, am aquainted with the various
development proposals relative to developers, have seen sewage dump-
ing in the river, and I am of the opinion that there is no
justification for including the Yale Creek sub-division in on the
proposed Island Park Sewage system.
Since E.P.A. funds are involved as well as E.P.'A. expertise I
request that you look into the Yale Creek area. This area is
scheduled for the Sewage disposal system with a starting date of
19?8.
Sincerely,
Richard G. Hackworth
ROH/dh
oc file
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49
Response to Richard G. Hackworth Letter
Although Figure 20 of the Planning Study shows an interceptor
serving Shotgun Village Estate in zone 4, the only service
planned initially for the first phase of construction would
be to the Shotgun Summer Homesite. Capacity will be provided,
however, for future service to the Yale Creek Area at such
time as it becomes warranted. Justification for future service
to the rest of zone 4 is contained on page 78 of the planning
study.
Fremont County's consultant has indicated that they did not
detect any outfalls to water courses during the study. If
any are known, they should be reported to the County so that
they can be corrected as soon as possible, since they are in
violation of State Water Quality Standards, unless a variance
is granted.
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50
LEAGUE OF WOMEN VOTERS OF IDAHO
329 South Phillippi
Boise, Idaho 83705
October 27, 1975
Mr. Richard R. Thiel, Chief
Environmental Impact Section, M/S hh3
'favironmental Protection Agency
1 200 Sixth Avenue
Seattle, .'/ashington 98101
Dear Mr. Thiel,
RECEIVED
OCT 301975
EPA-FIS
Having received the Draft Environmental Impact Statement on the North
Fremont County-Island Park Area tfastewater Facilities (EPA Project No. C-160186-01)
I would like to submit the following comments on behalf of the League of
Women Voters of Idaho.
The Draft Statement certainly serves to reinforce the gravity of a
situation of which we were already most aware - the water pollution problems
existing in the area under consideration. And even a reader already familiar
with the environmental values is impressed anew with the obviously lovely
and unique qualities, the diversity of wildlife and habitat, and the high
esthetic values which are present. The list of wildlife species present
sounds like a naturalist's dream world. (Other respondents will surely have
pointed to the errors in listing species as "threatened" which are in fact
"endangered". ) Thus we find a very basic conflict between environmental
goals 3 and 1; as listed on page 5 of the Impact Statement. Leauge members
doubt that the preservation and even enhancement of fish and wildlife and
their habitats is compatible with the development of the recreational
capacity of Island Park without careful attention to a concept which we
uave always found very relevant indeed - that of carrying capacity.
My reading of this long and complex document has not served to instill
confidence that the environmental values have received a full measure of
consideration in the selection of a method to solve a very real and pressing
problem, Page 62 discusses regional systems in preference to smaller
treatment systems for areas of most concentrated development. And although
we can understand the difficulty of monitoring many small systems and even
that somewhat less efficient treatment might be provided, we do wonder about
the statement that development will tend to be confined to those areas
having a regional system. May we suggest that without proper countywide
planning and zoning, development is going to continue wherever an
enterprising developer believes it is economically feasible. In reading
the comments given at the hearings, in fact, the impression is gained
that even now development would continue were it not for the moratorium
imposed because of the water pollution problems. Another area in which
we have not found sufficient information to justify the regional system
is in relation to the fluctuations in population. The Island Park population
figures, with 130 permanent residents and 6,800 or better in the summer,
are a case in point. Might not as efficient a community system as possible
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51
be more flexible for this great fluctuation in population? In short, we find
ourselves wanting answers to many questions about smaller community systems,
leading us to believe that the proposed regional systems have been a foregone
conclusion from the beginning.
To speak more specifically to a few problems under the regional systems
as proposed, when it comes to the alternate sites selected for lagoons and
sprinkler systems there is no information to justify why particular sites
were chosen, nor that they are indeed the best sites, particularly from an
environmental point of view. '!e noted that such sites tend to be located on
public land while the development which has caused the problem is for the
most part on private land, 'fe agree with Supervisor Olson of the Targee
Forest and his comments concerning this matter at the Island Park public
hearing. Other sites than Forest Land should surely be considered for the
sprinkler systems, and we woinld also particularly recommend consideration of
the golf course as a feasible site* There seems to be evidence that damage
can be caused to trees, thus making open areas the better choice. And we
have read that evidence also indicates a tendancy to earth compaction with
a larger droplet, thus making a finer spray more advisable.
Of course, the crux of the problem is how a contemplated sewerage system
aids and abets land use planning, a subject which I, as %vironmental Quality
chairman for Idaho's -League of -tomen Voters, am not competent to tackle,
except as it impacts on environmental values. And since it is the quality of
the environment which has drawn people to this area one cannot help but
wonder how soon added development will destroy those very values which have
made this land desirable. League members thus urge that in making decisions
for this lovely area environmental values be given full consideration. We
consider such a course practical as well as necessary, for without the high
qua'ity environment the dollar values will rapidly diminish.
Sincerely,
i j t. ii { /.. e -_
Doli Obee
Environmental Quality Chairman
l«
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52
Response to League of Women Voters Letter
1. See page 2 of Department of Interior letter and EPA's response.
2. Agreed, the definitions of "preservation" and "development" do
suggest a dichotomy. The concept of carrying capacity of the
resource is key to the future management of the area. The
article, "Carrying Capacity: Maintaining Outdoor Recreation
Quality," by Lime and Starkey (see Bibliography) contains a
good discussion of this concept. Carrying capacity is a dynamic
concept capable of manipulation by the manager, since it has
three basic components: (1) management objectives, (2) visitor
attitudes, and (3) recreational impact on physical resources.
The provision of sewer service is not the determinant of the
future quality of the recreational experience, but it will
place greater demands upon the area's resource managers as they
evaluate carrying capacity. Based on the demonstrated perfor-
mance of state and federal land use management agencies as com-
pared with private developers and local units of government,
there is every reason to believe that carrying capacity will
receive careful consideration in the future comprehensive
planning and zoning management for the Island Park area, due
to the preponderance of land under state and Federal control.
As discussed in the Preface of this final Environmental Impact
Statement, EPA has attempted to encourage development of sound
land use planning and zoning techniques by use of a grant con-
dition which will be carefully monitored. The management by
objectives set for the Island Park Area by those participating
in land use management will be the controlling factor in the
determination of its carrying capacity.
3. The concept or technique of restricting or concentrating de-
velopment through provision of sewerage service to specific
areas, when coupled with comprehensive land use planning, seems
to be gaining wide acceptance.We agree that without land use
controls or without sewerage facilities, development will still
occur, and in a less desirable fashion.
4. Four separate localized systems as compared with one large re-
gional plant for the entire area has many advantages: cost,
implementation, flexibility and lesser environmental impact.
We do not feel that smaller community treatment plants would
be practical or acceptable, however, especially in accommodating
load fluctuations. Septic tanks with few exceptions are not
suitable because of soils limitations and high groundwater con-
ditions (see pp. 10-11). Package plants do not accommodate
flow fluctuations and require careful maintenance and operation,
and probably would constantly be in violation of their discharge
permit effluent limitations. Any system of several small plants
would present major maintenance operation and management problems.
Aerated lagoons appear to be the best solution: cost-effective,
easily maintained and operated, and capable of handling wide
fluctuations in loading.
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53
5. Selection of lagoon and sprayfield sites is discussed in the
Study on pp. 107-110. See also EPA's response to p. 4 of the
Department of Interior letter, especially the Table of Site
Considerations. As stated on p. 107, the primary considerations
in site selection were: (1) cost of the required transmission
lines, and (2) environmental impact for each sub-area. Other
sites were studied and screened out, and do not appear in the
report. Sprinkling of effluent on the Island Park golf course
is not being given serious consideration. Twelve sites, then,
were studied and screened for final selection of four, which
is considered a reasonable range.
We share your concerns over use of National Forest lands for
utility purposes when private lands are available. However, when
the wastes are generated principally from activities on these lands,
the Forest Service should do (and indeed has done) its share in
finding suitable treatment and disposal sites. In any case, EPA's
construction grant regulations require a cost-effective evaluation
of alternatives, aimed at determining which treatment system will
result in the minimum total resources costs over time. The alter-
native selected must be the most cost-effective without overriding
non-monetary costs. This provides, then, a basis for careful eval-
uation of the comparative "cost" of using Forest Service lands when
private lands appear unavailable or prohibitively expensive. Private
land may be expensive to the point of its purchase possibly resulting
in a severe economic impact on project users. Private land costs from
$400-600/acre for sagebrush land and $600-800/acre for forested land.
This means that a 50 acre site could cost from $20,000-40,000, which
could have a significant impact on the cost-effectiveness comparison
of alternatives as well as cost to users. Land costs for some de-
sirable sites have been reported as high as $5,000 to 10,000/acre,
which is beyond the realm of financial feasibility. State and
Federal governments paying 90% of eligible costs have a certain re-
sponsibility to keep project costs low in order to spread limited
public funds as far as possible. Where the bulk of the wastes is
from private facilities, first consideration should be given to
disposal on private lands. Similarly, in areas where a large or
even predominant share of the wastes is from public campground or
trailer facilities, we see no reason why treatment and disposal on
public lands should not be considered. Please note in the Preface
to this EIS that a grant condition, calling for a revaluation of
private vs. public land for treatment and disposal sites, is recom-
mended.
The effect of land disposal on lodgepole pine growth can be
evaluated during phase one of the project, before other final spray-
field sites are selected. Problems of soil compaction due to large
droplet size are not anticipated, based on informal discussions with
the Kimberly, Idaho station of the USDA Agricultural Research Service.
Soils in the areas under consideration are light, friable, usually
granular, well-drained, and contain a minimum of clays. Careful
operation and monitoring should keep this problem under control.
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54
STATE OF IDAHO
DEPARTMENT OF FISH AND GAME REGION 6
1515 LINCOLN ROAD
IDAHO FALLS, IDAHO 83401
October 31, 1975
Mr. Richard R. Thiel, Chief
Environmental Impact Section, M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Thiel: Re: EPA Project No. C-160186-01
DRAFT ENVIRONMENTAL IMPACT STATEMENT,
N. FREMONT CO., ISLAND PARK AREA,
WASTEWATER FACILITIES
This Department welcomes the opportunity to comment on the wastewater
control plan for Island Park, North Fremont County, Idaho.
From our standpoint, the selected plan (spray irrigation to achieve
secondary treatment plus nutrient removal) is the only acceptable plan
formulated. The plan would reduce nutrient loading problems at Henry's Lake
and Island Park Reservoir. If the plan is not adopted, the projected 6,000
to 20,000 (people at one time) 20-year population increase in the drainage
above Island Park Reservoir will have a disastrous effect upon the Henry's
Lake and Island Park Reservoir fisheries, where nutrient loading is already
critical.
In the past, localized trout dieoffs have occurred in Henry's Lake in late
winter because trout were forced by anaerobic conditions throughout most of
the lake to over-concentrate in warmer spring waters. Nutrients from septic
tank fields are suspected to have increased the heavy blooms of blue-green algae
that caused the oxygen deficiencies. Substitution of spray irrigation for the
septic tanks should reduce phosphorous and ammonia nitrogen to more-tolerable
limits and make wintering conditions better for fish. Further, spray
irrigation could enhance natural propagation of cutthroat trout in streams such
as Targhee, Howard, Timber, and Duck Creeks where surface diversion occurs during
the period when trout fry are migrating lakeward provided the spray fields are
located so as to reduce the needs from surface diversion.
We agree that water monitoring below Island Park and Henry's Lake Dams is
needed to assess such factors as dissolved oxygen, chemistry, temperature and
algal turbidity.
RECEIVED
NOV03197b
EPA-EIS
EQUAL OPPORTUNITY EMPLOYER
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55
Mr. Richard R. Thiel
October 31, 1975
Page 2
On page 19, first paragraph of the planning study, the capacity of Island
Park Reservoir should be 127,300 acre feet rather than 27,300.
Reducing the public health hazard in Island Park will put greater demands
upon the stream and lake fisheries because of greater public usage. This will
require more intensive management on our part; however, we feel that the plan
is necessary and will have an overall beneficial effect upon the important
fisheries of the Island Park area.
Sincerely,
IDAHO DEPARTMENT OF FISH AND GAME
Joseph C. Greenley, Director
Tom Reinecker, Supervisor
Region 6
TR: jl
cc: Bureau of Environmental
Services
Bureau of Fisheries
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56
Response to Idaho Department of Fish and Game Letter
1. This benefit will accrue only if sprayfield site no. 3 for
the Henry's Lake sub-area is utilized, permitting a substitution
of treated effluent for diversion from the surface streams for
irrigation purposes.
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57
UNITED STATES DEPARTMENT OF AGRICULTURE
FOREST SERVICE
Targhee NF
St.Anthony, Idaho 83445
October 31, 1975 8410
r Richard R. Thiel, Chief
Environmental Impact Section, M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Wa. 98101
L
Dear Mr. Thiel:
This letter is in response to Mr. Smith's correspondence of
September 22, 1975 which enclosed a draft EIS statement for North
Fremont County, Idaho Wastewater Facilities, EPA Project C-160186-01.
We have the following comments and suggestions which should be
addressed in the final EIS.
We, of the Targhee National Forest, concur that corrective action
for the sub-areas listed is needed and that the corrective action
should entail solutions to water pollution on area-wide and all in-
clusive basis as proposed. We feel the benefits to be derived outweigh
the impacts.
We concur that the proposed method of treatment is the best method
based on todays technology in sewage treatment. If technology develops
s superior treatment method for these areas it should be employed at
the appropriate time and place.
We specifically agree with the proposed corrective action for the Mack's
Inn-Island Park Lodge sub-area including the general location of the
proposed treatment facilities. We have jointly, with Frenont County
and it's contractors, worked toward a corrective action that best, meets
Federal, State, and local objectives in pollution abatement. This
proposal is essential to treatment of wastes fron Federal facilities.
We do not concur with the selected alternative facility sites for the
I.P. Bills Island-Yale Creek or Last Chance-Ponds Lodge sub-areas. We
do not believe the studies and analysis made for these two sub-areas
has been extensive enough to justify use of Forest Service land. Many
people look to the Forest Service to keep National Forest lands free of
facility development that tends to expand and enhance development on
privately owned lands. Ccnmunity planning adjacent to the National
Forest should incorporate where practicable within private lands, their
requirements for water and wastewater treatment, utilities, access roads
and other cottnunity needs. RECEIVE
NOV 0 Jib"!?
EPA-FIS
6200-11 (1/6»)
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58
8410 (P-2)
We feel these two sub-areas have ample opportunity to plan their
needed facilities within private land. We recognize County control
through comprehensive planning, zoning, and ordinances are presently
lacking, but believe such control is essential to accomplish cotmunity
planning that incorporates the essentials within the limits of their
development.
We do not want our support of the corrective action proposed for the
four sub-areas to be misconstrued, as a Forest Service endorsement for
expanded development in North Frefnont County. We do support corrective
action for the problems that now exist.
We feel, for the scope of this proposal, adequate inventory, study, and
evaluation of effects on wildlife, fish, vegetation and water and air
resources has been presented. We base this judgment on the findings of
the National Forest Interdiscipline team of specialists engaged in
studying and evaluating this sane part of Fremont County. However,
more study and evaluation of social-economic effects must be presented
prior to Forest Service consideration in support of development expansion.
We suggest that some inaccuracies noted be reworded as follows:
Page 14, Land Use, first paragraph, next to last sentence is not accurate^
The area has not been identified as a National Geothermal Resource Area.
Island Park does contain a small KGRA (Known Geothermal Area) immediately
adjacent to the West Boundary of Yellowstone National Park.
Page 16, Other Agency Programs or Projects
Our retention lagoon serves only the Ranger Station. (Page 6- Existing
Treatment Facilities needs this correction also).
We would consider abandoning our lagoon if another system was developed.
All Forest Service wastes in Island Park, except those at the Ranger
Station, are hauled to State approved treatment facilities by contract,
however, the Forest Service does not operate a trailer waste holding
site.
GEORGE A. Olson
Forest Supervisor
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59
Response to USDA Forest Service letter
1. We disagree with the concept of not using public lands for
treatment and sprayfield sites. See comment no. 5 to League
of Women Voters letter for discussion.
Site no. 3 in the I.P. Bills Island -- Yale Creek sub-area is
located on Bureau of Land Management ground. The other two
sites are located on Forest Service ground. In the eastern
half of the sub-area there don't appear to be any suitable
sites that are not located on Forest Service property.
Site no. 1 is preferred because it has the most favorable lo-
cation in respect to the proposed initial service area, and,
therefore, would be the most cost-effective. Much of that
initial load will be from Forest Service campgrounds.
For the Last Chance -- Ponds Lodge sub-area there do not appear
to be any feasible sites for treatment and sprayfields that are
not located on Forest Service land. Again, much of the waste
loading will be coming from Forest Service campgrounds. For
these reasons, and especially in view of the high cost associated
with the purchase of private lands for sprayfield sites, there
appears to be no choice but to use public lands for treatment
and sprayfield sites. However, where recreation is competing
with treatment or sprayfields for use of the sites, the recreation
use should be considered of higher priority.
The County's consultants are continuing the study of site avail-
ability. Final selection will have to meet with Forest Service
approval.
2. Recognizing the lack of County land use control, comprehensive
planning, and zoning, we have developed the grant condition
discussed in the Preface to this EIS. Hopefully, this will
assure that necessary land use controls are developed and that
land use management agencies will have participation in the
management objectives established by the County for these re-
creation lands.
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60
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
ARCADE PLAZA BUILDING, 1321 SECOND AVENUE
SEATTLE, WASHINGTON 98101
October 30, 1975
REGION X
Office of Community
Planning & Development
IN REPLY REFER TO!
NOV041975 10D
Dr. Clifford V. Smith, Jr. EPA-EIS
Regional Administrator
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Wa 98101
Dear Dr. Smith:
Subject: Draft Environmental Impact Statement
North Fremont County, Idaho
Wastewater Facilities
We have reviewed the statement dated August 29, 1975.
The proposed project is the construction of sewerage facilities serving
the Island Park Area in Fremont County, Idaho.
Most of the housing activities in the area are of the recreational
type, and there have been no subdivisions approved by HUD in the area.
Your statement indicates that there is no comprehensive plan at this
time, but a program is under way. We assume that this proposed project
has no apparent conflict with the program, and Is consistent with the
purposes established in the County Subdivision Resolution.
We find that Fremont County is not identified under our Flood Insurance
Program as having any areas with special flood hazards; thus there is
no need for land use controls with respect to potential flooding.
We see no significant adverse impacts in our areas of concern, thus
have no objections to the proposed project.
l«
Thanks JkrfcBfc opportunity to comment.
Sincerely,
calia
'- 'Assistant Regional Administrator
cc: CEQ (5)
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61
Response to Department of Housing and Urban Development Letter
1. The proposed project has no apparent conflicts with the purposes
established by the County Subdivision Resolution.
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STATE OF
DEPARTMENT OF HEALTH AND WELFARE STATEHOUSE
BOISE, IDAHO 83720
DIVISION OF ENVIRONMENT
November 3, 1975
RECEIVED
NOV 041975
Mr. Richard R. Thiel, Chief EPA-ElS
Environmental Impact Section, M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
RE: Draft Environmental Impact Statement on North Fremont County (Island
Park Area), Idaho Wastewater Facilities, EPA Project C-160186-01.
Dear Mr. Thiel:
As you know our Division is very concerned about the water quality in the
North Fremont County area and therefore we welcome the opportunity to
review the draft environmental impact statement. Although the document
appears to be excellently done, there are a few specific areas we believe
need to be revised for the final EIS.
General Comments
1. Though the impact statement does address the population projections
in detail, it appears the 1994 projections are extremely optimistic.
These projections will be influenced extensively by national, state,
and local economics. It would appear increased growth at a rapid rate
might occur in the first 3 or 4 years of proposed project completion and
then level off to a more reasonable standard growth rate level. There-
fore, although design capacity for the proposed facilities may be for the
optimistic population projection, the proposed construction of a facility
should be phased to include additions to care for the future population.
2. It is our belief that the document has skirted the major issue of
accelerated growth due to the proposed project and its potential conse-
quences. The statement fails to sufficiently consider a number of the
secondary effects of the proposed action. One such impact can be seen
in Figure 2 of the report. This shows that a great deal of the land
surrounding critical shoreline is in private ownership and therefore
subject to accelerated development with the construction of sewage treat-
ment facilities. Development of these areas could result in the upset
of the natural ecological balance. Therefore, the final document should
address the secondary impacts of induced growth in much greater detail
than that given in the draft.
EQUAL OPPORTUNITY EMPLOYER
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Mr. Richard R. Thiel, Chief 63
November 3, 1975
I'ai'c 'Iwo
3. he must emphasize that to be completely effective the project should
be constructed in conjunction with a comprehensive land use plan for the
area. This would serve to limit growth and development in the area and
insure the project achieves its objectives of reducing water pollution.
Spec i fLc Comments
1. I'age 3, Paragraph 4: This paragraph indicates that, the corporate
boundaries of Island Park extend to Mack's Inn in the north. This is
incorrect because the boundary really extends to Valley View Ranch some
eight (8) miles north of Mack's Inn.
i. Facilities Plan, Figure 2: The names of the subareas should be shown
directly on the map thereby making the report easier to follow.
3. Facilities Plan, Page 106, Section (i) : In an area such as North
Fremont County, it is doubtful that an aerated lagoon system will be
"aesthetically appealing." Therefore, this consideration should be
removed from the list.
Our comments on this draft statement have been classified LO-2, LO (Lack
of Objections) 2 (Insufficient Information), corresponding to the EPA's
rating system for environmental statements. This rating is based primarily
on the report's insufficient evaluation of the secondary impacts of induced
growth.
If we can provide additional information or clarification, do not hesitate
to contact Mr. Al Murrey (384-2390), Chief, Bureau of Water Quality.
Sincerely,
DEPARTMENT OF HEALTH
AND WELFARE
Administrator, Division
of Environment
.WS/'IWK/sy
HPA, Idaho Operations Office
Henry Moran, IDHW - Pocatello
Orlando Ualke, IDHW
Terry Keyes, IDHW
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64
Response to Idaho Department of Health and Welfare letter
1. Although the 1994 projections may appear optimistic, they are
considerably less than those presented in the County's 1971
Comprehensive Sewer and Water Plan, and they are less than
those contained in the County's first draft of the Planning
Study. The primary reason for this reduction is the budgetary
constraints that have been placed on the Forest Service in
their development of recreation facilities. As demand increases
in this country, it is very possible that the Federal government
will again increase its funding of recreation facilities to
the Forest Service, which would cause these projections to be
understated. Phased construction of facilities is indeed pro-
posed in an effort to accommodate future projections in the
most cost-effective fashion. Unfortunately, sewer lines are de-
signed for 50 year or longer life, such that they must be sized
for long term development in order to be cost-effective. How-
ever, in the case of most of the sub-areas, these future in-
creases would cause at best a few inch increase in size of
gravity mains, and perhaps only a 2 inch increase in force
main sizing, which would result in minor increases in cost.
For the construction of lagoon treatment facilities, whenever
possible only one cell will be built initially and the minimum
number of aerators installed. Cost-effectiveness considerations
again will be the major constraint. Lands for sprayfields and
sprayfield equipment will be utilized only as required. In
almost all cases, collection system lines will be at a minimum
size allowed by state health department codes.
In summary, it does appear that the project has employed cost-
effective phasing. As to the apparent problem of state and
Federal governments financing future private development, State
Local Improvement District codes require that all property be
assessed in proportion to its benefits. New development will,
therefore, be paying its fair share of the local costs. As to
the provision of state and Federal funds for interceptor and
treatment facilities for a new or recreation development, this
is a matter to be decided through application of the state's
priority rating system for funding.
2. We admit to the difficulty of thoroughly evaluating secondary
impacts associated with this kind of project. However, we do
not share your concern that the land surrounding critical shore-
lines which is in private ownership, would be subjected to ac-
celerated development causing an adverse impact.
In the Henry's Lake sub-area, this may be true for the shore-
line along the north-northwest section of Henry's Lake, from
Staley Springs to Wild Rose Ranch. In the Mack's Inn -- Island
Park sub-area, all private land for which service is being pro-
vided is already developed. This is also true for the I.P.
Bills Island — Yale Creek sub-area. In the Last Chance --Ponds
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65
Lodge sub-area, the only private land being served is already
developed. The remainder of the areas for which service is
being made available is in Forest Service control. The Forest
Service is phasing out its private home site developments along
the Buffalo River from its confluence with the Henry's Fork to
the Buffalo Campground. It appears that they will be carefully
controlling the shoreline development in areas within their
jurisdiction.
As indicated in the draft EIS, 25 percent of the private land
now subdivided has already been developed, and of the undevel-
oped area 80 to 90 percent of the lots are already sold. It
is our conclusion that almost without exception the adverse
impacts have already occurred. It is also our conclusion that
in the absence of adequate sewerage facilities and adequate
County land use controls, development would still occur and in
areas resulting in more of an adverse impact on the environment.
Provision of sewerage facilities coupled with adequate County
land use controls, and a dynamic program of planning by the
land use management agencies, should realize the best and highest
potential for proper use of the resources in the Island Park
area. There may be considerable advantages associated with
the confinement of growth to planned areas. We would certainly
appreciate more assistance in the evaluation of specific secondary
impact.
3. Development of a comprehensive land use plan and zoning ordinance
is a condition of the grant as discussed in the Preface of this
final EIS.
Specific Comments:
1. This correction has been made.
2. This has been called to the County's attention for incorporation
in any future reprints of the Planning Study which need to be
made.
3. This has been called to the County's attention. A lagoon could
perhaps be considered to be aesthetically appealing as con-
trasted with a mechanical treatment plant in a natural wooded
area.
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66
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
SUBJECT: Review of Draft EIS on the North Fremont
County Wastewater Facilities
DATE: NOV 6 1375
FROM: Kenneth E. Biglane, Director
Division of Oil and Special Materials Cj^trol (WH-548)
TO: Clifford V. Smith, Jr.
Regional Administrator, Region X
Attn: Richard Thiel
The comments of the Office of Water Program Operations on
the subject EIS are enclosed. If any of the issues raised in these
comments require clarification, please contact Geraldine Werdig,
Chief, Environmental Evaluation Branch, (202)245-3054. This
memorandum confirms the comments telephoned to Mr. Thiel
on November 3, 1975.
Project Description
Location: Fremont County, Idaho
Proposed Action: Construction of collection systems, interceptors,
aerated lagoons, winter storage, chlorination
facilities, and spray irrigation systems for four
areas in Fremont County, The existing treatment
units are septic tanks which are experiencing
a high failure rate.
Major Issues:
1. The extent to which continued recreational
development will impact the area resources
2. The extent to which the availibility of sewerage
facilities will induce land use changes or rate
changes.
3. The absence of local land use planning which
might serve to control development or mitigate
adverse impacts
4. The secondary impacts on fish and wildlife
habitat
Review Coordinator: Kevin Warner
Enclosure
RECEIVED
EPA form 1320-6 (R»v. 6-72)
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67
Office of Water Program Operations
Comments on
Draft Environmental Impact Statement
Island Park Area Wastewater Facilities
North Fremont County, Idaho
1. The Region is to be commended for producing a document of this
quality. The information is presented in a well-organized fashion
and allows for an efficient review of the material. The following
comments are intended to point out areas where further information
or discussion is required.
2. To aid in their use, the maps in Appendix A should show distance
scales.
3. There is mention on page 12 of the Agency appraisal of consultation
with the Department of the Interior concerning threatened species
and threatened species habitat. The final EIS should include
information gathered from these consultations as it relates to the
project.
4. As mentioned on page 14, the State Historical Officer has been
contacted to determine if any known historical, cultural,
or archeological sites exist within the study area. The State
Historical Officer's findings should be included in the final EIS.
5. A statement on page 24 describes the impacts of the facilities on
rare, endangered, or unique species as "negligible. " Language
in the final statement should be more specific, and detailed
enough to identify the extent of these impacts.
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68
Response to EPA Headquarters Review Memo
2. Attachment 1 (Sewer Facilities Planning Study): all maps
either show the scale or designate sections (1 sq. mile)
3. Consultation with the Department of Interior concerning threat-
ened species was through their review comments on the Draft
Environmental Impact Statement. Their comments and EPA's re-
sponse are found on page 2 of their letter.
4. Appendix A of the final EIS contains the results of the archae-
ological survey conducted in response to the State Historical
Officer's recommendation. His review comments follow the report.
The survey confirmed the draft EIS1 statement that the project
will have no impact on historical, cultural, archaeological,
or architectural sites.
5. See response to page 4 of the Department of Interior comments
for a discussion of the concept of negligible impact on rare,
endangered or unique species.
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69
IDAHO STATE HISTORICAL SOCIETY
610 NORTH JULIA DAVIS DRIVE BOISE, IDAHO 83706
STATE MUSEUM
October 30, 1975
Dr. Clifford V. Smith, Jr.
Regional Administrator
U. S. Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
Dear Dr. Smith:
r °> 11975
DERATIONS OFFICE
In response to your request for information concerning your porposed
impact statement for Project C 1601 1 86 01 (Island Park Wastewater
treatment facilities), let me suggest in answer to your questions on
page 4 that
1. You will have to provide an inventory of architectural,
historic, and cultural sites in the project area, and
be able to demonstrate that this inventory was used in
the planning process. This requirement is imposed by the
Advisory Council for Historic Preservation.
2. The response on page 4 in question 5 that the study area
has no architectural, cultural, or historic sites is both
inaccurate and inadequate. Our state inventory for that
particular area has not progressed too far, but we already
list 30 or so cultural sites and will have some architect-
ural ones as the survey progresses.
3. Your project is unlikely to have adverse impact upon
architectural sites, but other cultural resources
(especially archaeological) will have to be considered.
An archaeological survey will be required, /^d Peter
Schmidt, Idaho State Archaeologist, will help you to
arrange for one so that you can comply with 36 CFR 800.4
and other provisions associated with Advisory Council
review.
4. Lynn McKee has been in touch with me since an early stage
in preparation of your statement, so that requirement has
been met. Regardless of whether the planning area has
historic or cultural resources, this step is necessary.
RESEARCH
PRESERVATION
RESTORATION
EDUCATION
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70
October 30, 1975
Dr. Clifford V. Smith
Page 2
I appreciate receiving this material concerning the project and shall
be glad to help in the preparation of your impact statement in any way
possible. I shall continue to be in touch with Lynn McKee about this.
Sincerely,
Merle W. Wells
State Historic Preservation Officer
MWWrmjw
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71
IDAHO STATE HISTORICAL SOCIETY
6)0 NORTH JULIA DAVIS DRIVE BOISE, IDAHO 83706
u «j«u>^&dtfi« m
STATE MUSEUM
Project: c 1601 186 01
In order for your project to qualify for federal approval, it is necessary to have an
adequate Inventory of archaeological and historical sites in the area. Any sites on
or eligible for the National Register of Historic Places have to be included. The
impact of the above described project on the archaeological, historical, architec-
tural or other non-renewable cultural resources can be assessed only by an on-site
reconnaissance survey performed by a professional archaeologist. Documentary
research has indicated that there is insufficient evidence to determine if there are
sites which may be eligible for the National Register; therefore, a site survey is
necessary to determine if there are eligible sites and if eligible sites will be affected.
The State Archaeologist will assist any agency or private concern by supplying a list
of consulting archaeologists who have specific expertise in the area concerned. In
the unlikely event that a bona.fide archaeologist is not available to perform such
services, then it may be possible to contract for such services with the State
Historical Society.
As a part of the assessment procedure, it will be necessary to submit to the State
Archaeologist a report performed by a professional archaeologist. This report
will 1) enumerate the kinds of sites and their location, 2) discuss the significance
of the site, and 3) assess the potential impact, if any, of the project on the sites.
These data will then be used by the concerned agency official and the State Archae-
ologist to apply the "Criteria of Effect" (included in 36 CFR 800. 8) and, if neces-
sary, the "Criteria of Adverse Effect" (36 CFR 800.9) as set out in the procedures
for protection of historic and cultural properties under the National Historic
Preservation Act.
If further clarification of these obligations is desired or if further assistance is
necessary, please contact the State Archaeologist or State Historic Preservation
Officer. In any event, we expect to assist you in gaining further advice and
professional consultation.
Peter R. Schmidt, Ph. D.
State Archaeologist
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72
Response to Idaho State Historical Society Letter
The survey of architectural, archaeological, historical, and
cultural sites conducted in response to this letter is contained
as Appendix A in this final EIS. The State Archaeologist's
comments follow the report. The report concludes that the
proposed project will have no primary impact on architectural,
archaeological, historic, or cultural sites in the project area.
These findings have been transmitted to the Advisory Council
for Historic Preservation for tlieir final evaluation.
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73
United States Department of the Interior
OFFICE OF THE SECRETARY
PACIFIC NORTHWEST REGION
P.O. Box 3621, Portland, Oregon 97208
November 11, 1975
RECEIVED
NOV141975
ER-75/946
Mr. Richard R. Thiel, Chief
Environmental Impact Section, M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Thiel:
This responds to your request for comments on the Draft Environmental
Impact Statement for Wastewater Facilities, North Fremont County (Island
Park Area), Idaho.
GENERAL COMMENTS:
Much of what now makes the Island Park Area a scenic, aesthetic and recrea-
tional attraction would be lost if the sewage system is constructed and
development of further subdivisions allowed. A more detailed discussion
of the proposed project's secondary environmental impacts on the quality
of recreational experiences in the Island Park area would aid in project
assessment.
The information contained in the draft statement lacks sufficient detail
to adequately determine the impacts on fish and wildlife resources and
their associated habitats with implementation of any of the proposed
alternatives.
In general the proposed action is oriented toward correction and
development without detailed consideration for the preservation or
enhancement of the fish and wildlife resources of the project area, or
the specific sites considered for proposed treatment and disposal
facilities.
On page two, paragraph, three, third sentence, "the nature of the sensitive
environment, and the potential for significant land use changes ..."
listed among the reasons for statement preparation. However, the
•^6-1976
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74
document does not analyze in detail the primary or secondary impacts which
would occur to fish and wildlife or their respective habitats. The document
should address more completely fish and wildlife impacts which would be
caused by continuing recreational developments and induced land use changes
that the project would encourage and accelerate.
The final environmental statement should include an evaluation of exfil-
tration and infiltration specifications; however, we anticipate that almost
any type of sewer construction should have beneficial net impacts on
ground water in the situation as described.
The draft statement notes that the east central portion of Fremont County
has been identified as a "national geothermal resource area." The official
terminology is "Known Geothermal Resource Area" (KGRA). For planning
purposes, the KGRA boundaries should be identified on maps.
Development of sewage treatment facilities is admittedly desirable to
improve water quality and protect human health in the project area. But
this singular concern should not be dominant over all other resource
values found here. From the information contained in the draft, the
reader can gain the impression that the proposed sewage treatment develop-
ments unquestionably will occur. As a correlative to this conclusion,
much emphasis is placed on economic costs of alternative methods of
development in the draft. Conversely, environmental impacts, other than
water quality and human health, are treated in a superficial manner and
we suggest this part of the analysis could be much improved by more
fully addressing other impacts.
SPECIFIC COMMENTS:
Page 12, paragraph 4. Under the heading of threatened species, list only
the grizzly bear. In addition there should be a heading for endangered
species listing the northern Rocky Mountain Wolf and American peregrine
falcon. The prairie falcon is no longer listed as either threatened or
endangered but is a likely candidate for classification.
Page 12, paragraph 5. We suggest the deletion of the first sentence.
There is no evidence provided that the Department of the Interior has been
consulted regarding possible project impacts on the two endangered and
one threatened species known to be present in the study area as referenced
in Section 7 of the Endangered Species Act of 1973 (P.L. 92-205). The
last sentence in this paragraph says ". . .that there has been detri-
mental impact on threatened species habitat noted in the past due to the
development that has already occurred." Then on page 23, paragraph 3,
4
7
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75
the statement is made that "There is expected to be some increase in
development in the area induced by construction of the proposed treat-
ment facilities." Impacts to any endangered and threatened species and
their habitats and to other wildlife which cannot be avoided with the
project should be identified. If possible, specific locations of these
impacts by site, subarea, study area, and region should be indicated.
Page 14. The statement that there are no cultural sites in the project
area should be documented. For historic sites, the "National Register of
Historic Places" and the Idaho State Historic Preservation Officer should
be consulted. The former was last printed in the Federal Register on
February 4, 1975, and is updated the first Tuesday of each month. The
results of these consultations should be reported and documented in the
final statement.
If archeological surveys of the area have been made, they should be cited.
If surveys have not been made, archeological authorities at the University
of Idaho or Idaho State University should be consulted to determine if
resources are likely to occur and if archeological surveys should be made
prior to construction. The final statement should report what has been
done regarding the protection of archeological resources. Information
regarding the Big Springs site should be corrected. This work of
volcanism has been declared a potential natural landmark. It has been
identified through the natural history theme study method but has not
yet been designated as a natural landmark by the Secretary of the Interior.
Page 14 and 15 - Land Use. The discussion on the bottom of page 14 and
top of page 15 indicates 7,777 acres will be developed over the life of
the project (which apparently is twenty years). It is further stated
that this acreage is 1.3% of the 600,000 acre study area and implies
the project and its related impacts would be insignificant to natural
resources. The implication is that this small percentage represents an
insignificant loss of wildlife values. This appears erroneous. More
accurately, loss of habitat must be viewed in the light of the primary
area affected and, more specifically, what particular species or popula-
tions are involved and how their life requirements are affected.
Page 16 - Other Agency Programs or Projects. This section should address
two additional points:
1. Bureau of Land Management officials have not been contacted for
input into either the study or EIS. It seems appropriate to contact
this agency before developing plans involving land under its
administration.
2. Several of the BLM tracts to be used if the proposed plan is
implemented are currently under selection by the State of Idaho as
Lieu Lands. This could create a potential conflict for the proposed
plan.
1
9
10
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76
Page 17 - Project Alternatives. This section should contain an analysis
of alternative site locations as well as alternative processes. Figures
18 through 21 seem to indicate that lagoon and spray field location was
determined by land ownership rather than land suitability. Although
the study contains a cost comparison of alternative sites and processes,
neither document contains an adequate environmental analysis of alter-
natives. In addition, it appears decisions concerning location and
type of process were made primarily on a dollar cost basis.
Page 18, goal //3. Where and how this goal has been met should be
clarified.
Page 24, Aesthetics. The actual impact on vegetation and fish and wild-
life at each specific site should be identified. The last sentence in the
paragraph implies that there will be impacts on endangered, threatened,
and unique species. The term "negligible" does not adequately identify
and analyze in detail the impacts which are referred to. The specific
impacts should be described and discussed.
Page 25, Secondary Impacts. The secondary impacts which will occur for
endangered or threatened species, other fish and wildlife, and their
respective habitats as a result of the proposed project should be iden-
tified for each subarea as well as for the entire study area.
Page 26, Secondary Impacts. Mention is made that the proposed action will
induce additional population growth (which, incidentally, will create
additional demand for sewage treatment facilities, roads, trails, camping,
facilities, utilities, energy, etc.). The statement "Such activity would
tend to restrict the movements of wildlife, particularly the moose,
trumpeter swans, and geese" is not an adequate discussion of what the
true impact to these and other species will be. It would appear that
primary and secondary impacts on wildlife, and therefore on people,
would be more serious than presented. Also, some attention should be
given to possible beneficial uses of wastewater that are currently or
potentially possible.
Page 27. Some erosion by wind and water will occur at construction sites
before the vegetative cover can be restored. Mitigating measures to
minimize this short-term adverse impact on the surface-water regime should
be considered.
Page 27, paragraph 2, last sentence. The specific minor interferences
which the wildlife will experience should be identified and discussed.
11
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77
Page 28, paragraph 3. It is indicated that lagoons will be lined in
accordance with state design standards, thus effectively preventing
percolation into ground water. Monitoring measures should be considered
in order to maintain the water quality of both ground-water and surface-
water regimes in the area of hydrologic influence of the lagoons.
Pages 28 and 29, Secondary Impacts. The impacts referred to in this
section are not clearly identified in the preceding chapter as is stated
in the last sentence on page 29. Unavoidable adverse impacts to fish
and wildlife should be indicated and be as site specific as possible.
Page 30, paragraph 1. The use of a large droplet size spray system as I *«f
described in the last sentence could possibly cause sufficient soil I *'•
compaction that would have an adverse impact on the plant and animal
communities present.
Page 30, paragraph 4, last sentence. In reviewing Chapters III and IV
of the statement, the specific impacts and mitigative measures referred
to were difficult to identify. These should be clarified.
Page 115, paragraphs A. 1, 21, 3, 4. The selected plan for the proposed
wastewater treatment system should contain an appropriate statement
regarding onsite responsibility for surveillance and maintenance to
assure adequate operation of the system.
ATTACHMENT 1 - NORTH FREMONT COUNTY SEWER FACILITIES PLANNING STUDY
The environmental assessments contained in this attachment do not
adequately identify and analyze in detail the impacts which would occur
to endangered and threatened species, other fish and wildlife, or their
respective habitats, and therefore does not fulfill the needs of the
preceding environmental impact statement as implied on page 2, paragraph
3, of the draft statement.
SPECIFIC COMMENTS:
Page 1, Summary, Conclusions and Recommendations, Conclusion 5. It is
unlikely that the contamination caused by human development in the study
area would render the rivers and lakes sterile.
Page 17, last paragraph, last sentence. If the concentrations of moose
and nesting sandhill cranes and waterfowl on the flats are so dense as
to be a possible cause of water pollution, then the impacts which would
occur to these populations should be discussed in detail in the environ-
mental statement or environmental assessment of the proposed project for
the specific treatment site selected for the Henrys Lake subareas.
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78
Page 30, Threatened and Unique Species of the Study Area. Please refer
to previous comment concerning page 12 of the EIS. The mention of
literature which is pending publication does not adequately describe
in detail the habitat requirements of the endangered and threatened
species of this study area nor the project-caused impacts which would
occur to these species. Of major concern are the secondary impacts
which would occur to endangered and threatened species present as a
result of the increased development and year around use caused directly
by project construction. Please refer to the comments on pages i, 2, and
12, Chapters III, IV, V, and VI of the draft statement, particularly
page 12, last paragraph, last sentence.
Page 33. I. Identification of Environmentally Sensitive Areas. Please
refer to previous comments concerning page 30. Required habitats for
endangered and threatened species are not identified.
Page 94, E. Environmental Considerations. Neither this section or
Table 16 (page 98) adequately describes in detail impacts which would
occur to endangered and threatened species, other fish and wildlife, nor
their respective habitats. This information should be added.
Page 107. IX, The Treatment Plant, paragraph 2. For each of the alter-
native sites selected for evaluation in Chapter IX, the impacts which
would occur to fish and wildlife resources should be identified and
described.
Page 107, A. Henrys Lake Subarea. It would be helpful to know what
considerations were used in evaluating the environmental impacts to
determine which alternative was the most attractive. Please refer to
comments above concerning page 17 of the Planning Study. Additional
alternative sites should have been selected for evaluation. A
systematic means of appraisal based on specific criteria could be used
to evaluate possible primary and secondary impacts to endangered and
threatened species, other fish and wildlife, and their respective
habitats for each site. This would help in meeting the goal identified
on page 34, paragraph 3, No. 3.
Page 108, B. Mack's Inn - Island Park Lodge Subarea. Evaluation of
two sites is adequate in examining the alternatives available to this
subarea. It appears preferable that the treated waste water be
applied to the existing Island Park Village golf course. This would
eliminate the need of committing any additional wildlife habitat to
development and promote a multiple use concept of the study areas
limited land resources.
23
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79
Page 109. C. I. P. Bill's Island - Yale Creek Subarea. It appears that
evaluation of only three sites is inadequate in examining the alternatives
available to this subarea. An example of an additional site would be the
evaluation of the SW1/4 of section 16, T. 13 N. , R. 43 E., BM. This land
is probably destined to some form of development in the near future;
therefore, its use as a spray irrigation site would again eliminate the
need for committing public lands and the associated fish and wildlife
resources.
Page 110, E. General. Please refer to previous comments above concerning
page 30, paragraph 1, of the draft environmental statement. In addition
the study recommended in the last paragraph on page 110 should include
effects of sprinkler irrigation on the wildlife species present at each
selected site.
We appreciate the opportunity to review and comment on this document.
Sincerely yours,
or r c CWr
V^WAJU a- WJu>^^_
Charles S. Polityka
Acting Special Assistant
to the Secretary
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80
Response to U.S. Department of the Interior letter
1. We would agree, however, we are not sure that the more detailed
discussion is needed for an informed management decision.
Within the reasonable scope of an impact statement for this
project, we found it difficult to do a thorough evaluation of
all secondary impacts which would completely satisfy all
readers. In response to these comments we would like to quote
portions of the comment letters from the two agencies most
intimately involved in day-to-day management of the natural
resources of the Island Park area.
Targhee National Forest: "We of the Targhee National Forest
concur that corrective action for the subareas listed is
needed and that the corrective action should entail solutions
of water pollution of area-wide and all-inclusive bases as
proposed. We feel the benefits to be derived outweigh the
impacts. We concur that the proposed method of treatment is
the best method based on today's technology and sewage treat-
ment...We feel for the scope of this proposal adequate in-
ventory, study, and evaluation of effects on wildlife, fish,
vegetation, and water and air resources has been presented.
We base this judgment on the findings of the National Forest
Interdiscipline Team of specialists engaged in study and
evaluating this same part of Fremont County."
Idaho Department of Fish and Game: "From our standpoint the
selected plan (spray irrigation to achieve secondary treat-
ment plus nutrient removal) is the only acceptable plan for-
mulated. . .Reducing the public health hazard in Island Park
will put greater demands on the stream and lake fisheries be-
cause of greater public usage. This will require more in-
tensive management on our part; however, we feel the plan is
necessary and will have an overall beneficial effect on the
important fisheries of the Island Park Area."
3. Current sewer line design and construction techniques and
materials now used have essentially eliminated exfiltration
or infiltration problems. The County's construction speci-
fications will be reviewed for this item and proper testing
following construction will be required.
4. This correction has been made.
5. It was not the intent of the Draft EIS to leave the reader
with the impression that the proposed sewage treatment de-
velopments unquestionably would occur regardless of findings
of the planning study or the comments made by interested public
or agencies.
6. This correction has been made.
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81
7. The first sentence has been deleted. The dissemination of
the draft EIS to the Department of the Interior was intended
to provide the Department with the opportunity to comment on
the possible impacts on the endangered and threatened species
known to be present in the study area. We have not been able
to identify any impacts on endangered or threatened species
and their habitats which cannot be avoided if the project is
to be constructed. We do feel that for all practical purposes
the adverse impact to wildlife has already occurred due to
the 25 percent development in existing subdivided or plotted
areas.
8. See the response to the Idaho State Historical Society letter.
9. As stated above, for all practical purposes, we feel that the
loss of habitat due to development has already occurred. If
the project is implemented, it should have a beneficial impact
on wildlife habitat in that the provision of sewerage facilities
coupled with adequate county land use controls should confine
development and prevent the loss of habitat in new outlying
areas.
10. The only Bureau of Land Management property directly involved
with construction of the project is located immediately north
of Henry's Lake and is land crossed by a proposed force main
going to treatment and sprayfield site no. 1. The County's
consultants did contact local BLM officials during the course
of the planning study. It is also assumed that the Department
of Interior coordinating office would have sent one of the 15
copies of the Draft EIS which they received to the Bureau of
Land Management since it is one of their agencies. No comments
have been received from them. It, therefore, can only be as-
sumed that they do not feel the project warrants their comment.
11. From the standpoint of Environmental Impact, all 12 of the
treatment plant and sprayfield sites studied are considered
environmentally acceptable. As stated on page 107 of the
Planning Study, the primary considerations in site selection
were: (1) cost of the required transmission lines, and (2)
environmental impact. For each sub-area, other sites were
studied and screened out, and do not appear in the report.
Following is a table listing other site considerations which
were utilized in reaching the tentative decision on site se-
lection. In addition to this information and Figures 8 through
21, see Table 16 and pages 107 to 110.
12. This goal has not yet been met.
13. Again, we can only respond to these comments in a general way.
Generally speaking, the secondary impacts on wildlife which
-------
SUMMARY OF SPRAYFIELD
SITE CONSIDERATIONS
SUB AREA
Henry's Lake
Mack's Inn
I. P. Lodge
(late addition)
I. P. Bill's
Yale Creek
Last Chance
Ponds 's Lodge
SITE
1
2
3
1
2
3
1
2
3
1
2
3
AREA
30a.
30a.
30a.
40a.
40a.
—
40a.
40a.
40a.
40a.
40a.
40a.
AVG.
SLOPE
6%
10%
<1%
1%
1%
3%
1%
3%
1%
<1%
<1%
<1%
APPROX.
DEPTH TO
GRND. WATER
50'
20'
3'
30'
30'
15'
30'
30'
30'
20'
20'
20'
SUBSOIL
CONDITIONS
dirty gravel
loam and gravel
3 ft. of soil over
sand and gravel
sandy loam
sandy loam
coarse sand
sandy loam and
dirty gravel
sandy loam over
gravel
sand loam over
gravel
sandy loam
sandy loam
sandy loam
VEGETIVE COVER
June grass and sagebrush
native grass and sagebrush
meadow hay
small lodgepole, native
grasses, lupine
small lodgepole, native
grasses, lupine
3o3f course
clear cut area, re-seeding
annuals, native grasses
large lodgepole, typical
native understory
native grasses and sagebrush
some large lodgepole, heavy
grasses
some large lodgepole, heavy
grasses plus some rock out-
crops
lodgepole, rangeland grasses
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83
would occur are contained in the discussion on pages 27 to 32
of the Planning Study. We are not sure it is practical if
even possible, for this kind of project, to accurately predict
the precise secondary impacts which would occur for each sub-
area on each species of fish or wildlife. Since 25 percent
of the private land has already been developed, and 80 to 90
percent of the remaining lots have been sold, we consider that,
for all practical purposes, the impact on wildlife habitat has
already occurred, and that in view of the size and nature of
the entire study area, this impact is not significant.
Concerning the restriction of 'the movements of wildlife which
was mentioned on page 26 of the Draft EIS, the word "restrict"
is perhaps not a good choice of words. Moose, swan, and geese
ranges are generally not within the areas which will be impacted
either primarily or secondarily due to the project construction.
We would predict then that there would possibly be only minor
alterations on the feeding and migration patterns of these
species and not to a significant degree.
14. Mitigating measures for wind and water erosion problems oc-
curring during construction will be included in the construction
specifications. Considering the topography, soil, and vege-
tation conditions present at the construction sites, this im-
pact should not be significant, and should be easily controlled
by proper construction techniques.
15. Monitoring measures will be included in the operations and
maintenance manual which must be prepared as a condition of
the award of Federal construction grant funds.
16. Refer to previous discussion and to letters of comment from
the Idaho Fish and Game Department and U.S. Forest Service.
17. No adverse impact on animal communities at the sprayfields is
anticipated. Informal contact with the USDA Agricultural Re-
search Service, Kimberly Station, indicates that for the soils
present at the proposed sprayfield sites, soil compaction will
not be a problem. No adverse impact on plant communities is
anticipated.
18. Chapters 3 and 4 do contain discussion of specific impacts
which are identified as such. Mitigative measures are also
covered, including the following: construction techniques
to control erosion and turbidity; phase construction so that
the effects of spray disposal on lodgepole pine can be evaluated;
development of regulations to control off-the-road vehicles;
requirements for the replacement of vegetative cover to control
wind and water erosion; landscaping for aesthetic purposes;
control of nozzle size to prevent transmission of pathogens
through aerosols; use of aeration to prevent ice buildup and
odors from lagoons; conditioning of the grant award for design
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84
and construction upon the development of suitable land use
controls; and location of separate facilities for each sub-
area 1n lieu of a single regional plant with long connecting
interceptors, to limit development.
19. We disagree. This is more properly part of an operations and
maintenance manual, preparation of which is a condition of
award of Federal grant funds for construction.
20. We disagree. We judge the assessment to be adequate. See
previous discussion.
21. The use of the word sterile perhaps is not a good word choice.
However, significant deterioration of water quality and aquatic
species affecting recreation use has already been observed.
22. This comment is not clearly understood. Little or no impact
on the population of nesting sandhill cranes, moose, or water-
fowl on the Henry's Lake flats is expected. Most of the land
is privately controlled and not available for hunting or ad-
ditional road development.
23. See previous discussion. The project may actually have a
beneficial secondary impact on wildlife habitat by reason
of it concentrating development in presently developing sites,
rather than permitting sprawl type development likely with
no project.
24. We disagree that additional alternative sites should have
been selected for evaluation. We would appreciate learning
of the systematic means of appraisal based on specific criteria
which you indicate could be used to evaluate possible primary
and secondary impacts to endangered and threatened species,
other fish and wildlife, and the respective habitats for each
site.
25. The Island Park Village Golf Course is presently being given
serious consideration as a site for effluent disposal.
26. The purchase of 50 acres of treatment and sprayfield site in
this area would cost approximately $300,000 to $400,000 and
would render this alternative financially infeasible. See
our comment no. 6 to the League of Women Voters letter.
-------
Advisory Council
On I lisloric Preservation
152? K Street N.W.
Wa'.hinatrn, D.C. 20005
November 17, 1975
Mr. Richard R. Thiel, Chief
Environmental Impact Section, M/S 443 RFPFIVFD
Environmental Protection Agency
1200 Sixth Avenue Mnw 04
Seattle, Washington 98101 U¥
Dear Mr. Thiel:
This is in response to your request of September 22, 1975, for comments
on the draft environmental statement for North Fremont County, Island
Park Area, Wastewater Facilities, Idaho. 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 while
you have mentioned the historical, architectural, and archeological aspects
related to the undertaking, the Advisory Council needs additional informa-
tion to adequately evaluate the effects on these cultural resources. Please
furnish additional data indicating:
I. Compliance with Section 106 of the National Historic Preservation
Act of 1966 (16 U.S.C. 470[f]). The Council must have evidence
that the most recent listing of the National Register of Historic
Places has been consulted (see Federal Register, February 4, 1975
and monthly supplements each first Tuesday thereafter) and that
either of the following conditions is satisfied:
A. If no National Register property is affected by the project,
a section detailing this determination must appear in the
environmental statement.
B. If a National Register property is affected by the project,
the environmental statement must contain an account of steps
taken in compliance with Section 106 and a comprehensive
discussion of the contemplated effects on the National
Register property. (36 C.F.R. Part 800 details compliance
procedures. )
'II: ( ,..'u!L c r: '/.',.'/ V of '.' • L< ./,.'/. I . . ,',.,',,.'OM/,•/,; /,/..'
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86
Page 2
Environmental Protection Agency
North Fremont County, Island Park Area, Wastewater Facilities
II. Compliance with Executive Order 11593, "Protection and
Enhancement of the Cultural Environment" of May 13, 1971.
A. Under Section 2(a) of the Executive Order, Federal agencies
are required to locate, inventory, and nominate eligible
historic, architectural and archeological properties under
their control or jurisdiction to the National Register of
Historic Places. The results of this survey should be
included in the environmental statement as evidence of
compliance with Section 2(a).
B. Until the inventory required by Section 2(a) is
complete, Federal agencies are required by Section
2(b) of the Order to submit proposals for the transfer,
sale, demolition, or substantial alteration of
federally owned properties eligible for inclusion in
the National Register to the Council for review and
comment. Federal agencies must continue to comply
with Section 2(b) review requirements even after the
initial inventory is complete, when they obtain
jurisdiction or control over additional properties
which are eligible for inclusion in the National Register
or when properties under their jurisdiction or control
are found to be eligible for inclusion in the National
Register subsequent to the initial inventory.
The environmental statement should contain a determination
as to whether or not the proposed undertaking will result
in the transfer, sale, demolition or substantial alteration
of eligible National Register properties under Federal
jurisdiction. If such is the case, the nature of the
effect should be clearly indicated as well as an account of
the steps taken in compliance with Section 2(b). (36 C.F.R.
Part 800 details compliance procedures.)
C. Under Section 1(3), Federal agencies are required to
establish procedures regarding the preservation and
enhancement of non-federally owned historic, architectural,
and archeological properties in the execution of their
plans and programs.
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87
Page 3
Environmental Protection Agency
North Fremont County, Island Park Area, Wastewater Facilities
The environmental statement should contain a determination
as to whether or not, pursuant to the Advisory Council's
"Procedures for the Protection of Historic and Cultural
Properties" (36 C.F.R. Part 800), the proposed undertaking
will contribute to the preservation and enhancement of non-
federally owned districts, sites, buildings, structures and
objects of historical, architectural or archeological
significance.
III. Contact with the State Historic Preservation Officer.
The procedures for compliance with Section 106 of the National
Historic Preservation Act of 1966 and the Executive Order 11593
require the Federal agency to consult with the appropriate State
Historic Preservation Officer. The State Historic Preservation
Officer for Idaho is Dr. Merle W. Wells, Director, Idaho
Historical Society, 610 North Julia Davis Drive, Boise, Idaho
83706.
Should you have any questions or require any additional assistance, please
contact Brit Allan Storey of the Advisory Council staff at P. 0. Box 25085,
Denver, Colorado 80225, telephone number (303) 234-4946.
Sincerely yours,
Louis S. Wall
Assistant Director, Office
of Review and Compliance
cc :
Sheldon Meyers-EPA:FLO
-------
Response to Advisory Council on Historic Preservation Letter
See response to Idaho State Historical Society letter.
-------
89
A)
^
s&t
-------
-------
/ Q/
^Z^i_-£-X-^ —-p2>t-^> m^S
-------
92
Response to W. H. Shiflett letter
See responses to Rex Moore and Richard G. Hackworth letters,
-------
APPENDIX A
FINAL REPORT
OF ARCHAEOLOGICAL SURVEY OF ISLAND PARK AREA
WASTEWATER FACILITIES
EPA PROJECT NO. C-160186-01
By: B. Robert Butler
Acting Chairman and Associate Professor
Department of Anthropology
and
Curator of Archaeology, Museum
Idaho State University
Pocatello, Idaho
December 23, 1975
-------
A-l
His tor i c and Archaco]ogle Values
The immediate vicinity of Henry's Lake and the Henry's Fork of the
Snake downstream from there past Last Chance form "Island Park", an area
which figures prominently in the history and prehistory of northern Fremont
County. No buildings, places or archaeological sites in this area are lis-
ted on the National Historic Sites Register, for the area has not been sys-
tematically studied. There is, however, a locally published history of the
area (Idaho's Gateway to Yellowstone, The Island Park Story: A Pictorial
Presentation by James L. Allison and Dean H. Green, Island Park Gateway
Publishing Co., Mack's Inn, Idaho, 1974) and an archaeological field team
under the direction of Professor B. Robert Butler, Idaho State University,
has been inventorying cultural resources on BLM lands in the area. Cul-
tural resources include structures, objects, sites and districts which have
archaeological, historical or architectural significance. Such resources
are limited and non-renewable and, therefore, require protection and pres-
ervation.
The cultural resource inventory work carried out on BLM lands in this
area by Professor Butler in 1975 yielded a substantial quantity of archae-
ological materials around Henry's Lake, some of which indicated human occu-
pance of the lake shore at least as early as 10,000-10,500 years ago and at
various times since. The inventory did not cover any of the lands involved
in the proposed Island Park Area Wastewater Facilities. Because no such
inventory had been made of the lands involved, the Seattle Office of the
U. S. Environmental Protection Agency (Region X) requested Professor Butler
to carry out such an inventory towards the end of November, 1975, even though
snow already blanketed the region.
-------
A-2
Working on touring skis, in a two-man team, the Henry's Lake, Mack's
Inn-Island Park Lodge, and Last Chance-Pond's Lodge subareas were completely
surveyed. At the times of the survey, November 28, December 6 and December
13, the I. P. Bills Island-Yale Creek subarea was inaccessible, at least
for the survey team. The purpose of conducting the survey in spite of the
snow cover was two-fold. First, the snow cover would not be gone before
May at the earliest. To delay the survey work until then would cause a ser-
ious delay in completing plans for the wastewater project. Second, based
on his previous experience in the area, Professor Butler believed that he
could identify the locations which had the highest probability of yielding
cultural materials on the basis of local landform and vegetation, both ap-
parent in spite of the snow cover. In each subarea examined, the entire
length of the project shown on the map provided and outlined in yellow by
the Seattle Office of the EPA was followed and places which should be test-
excavated for prehistoric cultural materials noted. The latter are as fol-
lows :
Henry's Lake Subarea--Local informants with whom Professor Butler visited
in the autumn of 1974 showed him archaeological materials collected from
the perimeter of the lake, some of which were in the age range of 10,000-
10,500 years. He also collected materials from the lake shore, mainly along
the south and west sides of the lake, and was told of similar materials col-
lected along the northeast shore of the lake at low water. Henry's Lake
Flat on the east side of the lake figured prominently in historic events
that transpired here. Because of these abundant indications, a minimum of
four test pits, each measuring 1 x 2 x 1.5 meters, is recommended. Because
the interceptor system runs so close to presently developed facilities (roads,
etc.), these pits should be excavated in undisturbed deposits. In the event
-------
A-3
that buried prehistoric cultural materials are encountered, provisions
should be made Cor expanding the test excavations and recovering all of
the material that would be adversely impacted by the project. These pro-
visions should apply both to the test excavations and to subsequent inter-
ceptor line and disposal site excavation.
Mack's Inn-Is land Park Subarea--For the most part, the proposed interceptor
system and siposal sites are located in a heavily forested area. The inter-
ceptor line, however, dissects an older terrace of the Henry's Fork in the
extreme northwest corner of Section 31. Such terraces have yielded ancient
cultural materials. Therefore, a test excavation measuring 1x3x1 meter
is recommended at this juncture, with provisions made as above.
I. P. Bill's Is land-Yale Creek Subarea--While surveying private property
along the southern shore of the Island Park Reservoir in 1966, Professor
Butler observed extensive prehistoric cultural materials eroding out of
the wave cut banks of the reservoir. Therefore, archaeological potential
of this subarea appears relatively high and a minimum of three 1x3x1
meter test pits are recommended with the same added provisions as at Henry's
Lake.
The La s t Chance-Pond's Lodge Subarea--The major part of the interceptor
system and disposal site is in a heavily wooded area well away from rivers
and streams. However, part of the interceptor system lies close to the
Buffalo River in Sections 27 and 28 and another part lies close to the
Henry's Fork in Section 17. While surveying the Railroad Ranch in 1966,
Professor Butler noted prehistoric cultural materials along both sides of
Henry's Fork immediately downstream from Last Chance. There appears to be
a good chance that similar cultural materials occur along the river in the
-------
A-4
vicinity of Last Chance and possibly also along the Buffalo River below
Pond's Lodge. Therefore, a minimum of four 1x3x1 meter test pits are
recommended along these parts of the proposed interceptor lines, again with
the same provisions outlined for the Henry's Lake interceptor system.
The test excavations proposed above could not be carried out until
snow had left and the area was relatively dry. In the meanwhile, however,
the interceptor systems could be staked out and work begun of the disposal
sites without posing serious threat to cultural resources. In fact, excav-
ation of the interceptor trenches could be carried out on all projects ex-
cept Henry's Lake, provided that where prehistoric cultural materials were
encountered, the immediate stretch of trench would be left open for excav-
ation by an archaeological crew. Work on the Henry's Lake project could
progress to the excavation stage prior to archaeological testing, but such
testing should almost certainly precede any excavation here. Henry's Lake
has the highest potential among the four subareas in question for prehis-
toric cultural materials.
-------
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-------
B-l
BIBLIOGRAPHY
Fremont County "Application for Federal Assistance", (EPA Form 5700-12
(4-72)), June 6, 1974.
State of Idaho, Department of Environmental and Community Services,
Rules and Regulations for the Establishment of Standards of
Water Quality and for Wastewater Treatment Requirements for
Waters of the State of Idaho, 1973.
Environmental Protection Agency (EPA),"Water quality profile of
Henry's Lake to mouth of Henry's Fork, Island Park Study",
Region X, Seattle, Washington, 1973.
Environmental Protection Agency (EPA) "Construction Grants for
Wastewater Treatment Works", Federal Register, Volume 39,
Number 29, Part III. 40 CFR Part 35, February 11, 1974.
Environmental Protection Agency (EPA), Manual for Preparation of
Environmental Impact Statement for Wastewater Treatment Works,
Facilities Plans, and 208 Areawide Waste Treatment Management
Plans, Office of Federal Activities, 1974.
Fremont County Planning Commission, Fremont County Comprehensive
Sewer and Water Plan, November, 1971.
Environmental Protection Agency (EPA), Final Regulations, "Prepara-
tion of Environmental Impact Statements", 40 CFR Part 6,
April 14, 1975.
National Environmental Policy Act of 1969 (NEPA), P.L. 91-190.
Council on Environmental Quality (CEQ), 'Guidelines for Preparation
of Environmental Impact Statements", 40 CFR Part 1500, August 1,
1973.
Federal Water Pollution Control Act, As Amended, P.L. 92-500.
"Carrying Capacity: Maintaining Outdoor Recreation Quality",
seminar paper by D. Lime and G. Stankey, USFS, 1971.
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