EVA •
 FINAL ENVffiONMENTAl IM
          STATEMENT
       EAGLE VALLEY AN
 WASTEWATER FACILITIES
          10BEE  1977
               YAH
               IAN
U. 3. Environmental iTctection Agency
       Region VIII
      Denver, Colorad
                         o

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                 FINAL  ENVIRONMENTAL  IMPACT  STATEMENT
            UPPER  EAGLE AND  VAIL  WASTEWATER  FACILITIES  PLAN
                              Prepared by
                 U.S. Environmental Protection Agency
                    Region VIII - Denver, Colorado
                              Approved by
Alan Merson
Regional Administrator
                                             October. 1977

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                                           (—Upper  Eagle  Valley Sanitation  District
Vail Water & Sanitation  District




Redcliff Water & Sanitation District





Upper Eagle Valley Sanitation District

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                             SUMMARY SHEET
                    Environmental  Impact Statement
                                   for
                      Upper Eagle  Valley and Vail
                      Wastewater Facilities Plan


      (   ) Draft                    (x)  Final


1.  Name of Action:   (x) Administrative     ( ) Legislative

2.  Description of Action:

    The Upper Eagle Valley Sanitation District and Vail Water and Sanita-
tion  District have proposed the expansion and improvement of their res-
pective wastewater facilities located at Avon and Vail, Colorado.  Under
these proposals the treatment plant at Avon would be expanded from a
capacity of 1.65 million gallons per day (MGD) to 3.5 MGD to meet the
projected 1985 flows, and treatment efficiency improved to meet stream
standards for the Upper Eagle River.  The treatment plant at Vail would
be expanded, under the District's  proposal, from 1.5 MGD to 3.0 MGD
to meet projected 1995 flows with  treatment improved to meet stream
standards for Gore Creek.

    The treatment capacities proposed by the two Districts are based
on a  per capita water use rate of  150 gallons per day.  EPA believes
this  figure to be excessive for this area and will fund capacity to
treat waste water from the projected population at a rate of 135 gallons
per capita per day.  This reduces  the plant capacities to 2.7 MGD for Vail
and 3.1 MGD for Avon.  EPA will  provide Step II design funds for the pro-
posed treatment facilities a,t these reduced capacities.

    The availability of Step III funds for construction of the improvements
and expansions (at reduced size) of these wastewater treatment facilities
will  be made available when the following conditions are met.

     1)  The Districts require the metering of all water service for the
         purpose of pricing to encourage water conservation and the
         installation of water conserving appliances and devices in
         all buildings, prior to providing any new service in the form
         of collection or treatment to any portion of the Districts'
         service areas.

     2)  The Districts require the enactment of an effective and enforce-
         able particulate control  ordinance by the Town of Vail, prior to
         providing any new service in the form of collection or treatment
         to areas within the Town of Vail.

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3.  Environmental Impacts:

    Secondary impacts of the proposed action will be the result of popula-
tion growth, land use conversion, and consequent resource utilization.
The average daily (winter) population within the study area is pro-
jected to Increase nearly three fold from a 1975 population of 16,000
to a 1995 population of 47,560.  Most of this population growth (23,850)
is projected to occur in the Upper Eagle Valley area.  By contrast, the
average daily population of Vail is projected to increase by 7,980 by 1995.
The Avon facility will support the developments of Arrowhead, Beaver Creek,
Benchmark, Eagle Vail, and West Vail along with development in Avon and
Minturn.  The Vail wastewater treatment plant will provide capacity for con-
tinued development of Vail and the Bighorn area (see preceding map).  Con-
sequently, the sizing and location of the treatment plants may have some
influence on the location of growth, but, this effect is substantially
reduced by the interconnection of the plants and by other overriding influ-
ences, including topography, land ownership, local zoning, state and federal
approvals.  It is not believed that the EPA action of providing federal
grant funds for design and construction of these facilities will in itself
promote development.  Several alternatives exist to federal funding of
these facilities which would allow for continued development, although
possibly at a slower pace.  The secondary impacts on environmental and
human resources which will result from population growth in the area include:

     1)  degraded air quality

     2)  increased nonpoint source pollution from construction and
         urban runoff

     3)  depleted stream flows

     4)  reduced scenic values

     5)  increased demand on many urban services and potential  shortages

     6)  loss of wilderness and wildlife habitat

     7)  greater demand on recreation facilities.

     8)  different employment opportunities benefiting some but not all.

Mitigative measures are proposed as part of the EPA action to reduce air
quality, nonpoint source pollution and stream flow impacts.

     Construction impacts of the proposed action include minor distur-
bance and/or destruction of vegetation and wildlife.   There will  be some

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erosion and sedimentation.  Unavoidable adverse  impacts will  be  the
temporary loss of terrestrial and aquatic habitat  along the  interceptor
replacement route and permanent removal of  vegetation on  land to be
used for plant expansion.  No impact to archeological or  historical
sites are anticipated.

4.  Alternatives Evaluated

    The alternatives to the proposed action which  were evaluated are:

    Alt. 1 - Upgrade Vail plant (same capacity)

           - Construct new Dowds Junction plant  at 2.6 MGD for
             1995 flows.

           - Upgrade and expand Avon plant  to 2.5  MGD for 1985 flows
             and later expand plant to 4.7 MGD for 1995 flows.

    Alt. 2 - Abandon Vail Plant

           - Construct new Dowds Plant at 4.1 MGD  for 1995 flows

           - Upgrade and later expand Avon Plant to 2.5 MGD for  1985 flows and
             expand Plant to 4.7 MGD for 1995 flows.

    Alt. 3 - (Districts' Recommended Alternative)

           - Upgrade and expand Avon Plant to 3.5  MGD for 1985 flows
             and later expand Plant to 5.8 MGD or_  construct new  2.3
             MGD plant downstream at Squaw Creek.

    Alt. 4 - Assumes no Vail participation

           - Upgrade and expand Avon Plant to 3.5  MGD for 1985 flows
             and later expand plant to 5.8 MGD or_  construct new  2.3 MGD plant
             downstream at Squaw Creek.

    Alt. 5 - No Project (No federal  funding is considered under  institutional
             and financial  conditions.)

5.  Distribution:

    (See list at end of this document).

6.  Final  Statement Sent to Council  on Environmental Quality:


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INTRODUCTION

     The purpose of this Final Environmental  Impact  Statement  (EIS)
is to present the decisions of EPA and  resulting environmental  impacts
of providing federal grant funds for expansion and improvement  of
wastewater treatment facilities in the  Upper  Eagle Valley and Vail
area of Colorado.  The Upper Eagle Valley Sanitation District and
Vail Water and Sanitation District have received a federal grant for
developing plans to examine various alternative solutions to the
collection and treatment of waste water generated in the area.  A
draft EIS was issued by EPA in April of 1977  which addressed these
alternatives, including the Districts recommended plan, and their
environmental impacts.  Subsequently, on May  26, 1977, EPA held a public
hearing on this draft EIS in Vail Municipal Building.  The Upper Eagle
Valley Sanitation District also held a  public meeting on the District's
recommended action on April 20, 1977.   All written comments received by
EPA on the draft EIS are included in this document along with EPA's
response.  In making decisions on this  action, EPA has reviewed and
evaluated the Districts recommendations, the  impacts discussed  in
the draft EIS and all comments received on the draft EIS.

EIS FORMAT

     This Final EIS does not use the standard EIS format normally used
by Federal Agencies.  The reason for using this modified format is
to highlight and bring to the reader's  attention what EPA believes to
be the most important aspects of this action while allowing a com-
plete review if desired.  This Final EIS is broken into two documents.
This document, being the smaller of the two, attempts to summarize
EPA's decisions so that previous reviewers and commentors may quickly
determine the results of this EIS and wastewater facilities planning
process.  The second document entitled  "Attachment to Final EIS" is a
revision of the draft EIS in accordance with comments that EPA  has
received on the draft.  The following portions of this document will
address EPA's proposed action, the more significant  issues, mitiga-
tion measures which will be incorporated in the action, comment
letters on the draft EIS and EPA's responses, and finally, pertinent
enclosures.  The "Attachment to the Final EIS" follows the more con-
ventional EIS format.  For more detailed information, the reader is referred
to this second and larger document.  The responses to comments  also
expands on the discussion of issues and mitigations which follow the des-
cription of the proposed action.

PROPOSED ACTION

     The Upper Eagle Valley Sanitation  District and Vail Water  and
Sanitation District have proposed to EPA the expansion and improvement
of their respective wastewater treatment facilities along with  some

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needed  replacement of  interceptor sewer for this expanded capacity.
In  recommending a plan to EPA for further funding of design and  con-
struction, the Districts evaluated, in some detail, four alternatives
These alternatives along with the no-project and no-federal funding
alternatives are explained  in the Attachment and also in the Facilities
Plan submitted to EPA and the State by the Districts earlier this year.
The Districts recommended a plan for expansion and upgrading their
existing facilities which is labeled 3a, b.  In recommending this
alternative, the option was left open on whether to expand, at some later
date (possibly 1985), the Upper Eagle facility located at Avon (3a) or
to  build a new plant downstream (3b) when this proposed expansion of the Avon
facility would be at capacity.  EPA will not make a decision on  this aspect
of  the  project at this time and will require a new facilities plan and
environmental assessment, possibly an EIS, prior to considering  this future
action.

     Other aspects of the recommended plan include the upgrading of
wastewater treatment efficiency and effluent discharge to meet stream
standards, including those only presently proposed by the State  for
unionized ammonia and residual clorine (both being toxic to fish at
certain concentrations).  This improved treatment will Include ammonia
removal, filtration, declorination or ozonlzation and special sludge hand-
ling along with the more conventional treatment processes.  The  recom-
mended  plan calls for improvement of the existing facilities at  Vail and
Avon with upstream areas being served by each facility with the  ability to
transport wastewater downstream to Avon under emergency or overload condi-
tions.  Sludge from the Vail facility would be transported via the same
connecting Interceptor line to Avon for dewatering and handling  there.
EPA approves of this recommended treatment process but will review the
predesign engineering work on the ammonia removal process, disinfection
process and sludge handling to insure these processes are workable prior to
funding construction of the project.

     The Districts recommended plan calls for expansion of the Upper
Eagle facility to 3.5 million gallons per day (MGD) from its present
capacity of 1.65 MGD to handle flows from the projected 1985 popula-
tion.  At Vail the proposed expansion 1s from the existing 1.5 MGD
to 3.0 MGD for the projected 1995 population.  These capacities  are
based upon an estimated per capita flow rate of 150 gallons per  day.
EPA believes this per capita flow rate to be excessive given informa-
tion presented in the 201 Facilities Plan and data on water usage in
other similar areas.  (See coiments from North West Colorado Council
of Governments and EPA's responses on water conservation issue).  There-
fore, EPA will fund the facilities design and construction only  for 135
gallons per capita per day, which reduces the proposed plant expansions
to 3.1  MGD for Upper Eagle (Avon) and 2.7 MGD for Vail.  This figure
of 135 gallons was derived using information in the 201 Facilities Plan
which indicated that a possible range in per capita wastewater genera-
tion of 125 to 150 gallons per day exists in Vail during the winter ski
season.   Use of 135 gallons per capita per day is a reasonable midvalue
which,  if low, will  not require unreasonable water conservation efforts
to achieve and,  if high, will  not result in excessive treatment capacity.

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     The expansion of capacity  to  handle wastewater  will  also  require
the replacement of certain  segments of  sewer  interceptor  lines where
existing pipe size and  slope would be restrictive.   The Districts'
proposed plan estimated the need to replace 5.25  miles of interceptor
sewer.  Exact sewer  replacement needs will be  determined  after com-
pletion of  survey work  under the predesign effort.   A per capita waste
flow figure of 135 gallons  per  capita per day  will be used to  determine
the need to replace  sewer lines.   It 1s not expected that use  of this
figure rather than the  150  gallons will result in significant  changes
in the plan regarding sewer replacement.  Since sewer replacement may
temporarily impact water quality,  aquatic life and wildlife, coordina-
tion by the District with the Colorado Division of Wildlife to mini-
mize such impacts will  be required as part of  the grant.   Also, the
Districts' will be required to  stop work on any portion of the con-
struction and contact the State Historic Preservation Officer,  if
buried material of potential archaeological value is encountered.

ISSUES

Water Conservation

     Comments on the draft  EIS  concerning the  need for water conserva-
tion and the consideration of such practices in sizing the wastewater
treatment facilities were received by both Eagle  County and the North
West Colorado Council of Governments.  Reasons cited for  the need for
water conservation included; reduced water and wastewater  treatment capa-
city and costs, reduced streamflow depletion thus mitigating adverse
impacts on aquatic life and reduced financial   risk to existing water
users if the projected growth does not occur.

     There  is a limited amount  of  water within the study  area  which is
readily available for the projected peak population  during winter ski
season.  Therefore water conservation must be  practiced to protect stream
values as well as to adequately support population growth.  Significant
streamflow depletion could occur as a result of the  projected  growth in
the area.  Such an impact may be properly mitigated  through the use of
water conserving applicances and devices, water use metering with a rate
scale to discourage overuse of  water, and developing new  more  sophis-
ticated water supply systems possibly including upstream  discharge or
shallow ground water injection  of  sewage effluent during  winter months.

     Since the peak population  within the study area is principally
transient skiers and visitors,  pricing Incentives to encourage water con-
servation may not be as effective as 1n areas   with a large permanent
population.   Generally, visitors do not recognize the costs associated
with water use and therefore higher prices may not be attributed to the
cost of water.  However, pricing may be effective in promoting property
owners and managers to encourage water conservation  by tenants through

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 education and encouraging proper use of water conserving appliances and
 devices.  Education of the tourist to the problem and costs of misusing
 water may be a more important component of an overall water conservation
 program than in other, more typical, urban areas.

      Presently, water metering is required by both the Upper Eagle Valley
 Sanitation District and the Vail Water and Sanitation District for all
 new taps.  However, a significant percentage of the existing dwellings
 do not presently have meters.  It is expected that all existing unmetered
 uses will also be forced to meter water use in the near future.

      Use of water-saving devices, appliances, and plumbing fixtures, such
 as fine spray shower heads, low flush toilets, washers with suds savers,
 and flow restrictors may be very effective in reducing water use in the
 Vail and Avon area.  Using results from previous studies,  EPA has esti-
 mated that laws and ordinances requiring installation of water saving
 plumbing fixtures and appliances in new dwellings could reduce wastewater
 flows from new developments by 30 to 35 percent.  Retrofit of water devices
 such as toilet dams and fine spray showerheads could reduce community
 wastewater flows by 15 to 20 percent.   However, these estimates are pre-
 liminary since experience is limited and may also be different for a ski
 resort community where the incentive to conserve water may be limited.

      Presently,  the Upper Eagle Valley Sanitation District is adopting
 regulations  requiring water-saving shower fixtures and toilet facilities.
 Eagle County and the Town of Vail  also are considering the adoption of
 such regulations for new structures.

 Nonpoint Pollution  Control

      The draft EIS  along with preliminary results of the North West Colorado
 208  Water Quality Management Plan  indicate the general significance of
 nonpoint pollution  in  the area.   The projected development, unless care-
 fully controlled to mitigate nonpoint  pollution sources, will add to the
 existing problem.   Generally,  the  control  of nonpoint pollution (urban
 runoff,  erosion  from construction,  etc.)  is not evaluated in the develop-
 ment  of  a  201  facilities  plan.   However,  the importance of nonpoint sources
 can not  be ignored  in  selecting  solutions to wastewater treatment as both
 are  integral  parts  of  a  water quality  management plan.  Since high levels
 of wastewater  treatment  are  proposed  for the Vail and Avon areas, effec-
 tive  nonpoint  source controls  are  needed 1n order to maintain high stand-
 ards  for water quality in  the  area.  The proposed wastewater facility
 improvements will support  the  continued development of the area by pro-
 viding capacity  for future  populations which in turn will  affect water
 quality through  increased  nonpoint  source pollution.  To date, a nonpoint
 source control plan  has  not  been  developed for any portion of the study
area.

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Air Quality
     The draft EIS recognizes the problem of air pollution  in the Gore
Valley where the Town of Vail is located.  During the winter ski season
of 1976-1977 both State and Federal air quality standards for particulates
were violated.  These violations are largely attributable to use of wood
burning fireplaces in the Valley.  The following particulate concentra-
tions which exceeded State and/or Federal standards were measured during
1977 in the Gore Valley.
Date

 9 Jan 77
21 Jan 77
21 Jan 77
25 Jan 77
22 Mar 77
 7 Apr 77
24-hour
Concentration
_i£ Micrograms

    240
    350
    220
    763
    284
    280
Location

Vail
Vail
West Vail
West Vail
West Vail
Vail
Standard
Violated

State
State & Fed.
State
State & Fed.
State & Fed.
State & Fed.
The State 24-hour standard for particulates has been exceeded in the Gore
Valley since 1973 when monitoring  was begun.  These high particulate
concentrations during the 1977 season represent the first time Federal
standards have been exceeded.

     The draft EIS indicated that without control of fireplace emissions
or burning, violations of State and Federal particulate standards would
continue in the future due to more development.  The draft EIS also indicated
the possibility of exceeding the particulate standard in the Avon area by
1985 unless fireplace use is adequately controled.  The Town of Vail has,
in cooperation with other mountain towns, been developing information to
support a program to control particulate emissions.  However, to date,
there is no law or ordinance enacted to control particulate emissions in
Gore Valley

Reuse of_ Wastewater

     In comments that EPA received from the Colorado Water Quality Control
Commission and the Colorado Open Space Council it is stated that the
draft EIS and facilities plan did not adequately analyze the land treatment or
reuse alternatives.  EPA requires each applicant for construction grant
funds to make a conscientious analysis of wastewater management alterna-
tives with the burden upon the applicant to examine all available alterna-
tive technologies including land treatment and reuse.  The Federal Water
Pollution Control Act Amendments of 1972 encourages the consideration of
wastewater reclamation and recycling by land treatment processes.  President
Carter's recent Environmental Message to the Congress emphasized the design
and construction of cost-effective publicly-owned wastewater treatment
facilities that encourage water conservation as well as adequately treat

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                                  10
wastewater.  Therefore, 1f a method that encourages water conservation,
wastewater reclamation and reuse 1s not recommended, the applicant
should be required to provide complete justification for the rejection of
land treatment and reuse.

     In evaluating this Issue, it is EPA belief that the downstream  land
treatment alternatives were legitimately dismissed during development
of the facilities plan for reasons of cost, environmental impact  and
difficulty of implementation.  Basically, the limited growing  season,
remoteness of suitable land, the possibility of significant stream flow
depletion and water rights conflict, high land costs, limitation  of  suitable
winter storage sites, and the winter limitations on discharge  of  ammonia,
make land treatment neither the most cost effective solution nor  an
environmentally sound alternative.

     However, the reuse of wastewater effluent should be considered  for
use in alleviating future demands on water supplies.  Presently,  limited
benefits can be achieved with summer reuse of wastewater on golf  courses
and other open space lands 1n the vicinity of Vail and Avon.   This situa-
tion occurs principally because winter discharge limitations are  more
restrictive than summer limitations for unionized amonia, suspended  solids,
residual clorine and biochemical oxygen demand.  Also, low flows  which
are subject to serious depletion, occur during the winter.  Therefore,
normal land application systems can not be used, in this climate, to
alleviate winter pollution control requirements nor to benefit winter
stream flows.  It is possible, however, that with the additional  use of
effluent for snow making and shallow ground water Injection, to augment
winter stream flows, reuse might become a realistic alternative to future
development of additional water supplies.  The proposed treatment Improve-
ments are consistent with any future scheme which might reuse  wastewater
effluent for several purposes during both the summer and winter months.
See discussion of mitigations regarding this issue.

Construction Impacts

     Certain comments received on the draft EIS from U.S. Forest  Service,
Colorado Division of Wildlife, U.S. Department of the Interior, State
Historical Society of Colorado and Federal Highway Administration addressed
the direct, construction impacts of the proposal.  These potential con-
struction impacts are addressed in EPA's responses to comments.  They
include impacts on archaeologic and historical resources, aquatic and
wildlife habitat impacts from construction near and through streams, dis-
ruption of recreational sites and opportunities, and conflicts with  high-
way transportation facilities.  EPA will require that such potential impacts
be mitigated to minimize the effects of construction.  See discussion
under mitigation measures.

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MITIGATION MEASURES

Water Conservation

     EPA will  require  prior  to  providing  grants  funds  for  construction  of
the proposed project,  the  implementation  of  a water  conservation  pro-
gram within the  201  project  area.  This water conservation program  will
require the metering of all  water  service for the  purpose  of  pricing to
encourage water  conservation and the  installation  of water conserving
appliances and devices  in  all structures.  As a  condition  to  receiving
federal funds  for construction  of  the proposed wastewater  treatment im-
provements, the  Districts' must require the  enactment  of such a water con-
servation program prior to providing  additional  service.   Presently,
water metering is required by both the Upper Eagle Valley  and Vail  sanita-
tion districts for all new taps.  The use of water saving  fixtures  is
under consideration  by Eagle County,  Vail  and the  Upper Eagle Valley Sanita-
tion District  for new  structures.

     In taking the action  to reduce the capacities of  the  proposed  waste-
water treatment  plants, EPA  believes  that water  conservation  should be
encouraged in  the area.  A successful  water  conservation program  may
easily reduce  wastewater generation below the estimated per capita  flow
rate of 135 gallons  per day.  If so,  the  effective service life of  the
facilities would be  extended, making  the  present investment good  for a
longer period  of time.  This potential benefit should  be a significant
contributor to the efforts already underway  in the area to promote  water
conservation.

Nonpoint Pollution Control

     As a condition  to the approval of the facilities  plan, EPA will
require the two Districts  to actively participate  in a nonpoint source
pollution control program, to be funded by EPA,  and  to pursue, within
their jurisdictional authorities, the implementation of the plan  recom-
mendations.  A joint agreement  to participate in the program  and  to pursue
implementation on nonpoint source controls has been  signed between  EPA
and Town of Vail, Town of Minturn, Northwest Colorado  Council of  Govern-
ments, Vail Water and Sanitation District, Upper Eagle Valley Sanita-
tion District  and the State of  Colorado.   Such an  agreement has also been
requested of Eagle County, but  has not yet been  received by EPA,  although
we understand  that it has  been  signed.  The  joint  agreements  so far signed
and received by EPA  are included in this  document  as Enclosure 1.   The
joint agreement which has  been  modified and  signed by  Upper Eagle is not
acceptable to  EPA and will have to be further negotiated in order to approve
the 201  facilities plan.   EPA does not intend to use the results  of the
nonpoint source pollution control program to hold  up funds or to  modify the
proposed action being considered at this  time.   However, the  use  and-need
for future federal funds for water quality improvements in this area
beyond this 201 planning, design and  construction  process, may be affected
by the results of this nonpoint control plan.

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Air Quality
     EPA will require  prior  to  providing grant funds for construction of
the proposed project the  implementation of a particulate air pollution
control ordinance by the  Town of Vail.   This particulate control ordinance
must be effective in addressing fireplace emissions and enforceable by
the Town.  As a condition to receiving  federal  funds for construction
of the proposed wastewater facility Improvements, the Districts must
require the enactment  of  this air pollution ordinance prior to providing
any new service to  the Town  of  Vail.

Reuse of_ Uastewater

     As a  condition to approval  of the  facilities plan, EPA will require
the sanitation districts  to  fund a study of wastewater resue in conjunc-
tion with  the on-going comprehensive  water study for the area.  We believe
this to be an appropriate approach in that there appears to be no obvious
water quality benefits or cost  savings  from reuse of effluent on golf
courses or other open  space  lands at  this time.   Therefore, our approach
for this project will  be  to  require study of these options, in the belief
that economics may  be  favorable in the  future as water demands and costs
increase.  See comments from the Colorado Open Space Council and the
Colorado Department of Health on wastewater reuse and EPA's responses.

Construction  Impacts

     1.  Archaeological and  Historical  Resources - EPA will require the
districts  to  minimize  any direct impact to archaeological  or historical
resources  which might  result from construction operations.  The follow-
 ing procedures will be required of the  sanitation districts in a special
condition  to  their  grant.

          "In  the event that  subsurface  materials, possibly con-
          stituting  an  historical or archaeologic find, are un-
          covered during construction, the following procedures will
          be  adhered to by the contractor.

              1)  Construction shall be  halted with as little dis-
              ruption  to the  archaeological  or historical  site as
              possible.

              2)  A  representative of  the Sanitation District shall
              notify the State Historic  Preservation Officer and EPA
              of the find  and ask for  guidance.

              3)  The  State Historic Preservation Officer may decide to
              have   an  archaeologist inspect the  site, and make recommenda-
              tions  about  steps  needed to protect the site, before
              construction in the area is resumed.

              4)  The  entire  event shall be handled as quickly as possible
              in order  to  hold the loss  in construction time to a mini-
              mum while still protecting archaeological  or historical  finds.1

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                                   13
     2.  Aquatic and Wildlife Habitat Impacts - The districts will be
required, as a special condition to their grant, to coordinate construc-
tion activities with the Colorado Division of Wildlife with respect to
minimizing impacts to terrestrial and aquatic habitats.  Potential miti-
gations to reduce adverse impacts to trout, deer etc., are listed on
pages 143 through 146 of the Attachment of the Final EIS.

     3.  Recreational Impacts - As a special condition to the districts'
grant, they will be required to coordinate construction activities with
the Towns of Minturn and Vail and Eagle County to minimize the disruption
of recreational activities in the area.  Mitigations may include limiting
construction to certain times of year, limiting duration of open trench-
ing and setting time requirements for restoration of land to previously
existing conditions.

     4.  Highway Conflicts - A special condition to the districts' grant
will require coordination with State, County and Towns to safely convey
and minimize traffic conflicts with sewer line construction areas in
the vicinity of any highways and local roads.  Such mitigations may include
barricading, lighting, use of hazard and directional signs and seasons
when construction can be done.

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                     COMMENT LETTERS AND RESPONSES
The following letters are all of the written comments  that  EPA  received
on the draft EIS.  Each response by EPA  follows  the  comment letter  and
is keyed to the letter by the numbers along the  left margin.  All those
that testified at the public hearing also  submitted  written comments
and so the hearing testimony is not included in  this document,  but  is
available for review at EPA offices in Denver.

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                                    16


UNITED STATES DEPARTMENT OF AGRICULTURE

SOIL CONSERVATION SERVICE	

 P.  0. Box 17107,  Denver,  Colorado 80217



                                                       May  17,  1977
                                        \.
                                              7O
Mr. John A. Green                       -     •••••-c.';.'Tu31_
Regional Administrator
U. S. Environmental  Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
Dear Mr. Green:
We have reviewed the Draft Environmental Impact Statement for the Upper
Eagle and Vail Wastewater Facilities Plan.

We feel the draft EIS is well  written and adequately covers the items in
which the Soil Conservation Service has expertise.  However, we would like
to call your attention to an error on page  173, last sentence.  Crested
wheatgrass is not an exotic annual species  as described in the last sen-
tence.  It is an introduced perennial and would probably be a suitable
species for revegetation purposes.

We appreciate the opportunity to review and comment on this project.

Sincerely,
 \\
Robert G. Hal stead
State Conservationist

cc:  R. M. Davis, Administrator, SCS, Washington, D.C.
     Office of the Coordinator of Environmental  Quality Activities
         Office of the Secretary, USDA, Washington, D.C.
     Council on Environmental  Quality (5 copies)
                      Cir

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                          17
Response to Soil Conservation Service

1.   Your correction concerning crested wheatgrass has been
    noted and the text changed accordingly.

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                                              18
     EAGLE   COUNTY
                             DEPftiOTUT  OF  PIMIIHB MID  DEVELQPIiEIIT
                               McOmiitld Illilj;.      5f»0 Itriindwiy      I'.O. HOK 17'J     lia(cle. Colorado 8IC31
                                               1 June 1977
      U.S. Environmental Protection Agency
      Region VIII
      Attn: John A. Green,
      Regional Administrator
      Denver, Colorado
  The 201 Facilities Plan of the Upper Eagle Valley Sanitation District has been reviewed
  by the Eagle County Planning Commission and the  Eagle County Planning Department.

  The Plan is readable and appears to be comprehensive in scope.  The financial estimates
  of recommended construction are well documented.   Public involvement has been adequate
  considering strictures of  time.
The following comments and concerns are offered for your consideration before final
implementation of the construction phase.
     1.  There: appears to be very little imagination in addressing the problems
        of effluent treatment and water conservation. Sludge treatment by hauling
        to a distant county dump is simplistic but should not be considered an
   	.  effectivo disposal solution over the short or  long term.

     2.  Water conservation should be addressed as a positive program  to alleviate effluent
        generation. Public awareness of the need for conservation should be considered
   	  as an ongoing public relations project of the District.
 ©
3
©
 4
s-^
 5
      3.  Serious inadequacies in effluent discharges into the Eagle River and Gore Creek
          should be emphasised.  Dace data should reflect current problems during periods
     	.   of low  stream flow and peak discharges and possible administrative  solutions.
     4.  Lessened stream flow where upr.tream diversions come on lino need to bo
        considered especially in water quality projections.
      5.  Conr.ol iclotion of water and sanitation districts should be considered in depth
          to icduco costly duplication and divergent planning.

          Non point generation of pollulr.inlr. should bo considered and possibly included
          In the plan as a part of the district projections of potential  effluent sources.
©
    7.  Limitation of clrnr.ilior. within Ihc r.ervico orca tihould bo considered as a
        r.hort torm evolution of diI'.charge problems.
        I'l.iiiniiii: l>r|i.ii Iniriil.Tl.iMmiii; ('iiiiiiiip.-.inii: Nnliiliv I'MIHI, lie, iiiiiii);, A|>|>li mills ,uul Iii'.|irclion, X.uitilii; Ailiniiii'.ll,ilinii (.'Hl.'l' """''•'"'

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                                       19
 ,   0.  Costing of current treatment may huvc on economic impact on Minium
        residents.
Endorsement of this 201 Facilities Plan in no way sets land use patterns.  In general,
assumptions presented by the plan ore consistent with counly projections, however,
each xoning and subdivision decision must be based on  its' individual merits and the
Counly Master Plan.

We would appreciate comments and suggestions as to how County Planning can assist
in solving your problems.
    .
Donald Price
Chairman,
Eagle County Planning Commission
DP/kp

fee:  Board of Counly Commissioners

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                           20
Response to Eagle County Department  of Planning and
  Development

1.  Regarding effluent treatment,  many treatment processes
    were considered and evaluated  in the course of the plan
    development.  Since advanced treatment must be provided
    at both plants, the proposed processes will significantly
    reduce the wastes presently being discharged to Gore
    Creek and the Eagle River.  This advanced treatment will
    be achieved by adding  the necessary treatment units to
    the already operating  facilities,  including the addition
    of nitrofication, filtration and dechlorination or
    ozonization.  EPA considers these improvements to have
    significant water quality benefits and to be cost ef-
    fective, given the existing facilities.

    Regarding water conservation,  EPA will require,
    prior to funding construction of the facilities, the in-
    stitution of water conserving  devices and water meters
    or other pricing incentives to encourage conservation
    within the study area.   (See discussion of water con-
    servation under Issues  and Mitigations.)

    Regarding disposal of  sludge at  the Eagle County land
    fill, the preferred alternative  of both EPA and the two
    Sanitation Districts is  to recycle dewatered sludge
    residues back to the land on golf courses, interstate
    median strips, public  greenbelt  areas and private lands
    where use agreements can be developed.   Presently,
    sludge from these wastewater facilities  is being used in
    pasture land on an as  needed basis.   Expansion of this
    program will require recognition,  by both public and
    private land managers,  of the  value and acceptability of
    sludge for land application.

2.  See response to 1. above on water conservation.

3.  The proposed improvements at both facilities will
    significantly improve  the Quality of effluent discharges
    and represent the solution to present  problems over the
    next ten to twenty years.  Since expansion and improve-
    ment of the Avon wastewater treatment  facility will occur
    prior to that at Vail,  it is recognized  that interim
    improvements at Vail,  such as  additional  clarifier
    capacity, may need to  be provided first.

4.  See response to Northwest Colorado Council of
    Governments letter on  the subject of future water
    diversions.

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                           21
5.   EPA agrees that consolidation of water and wastewater
    treatment services should be encouraged.  We  understand
    that water districts in the areas are presently  studying
    this matter under a recently developed "Water Authority."
    This matter is best handled on the  local  and  regional
    level. and we encourage Eagle County to pursue such con-
    solidation of services.  However, we do not believe  that
    the projects being considered should be held  up  a-
    waiting the establishment of a single authority.

6.   We agree that nonpoint sources must be considered in
    developing a complete water quality management plan  for
    the area.  EPA will be funding a nonpoint source study
    for the area which will include a set of  implementation
    recommendations.  Because Eagle County has direct land
    use and other jurisdictional authority in this area,
    substantial participation by the County in this  effort
    will be encouraged through a joint  agreement  between the
    County and EPA, and others.  (See copies of the  Joint
    Agreement included as Enclosure 1.)  Also see responses
    (8) through (10) to Northwest Colorado Council of
    Governments comments.

7.   EPA does not disagree with this concept, but  believes
    that it is the authority of Eagle County and  other local
    governments with land use jurisdiction to implement  such
    controls.

8.   It is true that service charges are expected  to  increase
    for all users.  However, this is a  result of  anticipated
    increased operation and maintenance costs attributable
    to the higher levels of treatment required to be pro-
    vided by the improved facilities (e.g. ammonia reduction,
    dechlorination, etc.).  These costs should obviously be
    shared by all users.  Costs attributable to expanded
    capacity will be paid for by tap fees, thus new  users
    will pay fully for their share of capacity which is
    built for them.

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                                      22
                                                                    Keith  Troxel
                                                                        Disinci No 2

                                                                       DALE f GRANT
                                                                        District No. 3
        The Board of  County Commissioners-Eagle  County. Colorado

                          EAGLE, COLORADO 81631
                             Phone 326-6377
                             31  May 1977


U.D. Environmental Protection Agency
Region VIII
Attn:  John A. Green,
Regional Administrator
Denver, Colorado

        Re:  Draft Environmental Impact Statement -
             Upper Eagle  Valley and.Vail Wastewater Facilities Plan

Dear Mr. Green:

    The Eagle County Board  of Commissioners has reviewed  the  Upper
Eagle Valley 201 Facilities Plan and has made the following evaluation.

    In general, the  Plan  appears to meet the requirements for a 201
plan and is reasonably  consistent with County Planning policy.
Population projections  upon which the report is based are within an
acceptable range of  County  20&  land use and population estimates.
The selected alternative  appears to be a positive step toward water
Quality improvement  in  the  Upper Eagle Valley.
            The Board feels that  the  change in water use patterns from
        agricultural (6 month  consumption period) to domestic  (12 month
        consumption period) will  have significant impact on stream  flow;
        thus on discharge limitations.
                                                                   and
            Water availability  based  on change in use could seriously  affect
        growth rate and location  and  should be included in the report.
            (Jo.r,L of : orvi.ce  pr-o.jcct.ionr, arc hanod on growth project, ionr,.   In
        the ''voul that r.rowLh  dorr;  not occur at the projected r;itc,  there will.
        be :i revere impact on  current uccr cor,tc;.  This contingency  r.honld be
        included in the  plan in  order to effectively deal with all future
        situations.
            Although the  201  plan  was allowed to precede the 208 plan,  the
        subject of non point  sources should be addressed.  No plan  can
        effectively deal  with stream quality without addressing this  major
        contributor to stream pollution.   Some interchange and coordination
        is required in order  to  meet the  goal of high water quality in  the
        Upper Eagle Valley.
3or;:c Uosenberr
                 coumy
                                  MMlIng of Board . Flr»l Monday ol Month
                                                                 MAXWELL R. BARZ - County Clerk

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                              23

 Par,e  2
     The Board endorsed the comments of the Planning Commicsion  as
 stated  in their letter of 20 April 1977.   Major points  which  the Board
 feels should be emphasised arc:   effect of reduced stream flow  (and
 resultant effect on discharge limitations) of transbasin diversions,
 study of consolidation of special districts,  water conservation impacts,
_and sludge disposal alternatives,
 W.  Keith Troxel
 Chairman,
 Board of County Commissioners

 WKT/TK/ge

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                           24
Response to The Board of County Commissioners-Eagle County,
  Colorado

1.  These comments regarding water supply, availability, and
    quality impacts are nearly impossible to adeauately
    address at this time, due to the unknowns regarding
    water use and development decisions that are outside
    EPA's or the Sanitation District's control.  To some de-
    gree this issue is addressed on pages 120-122 in the
    Attachment to the Final EIS.  For further clarification
    an example can be given for the Vail-Gore Creek area
    which indicates that the level of treatment to be pro-
    vided will protect water quality against future stream
    depletions to a reasonable degree.  Assume that low
    flows on Gore Creek are depleted by 25 percent, which
    is consistent with 1995 growth projections for the Gore
    Valley.  Assuming such a decrease in flows would result
    in an eaual increase in pollutant concentrations in the
    creek, instream limits as shown in Tables 23, 24 and 25
    would still not be exceeded.  It should be recognized
    that any reduced treatment efficiency during such de-
    pleted, low flow periods would more significantly im-
    pact stream quality than presently projected.  Therefore,
    stream flows should be maintained as a protection to
    water quality, fisheries and aesthetics.  Such pro-
    tection will require the development of more innovative
    water supply methods than presently provided within the
    area.

2.  It is agreed that if growth does not occur as projected,
    costs for wastewater services would probably increase.
    However, the population projections are consistent with
    Eagle County and Town of Vail projections and there is
    little reason to believe that such growth will not be
    accomodated and supported by other public services as
    well.  We believe the issue, while possible, is not
    predictable.

3.  We agree on the subject of nonpoint pollution and control,
    Please see response  (6) to comments received from
    Eagle County Department of Planning and Development and
    responses (8) through  (10) to comments received from the
    Northwest Colorado Council of Governments.

4.  See responses to comments received from the Eagle County
    Planning Department dated 20 April 1977.

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                                Mrlliiniitd Illilf;.      .rir>0 Itroutlway      I'.O. llox 170     KnKlo. Oilornclo HIO.'ll
    P.OI.E   GOTH  1
D
D
                                       201 Facilities Plan Review
                                     Eoglo County Planning Department
                                             20 April  1977
 The Planning Department has reviewed the Unit  1 Activities for 201 Facilities Planning
 Study for the Upper Eagle Valley.  In  general  the concept of a coordinated plan for
 ensuring high quality wnlcr in the Upper Eagle Valley  is acceptable.  The following comment
 apply to specific areas of the Plan.

 NON POINT  SOURCES

 The intent of the Water Pollution Control  Act - Amendments 1972 was to set a process for
 water quality control through a designated scries of steps, however, in the Upper Eagle
 Vulley the process was changed to speed the approval  process for wastcwator treatment
 facilities. This change puts the domestic treatment facilities planning ahead of the area
 review of oilier pollution sources, specifically, non point sources.  Without  an integration
 plan to  relate all sources of pollution prior to approval of specific plant construction grants
 the goal of high quality water cannot bo met.

 Alllhough the Environmental Impact Statement doos briefly address non point sources the
 201 Plan dorr. not.  An nmcndment to the plan to deal with potential problems and mitigation
 measures should be nddod. The 201 Plan war. allowed to proceed before  the  208 Water
 Quality  Management Plan but it should not be completed without addressing  the major issue •
_conformance with the goals of the overall Water  Quality  Management program-.

 Eagle County has begun to set requirements  for construction of urban run-off control devices
 for new  development, however,/a"plan for mitigation of sources of pollution, this  does not
 provide  a solution.  Cooperation between all entities is essential to ensure success of water
 quality programs and should be  an integral part of the  study.
          Pl.in	:  l>i'|i:i|-lini'iil 'IM.iniiiiii; ('imiinr.sinii: Suliilivisi.m. Kivniiini:. A|>|>lir.ilinir. .-tud l!,.\j,.w Cl(l.'l) .'I2S (i.'t.'l.'t
          HuiUiMi: (Iflm.il: Iliiililmr. IVrinil'. .mil ln-.|	linn, /.niuiij; Ailliiini-.il ;M ion  CIO.'I) ;i:?!l li.'l.'lil

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                                           26
                ERVATION
       water use projections  in Iho 201  Report do not deal with potential  impacts of water
   conservation measures.  It is apparent that not only is water conservation becoming moro
   popular,  it is essential.  Eagle County has begun to review possible changes to its'
   regulations to require water r.aving appliances with all new development.  The impact of
   such chanyo of wnler use will be significant, therefore, sizing  of 'the proposed facilities
   must reflect use patterns in order to  provide cost effective treatment.

   Water quality management plans could provide a basis for public review of water conservation
   programs.
 WATER QUANTITY
 Tranobasin water diversions,  if constructed, will impact the stream quality.  At this time
 there is no reliable method of determining whnt effect and how much effect they will hcvo.
 Since the  201 Plan will possibly need to be revised based on change in stream  flow, the
 plan should allow for these changes.
 LAND USE DECISIONS
__
 Ac a general guide for wastcwotcr treatment in the Upper Eagle Valley the plan appears to
 bo workable.  Lund use decisions,  however, must bo bn^cd on individual site chc.ractcristics
 and their rclalionuhip to the County Master Plun.  Acceptance of Iho 201 Plan  and related
_populotion estimates does not set land use patterns or  initiate any development plans.

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                           27
Response to Eagle County Planning Department

1.  We do not agree that "the goal of high Quality water
    cannot be met" without a plan to control all water pol-
    lutant sources prior to the proposed action to improve
    and expand wastewater treatment in the area.  While it
    is desirable to have and implement such an integrated
    plan, realities dictate that action on  improvement of
    wastewater treatment not await the development ana
    implementation of a nonpoint source control plan.  This
    action in no way precludes control of other pollutant
    sources.

2.  This is in part a procedural question.   The Final
    Environmental Impact Statement was developed during
    the 201 planning process and is considered by EPA to
    be a part of the 201 plan.  EPA is proposing to
    conditionally approve the 201 Facilities Plan upon
    completion of recommendations for nonpoint pollution
    controls to insure the goals of the Water Quality
    Management Program.  Construction on these wastewater
    facilities cannot proceed with federal grant money until
    this 201 Plan is fully approved.

3.  See response (3) to Eagle County Department of Planning
    and Development.

4.  We agree that water conservation is an important means
    to reduce associated environmental impact and invest-
    ment requirements in water and wastewater treatment
    facilities.  See responses (1) through (7)  to Northwest
    Colorado Council of Governments comments.

5.  We agree that there is the possibility that future
    transbasin diversions may impact water quality in the
    area.  However, this 201 Facilities Plan must be bnsed
    on the stream flow information which includes the
    effects of only those projects which are fully developed
    or approved.  To do otherwise would be to prejudice the
    decision making process in favor of such diversion
    projects.   Further wastewater treatment planning may
    need to take into account the effects of transbasin
    diversion which are not now active.

6.  We agree that acceptance of the 201 Plan does not set
    county and local use and development decisions.

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                                       28

                   UNITED STATES DEPARTMENT OF AGRICULTURE
                               FOREST SERVICE
                              11177 West 8th Avenue
                                P.O. Box 25127
                            Lakewood. Colorado 80225

                                                                     8430

                                                             June  3, 1977
©



©
 John A.  Green,  Regional  Administrator
 U.  S.  Environmental  Protection Agency
 1860 Lincoln Street
 Denver,  Colorado  80203

 Dear Mr. Green:

 Thank you for the opportunity to review the Draft Environmental
 Statement for the Upper  Eagle Valley and Vail Wastewater Facilities.
 Our comments are mostly  editorial in nature and are offered for your
 consideration in strengthening the statement.

 The statement could be strengthened by eliminating repetitious and
 other narrative material not directly related to the proposed action.

 The maps would  have greater utility if the project site was shown on
 them.   The problem being addressed by the proposed action is not well
_defined.

 Alternatives 3a and 3b are apparently favored.  It is difficult to
 tell from the statement  if peak flows from Vail are by-passed to
_Avon,  if so can Avon handle them between now and 1985?

 Page 1,  should  reference the National Environmental Policy Act, not
 Protection Act.

 Page 5 should be Redd iff, not Red Cliff.

 Page 10 Terrestrial  Wildlife - There is no white-tailed rabbit.
 White-tailed jackrabbit  was probably intended, but if so, it is not
 a game species.   Also, elk winter and calve on south-facing slopes.
 Same on page 75.

 Page 10 Aquatic Biology  - The third paragraph may contain some
 typographical errors.  As written, it is either obscure in meaning
 or inaccurate.

 Page 36 (2nd full paragraph) - There is a recommendation for fishing
_flows  on Beaver Creek  as well as those mentioned here and on page 180.

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                                       29
©
                                                                       2.
  Page 61  -  Statement on Cultural  Resources appears to be inadequate.
  Where ground distributing projects are to be authorized, a cultural
  resource inventory (archeological  surveys) must be conducted on
  the ground where impacts are to  be.   The statement addresses a
  Level I  intensity inventory, when  a Level IV intensity inventory
__wpuld be more appropriate.

  Page 75  (bottom) - Should read Endangered and Threatened Species.

  Page 79, Table 16 - If the Beaver  Creek listed is the stream flowing
  through  the proposed ski development at Avon, its ranking is too low.
  Does the dash in the column headed "Condition of Fish" mean that the
  stream has no fish (see bottom of  page 80)?  Condition of trout in
  Beaver Creek is very good — should be rated about as high as  any other
  stream in  the list.

  Page 175 - "Channelization of stream flows around disturbed portion
  of streams" could cause more damage than it prevents.

 Tage 180,  Table 39 - It should not be assumed that the Forest  Service
  concurs  in these recommended flows.   Eventually, the Forest Service
  may make claims in state court for instream flows under Authority of
 _the Reservation Principle.

  Page 187 - "Potential  artifacts" ~ they either are artifacts  or
  they are not.
       Sincerely,
       S.T.  HANKS
       Deputy Regional Forester Resources

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                           30
Response to the United States Forest Service

1.  This new format for the Final EIS  is  in part an effort
    to respond to this comment.

2.  It is not planned to bypass peak flows from the Gore
    Creek area to the Avon facility, but  rather to design
    both plants to handle peak flows.

3.  The appropriate corrections have been made on the
    referenced page or was deleted for the sake of clarity.

4.  EPA does not require field surveys  to identify cultural
    resources for all construction projects.  EPA's re-
    sponsibility to conduct or fund  such  surveys on primary
    impact areas is limited by the following standard:   The
    extent of survey activities should  be based on the de-
    gree of probability with which cultural resources can
    be expected to be found.  Such probability is determined
    through consultation with the State Historial Society
    Preservation Officer.  See comments and responses to
    the State Historical Society of Colorado  (June 9, 1977
    and June 29, 1977).

5.  The appropriate corrections have been made.

6.  It is not stated or assumed that the Forest Service
    concurs in these minimum stream flow recommendations.

7.  The word "potential" has been deleted.

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                                 31
                FEDERAL ENERGY ADMINISTRATION

                             REGION  VIII
                            1075 South Yukon
                        P.O. Box 26247, Belmor Branch
                        Lokewood, Colorado 80226
                            June 8, 1977
 Mr.  John A. Green
 Regional Administrator
 Environmental Protection Agency
 1860 Lincoln Street
 Denver, Colorado   80203

 Dear Jack:

 The  Federal Energy Administration Region VIII office has reviewed the
 draft EIS on the "Upper Eagle and Vail Wastewater Facilities Plan."
 From our review, it appears that alternatives 3a through 5 are the
 most promising of the 10 listed, due to their cost effectiveness and
 flexibility.
 There is some question about the proposed sludge processing and disposal
 procedures discussed on page 129.  The description mentions the aerobic
 digestion process is adversely affected by cold temperatures, but by
 increasing the holding time and by heating the reaction buildings, this
 problem is partially mitigated.   Considering this problem, it appears
 that a closer look should be made of the anaerobic digestion process.
 At least a cost/benefit and energy consumption comparison should be
 considered for the two processes to pick the best alternative.
 There is also some concern about the discussion of water disinfectants
 as mentioned on pages 131 and 133.  The discussion mentions there is some
 uncertainty whether the proposed use of chlorination will meet the 1977
 kill  level  and still maintain acceptable chlorine residual discharge
 levels.   Since this is a recognized problem, should not more emphasis
 be placed on researching and solving this problem?  Will comparisons of
 the costs/benefits and energy consumptions be used to make the final
jjecision?

 Thank you for the opportunity to comment on this draft statement.

                                  Sincerely,
                                  Dudley E. Faver
                                  Regional Administrator

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                          32
Response to Federal Energy Administration

1.  Cost/benefit and energy consideration were an  integral
    part of the decision to use aerobic sludge digestion.
    Normally, the higher capital costs of anaerobic diges-
    tion are offset by production of digester gas  which
    ordinarily provides a net credit to a plants'  overall
    energy consumption.  However, the highly variable
    loadings in the Vail and UEVSD systems makes reliable
    gas production highly questionable.  Additionally, at
    smaller plants, aerobic digestion is often the method
    of choice to avoid imposing a more complex  (anaerobic
    digestion) system on a necessarily small operating
    force.  Additionally, since there will be only waste
    activated sludge produced at the plants  (no primary
    treatment) the aerobic digestion process is very
    directly compatible with the main flow processes in
    the treatment facilities.

2.  It is presently anticipated that if chlorination is
    the method of disinfection, that dechlorination will
    follow to reduce chlorine residuals to acceptable levels
    in the stream.  The final choice between chlorination/
    dechlorination and ozonation will be based on  cost/
    benefit and energy consumption requirements.   The
    problem is complex, however, since ozonation has rel-
    atively high on-site power requirements but no off-
    site demands, chlorination/dechlorination requires
    less on-site power, but also requires chemically man-
    ufactured off-site and transportation to the site.  The
    sources and types of fuel for the various power re-
    quirements are vari-ed and very difficult to predict for
    a given operation.

3.  EPA is currently formulating guidelines for making
    energy comparisons for these kinds of alternative
    analysis, but they will not be available in this case.
    The energy consumption for any of the possible dis-
    infection methods will not have a major effect on the
    overall energy consumption for the treatment facilities.

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               Department of Local Affairs
      ^     Colorado  Division  of Planning
                         Philip H. Schmuck, Director
                                                           Richard D. Lamm, Governor
.lime 6, 1977
Mr. John A.  Green
Regional Administrator
U. S. Environmental  Protection Agency
1860 Lincoln Street
Denver, Colorado  80203
               SUBJECT:  Draft Environmental Impact  Statement
                        Upper Eagle Valley and  Vail Wastewater Facilities

Dear Mr.  Green:

The Colorado Clearinghouse has received and distributed copies of the
above-referenced  draft environmental statement  for review by state
agencies  pursuant to  the National Environmental  Policy Act and OMB
Circular  A-95.  The comments of interested agencies  are enclosed here-
with.

Thank you for the opportunity to participate in  your planning.

                                  Very truly yours,
                                   larles G.  Jor/flan
                                  Senior Planner
Reviewed: .'-
          Philip H. Schmuck, Director

CGJ/vt
Enclosures

cc:   Office  of  the Governor
     Department of Health
     Department of Natural Resources
     Northwest  Colorado Council of Governments
 520 Stote Centennial Building, 1313 Sherman Street, Denver, Colorado 80203  (303)892-2351

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   STATE OF COLORADO
   Richard 0. Lamm, Governor
   DL'PAR TMFNT Ol NATURAL RESOURCES

   DIVISION OF WILDLIFE
                                        34
       R. Gripb. Director
   GOGO Bro.idw.iy
   Denver. Colorado OO216 (025-1192)
                                           June 1, 1977
                                                                          /,' 77-lit)
 o
       TO:
       FROM:
                Philip H. Schmuck,  Director
                Colorado Clearinghouse
                                 li rector
                            Voiron of Wildlife

SUBJECT:  / /-Draft Environmental Impact Statement  - Upper
                Eagle Valley and Vail Wastewater Facilities  Plan

The statement is both comprehensive and objective in considering existing
wildlife, wildlife habitats and the possible impacts on both that may result
from the proposal.
Apparently alternatives 3a or 3c (page 119) would cause the least distur-
bance to existing habitat so would be our choice of plans.  As stated, Gore
Creek and this general area have already been impacted by other types of
construction and by growth.  Alternative #1 (page 114), the no-expansion
proposal,  may slow the rate of development but would also probably result
in each new development building a separate facility.   This piecemeal
approach would do more damage than would the construction and use of a
common treatment  system.  As in most cases,  the  concomitant development
will probably bring greater impacts than will  the base facility.
       We agree with the mitigative measures listed on pages 172-176.  Equipment
       such as draglines,  working from the bank,  •will do less damage and cause
       less  siltation than would bulldozers working in the stream.  Revegetation,
       as listed,  should be a must.  We, also,  agree that construction should be
       _limited to certain periods  of the year.

       The sections covering air  and water quality and noise pollution appear to
       be adequate as are  other related  portions.  Overall,  it appears the probable
       impacts have been  recognized and provisions have been included to mini-
       mize these impacts.

       We do appreciate being given the opportunity to review and comment on the
       statement.
       JRG:cs
       cc:  H. Sherman
            P. Olson
            USFWS
            B. Evans
DEPARTMENT OF NATURAL RESOURCES, Harris Sherman, Execut.ve Director • WILDLIFE COMMISSION,. Vernon C. Williams, Chairman
          Thomas Farley, Vice Chairman • Sam Caudill, Secretary • Jean K. Tool, Member • Roger Clark, Member
       /g\           Jay K. Childress, Member • Dean Hull, Member • Dean Sutlle, Member

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Response to Colorado Division of Wildlife

1.  See discussion of EPA Proposed   Action.

2.  Prior to construction of this project, it will be re-
    quired that the Sanitation Districts coordinate with the
    Colorado Department of Natural Resources, Division of
    Wildlife, to insure proper protection to fish and wild-
    life by including the necessary mitigations which are
    described on pages 143 through 146 of the Attachment to
    the Final EIS.

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                            36
COLORADO  D£3=»ART&V3El\rr  OF HEALTH
     E 11TH AVENUE     DENVER BO2c?O     PHONE 308-6111 EXT. 329
                               NS.M U..M HA. liXECUTlVe TJIr{€CTOM
 DATE: May 23~  1977

 SUBJECT:    NON-STATE  ASSISTANCE

                        REVIEW  AND  COMMENTS

 T0 :   Ph i I ScliiTiuck
      Division  of Planning
      Dept of Local Affairs
 TO:
      NA
 PROJECT  TITLE:   DEIS,  Upper  Eagle  Valley  6 Vail  Wastewater Facilities

 STATE  IDENTIFIER:     NA
 COMMENTS  DUE  BY:   May  26
Yes
Yes
Yes
~] No LJ
D No Q
ID N° n
 Yes|_]
No
Is this project consistent with  the  goals  and
objectives of this agency?

Is there evidence of overlapping of  duplica-
tion with other agencies?

Is meeting desired with applicant?

A 15-day extension is requested.
 Commen ts:
            Air  Pollution  Control:   The  above-referenced DEIS has
 adequately  addressed  air  quality  impacts.   The list of control stra-
 tegies  on pages  182-187 of  the  analysis  provides  the local governments
 a  very  good  basis  upon which  to implement  local  control  plan(s),
 which will  assist  in  the  attainment  and  maintenance of air quality
 standards.
    Upon  further  modeling  of  the Upper  Eagle Valley and the Vail area,
 it  may  be determined  which  of the  control  strategies or  combinations
 may be  most  appropriate.  The analysis  performed  in the  DEIS  is
 appropriate  for  the  data  inputs available.   The  assumptions used should
 be  analyzed  and  the  model corrected  as  necessary  as further information
 is  acqu i red.
                            Name,  Title 6 Phone
 SOC-3,  Feb 77
WR/RS/ggb
                      ATTACHMENT B
                                            Jl
                                    Ron  Simsick,  Program Administrator

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                            37
Response  to Colorado  Department of  Health

1.  See discussion of proposed air  quality condition to
    approval and construction of the proposed facilities under
    discussion of Issues and Mitigation Measures.

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                                              38

                                              REGION XII
                               NORTH WbST C
           bST UOLORAOO tfOUNCIL
Or 6
                                                             OVFRNMFNTS
                                      Holiday Center Building Suite 200

                                             P. 0. BOX 737
                                         FRISCO. COLORADO 80443

                                             (303) 468-5445
EAGLE COUNTY
 RASAl.T
 r.Ac;i r
 GVPSUM
 MINUJRN
 VAIL
GRAND COUNTY
 PHASER
 (,HANDY

 rillANn L AKI
 Mill Mil I'HIIH SPRINGS
 Kill MMI IKK,
JACKSON COUNTY
 WALOEN
PITKIN COUNTY
 ASPEN
ROUTT COUNTY
 HAYDEN
 OAK CHEEK
 STEAMBOAT SPRINGS
 YAMPA
SUMMIT COUNTY
 BLUE RIVER
 BRECKENRIDGE
 DILI ON
 FRISCO
 SIL VEflTHORNE
                      I.
                     ©
                                                    June 9, 1977
John A. Green, Regional Administrator
U. S. Environmental Protection Agency
1860 Lincoln Street,  Suite 105
Denver, Colorado   80205
                        Subject:  Review of Draft EIS on
                                  Upper Eagle Valley 201
Dear Mr. Green:
     Thank you for the opportunity to review the subject, Envi-
ronmental Impact Statement.  My written comments will clarify
and expand on my oral testimony of May 26,  1977.   We believe
there are three major issues with regard to the  proposal which
remain unresolved:  1) The implementation of water conservation
measures as a partial alternative to plant  expansion. 2) The
relationship  of the proposed project to future development and
the generation of non-point source pollution. 3)  Future water
diversion projects and their effect on minimum streamflows.

Water Conservation

A.  Per Capita Usage
    The per capita water usage developed in  the facility plan is
150 gpcd based  on estijnated existing, per capita flow rates in
the Vail area,  plus an allowance for additional future usage.
We believe that an allowance of 150 gpcd is  excessive based on
the following information:
       Per Capita Usage

          150 gpcd
          100 gpcd
           90 gpcd
           90 gpcd
          100 gpcd
           64 gpcd
       Source

       Upper Eagle Valley 201
       Dillon/Silverthorne 201
       Snowmass 201
       Aspen Metro 201
       Steamboat Springs 201
       National Average based on:
       USGS  - Public Water Supply
       Bailey- WPC Research Series

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                                    39
    John A. Green, Regional Administrator
    Page 2
   ©
In summary, the projected per capita sewage generation for this area is
over 50% higher than the average of comparable recreation communities
within Region 12, even without the application of measures to control per
capita usage.
          B.  Population Growth
              The facility plan (and the 208 Study) projects a maximum population
          growth as follows:
                  Year
          208 Projections-Average Daily Population
          201 Projections-Average Daily Population
                                                    1975
                                                  197T57)
                                                  16,000
                                      1995
                                    477550
                                    44,700
              In other words, within the 20 year planning period, more than half the
          water and sewage demands are anticipated to be generated by new development.
          Current national and regional trends towards the use of water conserving
          fixtures and appliances will mitigate against the high projected per capita
          usage in over half of the services without any action from local governments.
          However, because of the critical nature of water supply and sewage treatment
          within the study area, it is anticipated that the County and municipalities
          will take action to curb water use.  Depending on the level of implementation
          of water conservation measures, the following water savings could be realized:
Water Demand
      Per Capita Use
         Source

     UEVSD 201
     Region XII Avg.
     No
Conservation

   150 gpcd
   100 gpcd
Water Conservation
on New Construction

      114 gpcd
       76 gpcdl
Water Conservation
  and Retrofit

     98 gpcdj
     65 gpcdz
               •"•Based on 35% water savings on new taps requiring water conservation
                measures.
               "Based on 3570 water savings on all taps requiring conservation on
                existing (retrofit) and new development.
          C.  Benefits of Water Conservation

              Re-evaluation of per-capita use figures as an alternative to building
          plant cpacities as proposed would have the following benefits:

              1.  Reduction of capital and 0 & M expenditures for wastewater treatment
                  to serve an equivalent level of development.

              2.  Reduction of capital and 0 & M expenditures for water supply and treat-
                  ment .  This is particularly true in the Beaver Creek Area where 18,200
                  new residents (average day) are expected to place demands on a water
                  supply which will come from the mouth of Beaver Creek and must be

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©
                                        40

         John A. Green, Regional Administrator
         Page 3
    pumped some 4 miles and  1200 vertical  feet  to  the point of use.

3.  Reduces financial risks  to existing users of water and wastewater
    systems if growth does not occur at projected  levels.

4.  Increases minimum streamflows and mitigates adverse effects on  fish
    and wildlife.

5.  The opportunity to balance water supply and wastewater treatment
    facilities without excessive costs or  risks users.

6.  A case study of a similar recreation cocmunity demonstrated that a
    water conservation ordinance plus a retrofit program on existing
    services allowed the connunity  to service 257,  more customers with-
    out modifying their water or T.-:astewater system.
            D.  Reconmended Actions

                The  following actions are recommended prior to approval of the facility
            plan:
0
©
©
©
 1.  A more detailed investigation of conservation as an alternative or
    partial  solution  to expansion of existing wastewater  treatment facil-
    ities be required.
 2.  The projected wastewater service demands and sizing of facilities  to
_   re-evaluated based upon water conservation measures being implemented.
    The County and municipalities should be encouraged to adopt and enforce
    water conservation ordinances as part of their building codes.

    A "retrofit" program of water conservation measures be undertaken as a
    cooperative effort of:
                             Eagle County
                             Town of Vail
                             Town of Minturn
                             Water Districts
                             Sanitation Districts
                             Council of Governments
       II.   Non-Point Source Pollution
            A.  Relationship of 201 and 208 Plan

                Both  the facility plan and the environmental impact statement place heavy
            reliance  on the completion and implementation of non-point source controls con-
            tained  in the 208 Walter Quality Plan under development by the Council of Govern-
            ments.  The Council of Governments, Eagle County and municipalities within the
            area recognize their responsibility to identify, assess and control the impacts of

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                               41
John A. Green, Regional Administrator
Page 4
     non-point source pollution which may be a secondary impact of the proposed
     expansion of wastewater facilities.  However, this cannot be practically
     accomplished without the participation of all entities which influence the
     location, character and density of future land uses within the study area.
     It is the council's opinion that the proposal will have a significant im-
     pact on the location, density and character of future development and
     therefore will affect the capabilities of government agencies to deal with
     non-point source pollution.

         It is our opinion that before a final decision is made on the sizing and
     location of wastewater treatment facilities in the Upper Eagle Valley, a
     more detailed evaluation of the secondary effects of the proposed system on
     non-point source pollution (such as was performed at Three Lakes) be initi-
     ated.  This recommendation is substantiated by the following information
     relative to the findings and of the 208 Plan.  It is important that EPA
     recognize the degree to which non-point sources can be controlled from the
    jiiechanisms contained in the 208 Program.
     B.  Non-Point Source-Overview Assessment

         The water quality assessment conducted by USGS as part of the 208 Plan
     indicates that runoff from urbanized areas and construction activities pre-
     sently causes water quality degradation in Gore Creek downstream from the
     Town of Vail.  Urban runoff and construction activities can be demonstrated
     to increase turbidity levels, decrease biological diversity and productivity
     and increase concentrations of heavy metals, oil and grease.

         The 208 water quality data base is intended to identify problem areas
     such that they can be correlated with other environmental factors to identify
     mitigation measures which will be applicable to the resource capabilities
     of the area in question.  It is not the intent of the data collection effort
     to be able to produce a detailed quantitative assessment of non-point source
     pollution, nor would such an effort produce substantial results.  The app-
     roach of assessing non-point source pollution from urban runoff using "typ-
     ical values for urbanized areas" merely tells us that non-point source pol-
     lution is significant in terms of pollutant loading, but does not suggest
     ways of controlling the runoff from urban areas before it is generated.
     Most importantly, this approach does not lend any insight into the type of
     control measures which would be most suitable for the particular area in
     questions.

         Table 37 in the draft EIS suggests that urban runoff contributes a sig-
     nificant pollutant load when compared to sewage treatment in the Vail area.
     However, because of the temporal variations in non-point source generation,
     it is difficult to compare the impacts of non-point source waste loading as
     compared to point sources.  This quantitative approach certainly suggests
     the need to control runoff from urbanizing and developing areas within the
     study area.

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                                42
John A. Green,  Regional Administrator
Page 5
         Further documentation for the potential severity of non-point source
     contribution is contained in the DEIS.  Applying the methodology described
     in the "Regional Overview" level 208 study (see attachment). we can pre-
     sently conclude the following:

         1.  Water quality degradation from urban runoff in the Vail are pre-
             sently exists.

         2.  The most significant future development of recreation/urban develop-
             ment in Region 12 is projected to occur withing the 201 Study area
             in the next 20 years.  An additional 10,000 housing units accomo-
             dating 28,700 additional persons and concentrated in the Benchmark,
             Eagle, Vail, Arrowhead and Deaver Creek Area is projected in the
             study.

         3.  A total of 6,730 acres are projected to be developed by 1995.  Al-
             though the development plans allow for approximately 257. of future
             development to be left in open space and parks, the location density
             and amount of development which would be accomodated by the proposed
             expansion of sewer facilities is significantly pre-determined by the
             proposal.  Although the DEIS states that because additional capacity
             will be provided at the downstream Avon site, and therefore, location
             of future development can occur anywhere within the service area of
             the district (p.57), a glance at Figure 11 reveals that the availa-
             bility of private bands, topographic constraints and other factors
             will focus growth into the western end of the service boundaries,
             much as shown.

             The factor that has clearly not been investigated or considered in
             determining the future land use is the effect on non-point source
             pollution of the proposal.  Our investigations have demonstrated that
             there is a relationship between the potential for generation and trans-
             port of non-point source pollutants depending on geologic formation,
             land use soil type, cover type slope, proximity to streams and other
             factors.  The most important of these? facts are geologic formation
             and land use since many of the other physical resources are in large
             part characterized by the geology.

             The majority of development which could be serviced by the project is
             located within the Eagle Valley Formation (Bedded Evaporites), the
             Minturn Formation and to a lesser degree on alluvial deposits in the
             Eagle Valley floor.  Development in the Eagle Valley and Minturn for-
             mations has severe implications for the generation of non-point source
             pollution since the formations and related soil types are subject to
             extreme to moderate stream, gully and slope wash with the removal of
             the protective vegetative cover.  Mitigation measures discussed in
             the DEIS do not include consideration of altering the location density
             or character of development to avoid the generation of non-point source

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                                43
John A. Green, Regional Administrator
Page 6
             pollution in critical areas, nor does the DEIS describe any re-
             quirements for re-vegetation of disturbed areas outside of con-
             struction directly related to the proposal.  Rather, the proposal
             tends to "lock in" future land uses without a thorough evaluation
             of the total water quality effects (i.e., both point and non-point
             source).

             4.  The DEIS states on p.167 that conversion of irrigated agricul-
             tural lands to urban uses will be a mitigating factor for non-point
             sources since the pollutant loads from urban lands will be more than
             offset by elimination of sediments and salts from agricultural prac-
             tices.  Data from the USGS 208 Study refutes this statement for the
             type of lands and irrigation practices prevalent withing Region XII
             and Eagle County.  In general, agricultural practices within Region
             XII cannot be demonstrated to have a significant adverse effect on
             water quality, while runoff from urban areas can.  On the contrary.
             data on water applied to upland mountain meadows in this area and
             other parts of the country, suggests that irrigated meadowland is
             a significant resource in reducing the types of pollutants generated
             in surrounding urban areas before they can reach the stream course.

             5.  Control of non-point source pollution problems from urbanizing
             and developing areas can be most effectively and economically achieved
             by prevention strategies rather than through costly structural abate-
             ment techniques which are applied after the fact.

             6.  Additional stream courses not currently affected by significant
             point or non-point source discharges will be degraded by the develop-
             ment accomodated by the proposal unless current land use policies and
             practices are changed.  These streams include Beaver Creek, Stone
             Creek and McCoy Creek.

     C.  Sunmary and Recommended Actions

         Summary

             1.  The proposed facility plan is believed to be a significant deter-
             minant on future patterns, location and density of development with-
             in the study area.

             2.  The natural characteristics of a large portion of the area to be
             developed indicate the area is highly susceptable to generation and
    	transport of non-point source contaminants.
         Recommended Actions

             1.  Changes in land use policies with respect to location, pattern
             and density of development and other land use controls should be
             evaluated before construction of the proposed treatment works.

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                                44
 John A.  Green,  Regional Administrator
 Page 7
              2.   A detailed site-specific evaluation of non-point source controls
              (see attachment - Phase 11-208 Water Quality Management Program)
              should be initiated to determine and implement land use controls, run-
              off control systems,  and structural controls if necessary.   The meth-
              odology for this type of program has been developed in the four proto-
              type programs demonstrated under the 208 Program.   It is anticipated
              that this could be accomplished within two months of initiation of
              the site-specific evaluation.   It is also proposed that proponents
              of projects which can be demonstrated to have significant impact
             _on non-point source pollution bear the cost of these detailed studies.
III.  Future Water Diversions

      A.   General

          Three basic physical control elements are contained within the 208 Water
      Quality Management Plan to assure that the water quality goals of the Region
      are attained:

                   (1)  Point Source Control Element
                   (2)  Non-Point Source Control Element (control of land disturing
                        activities)
                   (3)  Hydrologic Modification Control Element

          Implementation of the reconmendations contained in this letter will achieve
      the goal of assuring that the  first two elements are achieved.   Control of
      element #3 is broader in perspective than elements #1,  #2,  since it involves
      actions of municipalities,  private and governmental entities outside of Region
      XII, the State of Colorado,  and the various branches of the Federal Government.

          Without implementation of  controls to assure adequate streamflows for
      protection of water quality, funds expended for advanced waste treatment and
      costs incurred by local governments,  developers and others to insure that an
      adequate non-point source control program is initiated will fall short of
      meeting the water quality objectives established in the 208 Plan.

          Control of hydrologic modifications as it affects water quality,  was
      identified as a key element in the water quality management goals and object-
      ives through the input of over 300 citizens in public workshops.   The Council
      of Governments has developed a set of model regulations which can be utilized
      by local governments in Region XII to help insure that  future transbasin di-
      versions will not be in conflict with the design streamflows established in
      the 208 Plan.

          The successful implementation of the effort to maintain minimum stream-
      flows in Region XII and Eastern Eagle County will require a counterpart effort
      at the State and Federal level.   To date,  there has been a failure to recog-
      nize the need for this effort  or to take substantial action at  the Federal
      and State levels.   The mitigation measures proposed in  the DEIS consist of:

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                               45
John A. Green, Regional Administrator
Page 8
             1.  Written agreements between Federal Land Management and Reg-
             ulatory Agencies and the transbasin divertors as to minimum
             streamflows to be achieved (recomnendations from U.S. Fish and
             Wildlife Service on minimum streamflows necessary to preserve
             fish habitats).

             2.  Adjudicated water rights obtained by the Colorado Water Conser-
             vation Board to maintain minimum streamflows (reconmended flows
             from the Colorado Division of Wildlife).

          There are several basic flaws in the existing method of attempting to
      control transbasin diversions as an element in an overall water quality
      management strategy:

             1.  The existing method does not recognize water quality as a
             factor in establishing minimum streamflows.  This is clearly evi-
             denced in the case of Gore Creek where Division of Wildlife recomnends
             7 cfs as a minimum streamflow to be obtained and the design of waste-
             water facilities is based on a 7 day - 10 year low flow between 13.5
             and 115.0 cfs depending on the time of year.  Clearly even if the
             DOW reconmended streamflows could be achieved, in-stream concentra-
             tions of pollutants from point source discharges could be 200% higher
             than reconmended in the facility plan.  Thus an investment of approx-
             imately $5.35 Million in treatment facility upgrading and expansion
             along with local ordinances to control non-point source pollution
             would fall far short of meeting the water quality goals and standards
             established in the 201 Plan, 208 Plan and by the Colorado Department
             of Health.

             2.  The minimum streamflow program administered through the Colorado
             Water Conservation Board is dependent on obtaining the necessary
             water rights.  The financial limitations of the program become evi-
             dent when the number of streams potentially affected by future trans-
             basin diversions is considered.  There are presently 16 transbasin
             diversion projects which affect historic minimum streamflows through-
             out Region XII.  An additional 33 transbasin diversions from the Region
             are in various stages of development.  It is highly unlikely that the
             financial resources of the Water Conservation Board will be adequate
             to obtain all the rights necessary to protect water quality in all
             of the potentially affected streams in the Region.  There are no
             guarantees in the case of Gore Creek or the Eagle River that even
             the minimum streamflows established by DOW will be obtained.

             3.  Agreements between Federal agencies and transbasin divertors are
             in a similar status.  There is no consideration of water quality
             management objectives in establishing minimum flows.  Inclusion of
             minimum streamflows in permit conditions is on a case by case basis
             and there are no guarantees that such stipulations will be included
             in the permit or what criteria will be applied by the Federal Agency
             in determining the need for such stipulations.

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                                 46
John A. Green, Regional Administrator
Page 9
             4.  Section 208 of PL-92-500 stipulates that the planning process
             of each State shall include a process to identify and set forth
             procedures to control pollution caused by hydrologic modifications.
             NVCCOG is the only designated 208 Agency in Colorado addressing
             this issue.  An effective counterpart at the State level to develop
             procedures, regulations or modification of State statutes to achieve
             this is lacking at present.

     B.  Reccranended Actions

         EPA should consider the ramifications of continued funding of wastewater
     treatment works and State and areawide planning efforts without making sig-
     nificant headway in controlling the proliferation of hydrologic modifications
     which will alter the base from which water quality systems are presently being
     designed.  Without inclusion of this element as part of a water quality manage-
     ment strategy at all levels of government, the water quality goals stated in
     the DEIS will not be achieved.  The following actions are recomnended:

             1.  iiie Council of Governments will continue to work with local govern-
             ments to develop necessary regulatory programs to control hydrologic
             modifications at the county and regional level.

             2.  The State of Colorado should be requested by EPA to include hydro-
             logic modifications as an element in its continuing planning process.
             Regulatory programs, legislation, financial and institutional struc-
             tures necessary to deal with the problem at the State level should
             be developed and implemented as part of the Statewide water quality
             program.

             3.  In its role of evaluating Federal Agency compliance with the re-
             quirements of NEPA, the EPA review of Federal permits for transbasin
             diversion facilities (i.e. Federal Land Management Use Permits) should
             insure that there is a consistent policy towards inclusion of special
    	conditions for minimum streamflows consistent with water quality goals.
          Thank you for the opportunity to comment on the Draft EIS.  The staff
     realizes that many of the comments and recommendations made are relevant to
     issues that are regional and statewide and not totally within the control of
     the grant applicant.  However, if water quality management goals that have
     been established by Congress, the State and locally developed plans are to
     be achieved, it is time that we recognize the interdependence of the systems
     with which we are dealing and deal with the problem accordingly.


                                    Sincerely,
                                            _
                                    Phil Overeyhder       <^        \
                                    208 Coordinator           *
     P0:vg

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                           47
Response to Northwest Colorado of Governments

1.  We recognize that the  150 gallons capita per day  is  a
    higher figure than normally used for design of waste
    water facilities.  At  the beginning of the 201 facilities
    planning effort, it was decided that the per capita
    waste flows would be estimated for the Vail area  whero
    some information was available on water use, and  then
    applied to the whole study area.  This appeared to be
    the most reasonable approach given the proximity  at
    Vail to newer developments around Avon and the similarity
    of the developments, both being winter skiing oriented.
    After examination of water use records, wastewater flow
    measurements, skier populations, and estimating peak day
    populations, it was estimated that the per capita waste
    generation was within  a range of 125 to 150 gallons per
    capita per day.  Since these are relatively high  figures,
    it is reasonable to question whether these should be
    used in a newly developing area where water use could
    be substantially reduced through conservation practices.
    Also, the use of 150 gallons per capita per day,  (g/c/d)
    instead of 125 g/c/d, may be Questionable for either the
    Vail or Avon facilities.

2.  We believe your statement involves two similar but dif-
    ferent aspects of the questions involving per capita
    flow projections for wastewater facilities.  First, is
    the question of what is the effect, in terms of design
    capacity, of assuming a per capita flow figure lower
    than 150 g/c/d; and second what is the effect of  requiring
    additional water conservation practices?  Since there
    are two proposed wastewater facility expansions,  both
    questions must be addressed for each facility.  The
    effect on design capacity of assuming a flow rate of 135
    g/c/d and then assuming an additional 30 percent water
    savings on all new taps is shown in the table below.

FACILITY      PROPOSED            CAPACITY            CAPACITY WITt
           DESIGN CAPACITY      AT 135 G/C/D          CONSERVATION'

Vail      3.0 MGD(2) (1995)       2.7 MGD              2.5 MGD

Avon      3.5 MGD (1985)          3.1 MGD              2.5 MGD

    The service area populations used to determine these
    various design facilities are:

     1.   Vail Facility     1975-  15,990
                           1995-  20,150

     2.   Avon Facility     1975-   7,510
                           1995-  23,150

       Equals 95 g/c/d for all new taps and 135 g/c/d
       for existing taps.


       MGD means million gallons per day.

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                           48
    As  is shown in the previous table, additional conservation
    practices do not have as great an effect on the design
    flow-capacity for the Vail facility as the Avon facility.
    This difference is due to the assumption that conservation,
    through use of water saving fixtures, will only be applied
    to  new taps which are only 20 percent of Vail's total 1995
    service area population and nearly 70 percent of Avon's.

    If we are to  assume that all existing  taps  where re-
    quired  to retrofit  water use systems,  including such
    items as toilet dams and fine spray showerheads, a
    15 percent water  savings is possible.  Presently, such a
    retrofit program  is being pursued within the study area.
    This additional water savings would lower projected
    plant capacities  to 2.2  million gallons  per day (MGD)
    for Vail and  2.3  MGD for Avon.

3.   We generally  agree  with  the points you bring out con-
    cerning benefits  of water conservation.  For these
    reasons we plan to  condition our approval of the
    facilities plan to  require enactment of  water con-
    servation incentives and practices.  Under  this con-
    ditional approval no funds for construction  will be
    made available by EPA until metering and installation
    of water conserving devices is required  by  each
    Sanitation District prior to extending new  service.

    Certain benefits  of water conservation that  you have
    cited do not  directly relate to a decision  on sizing
    of the wastewater  facilities.   The benefits  of re-
    ducing operation  and maintenance  (0 &  M) costs for
    water supply  and  increases in minimum  stream flows would
    occur with water  conservation regardless of  the sizing
    of the wastewater treatment plants.  However,  we believe
    that the sizing decision should reflect  reasonable water
    use projections in order to provide incentive for conservation
    as  well as to receive the direct cost benefits.
    In considering  the  sizing question, the difference in
    planning horizons  (1995 for Vail, 1985 for  Avon)  and
    annual compound growth rates (2.4 percent for  Vail,
    20 percent for  Avon area)  should be considered because

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                                 49
          of the possibility  of  severely undersizing the facilities
          and thus having  to  expand the facilities again in the
          near future.   For the  Vail facility these considerations
          are not as  significant since the planning period is
          sufficiently  long,  approximately 17 years, and the
          growth rate is moderate.   However, for the Avon facility,
          the planning  period is much shorter, approximately seven
          years, and  the rate of growth is projected to be much
          higher.  The  result of undersizing the facilities would
          be to either  shorten the  effective service life of the
          plant or to reduce  the growth rate.  If the Avon facility
          were built  at the proposed 3.5 MGD capacity and popula-
          tion growth occurs  as  projected but water use rates are
          reduced so  that  only 2.3  MGD is needed by 1985, the
          effective service life of the treatment plant would be
          extended to around  1993 or 1994.  On the other hand,
          if a 2.3 MGD  capacity  is  built at the Avon site and the
          per capita  water use rate is 135 gallons per day, the
          annual growth rate  would  have to be reduced to around
          8.5 percent for  the Avon  service area if the capacity
          were not to be exceeded.   A per capita water use figure
          of 150 gallons per  day would require an annual growth
          rate of 7.4 percent in order to not exceed 2.3 MGD by
          1985.

      4.  In response to items (1)  through (3) we have expanded
          the discussion and  investigation of conservation as a
          partial solution to expansion of existing wastewater
          treatment facilities.   We do not believe that water
          conservation  in  itself is an alternative to expansion.

      5.  The following table summarizes the resulting wastewater
          treatment plant  capacities for various assumed water use
          practices and estimated usage rates.

                                 CAPACITY
                          (Million Gallons Per Day)

                  MODIFIED USAGE     WATER CONSERVATION     '-JATER CONSERVATION
                  ASSUMPTION        WITHOUT HhTKOFIT       WITH Kh'i'HOFIT
      PROPOSED     (135 G/C/D)         (EXISTING-135 G/C/D      (EXISTING-115 G/C/D
      (150 G/C/D)                    FUTURE-95 G/C/D)FUTUKE-95

Vail      3.0           2.7                  2.5                  2.2

Avon      3.5           3.1                  2.5                  2.3

      6.  The purpose of the  grant  condition explained earlier is
          to encourage  water  conservation in the area, through ap-
          propriate county and local ordinances.

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                           50
7.   We nqree that a retrofit proqram should be instituted
    for reducing water use and understand that such a
    program is being considered by both Eagle County and
    the Town of Vail.

8.   We do not agree that the final decision in sizing of
    the wastewater facilities expansion at Vail and Avon
    should await a more detailed evaluation of nonpoint
    source pollution.  However, we do believe that a non-
    point source study must be made which results in con-
    trols which will adequately protect water quality and
    the proposed investment in advanced waste water treat-
    ment.

    EPA will be funding a nonpoint source assessment for
    the 201 study area during the design of these facilities.
    This assessment should lead to an implementation plan
    which may recommend land use changes, but it is our
    belief that it should not affect the sizing of the
    treatment plants.  Also, many other controls, other than
    land use, exist for abatement   of nonpoint pollution.
    To wait until this nonpoint assessment is completed
    would substantially delay the proposed water quality
    improvements proposed for these point source discharges
    and we do not believe that the benefits of such a delay
    match the environmental and financial costs.

9.   It is true that the land use assumptions used do not
    include consideration of nonpoint source pollution.
    However, the assumed land use patterns are in line
    with approved and projected development of the area by
    Eagle County and Town of Vail.  The proposed facilities
    do not preclude future land use decisions by either
    Eagle County, the Town of Vail, or the Town of Minturn.
    The nonpoint source control assessment which EPA will
    fund and manage in cooperation with local governments
    should provide a sound technical basis for recommending
    solutions to existing and future nonpoint source problems.
    Such recommendations such as land use controls, structural
    nbato.ment measures, and nonstructural controls must then
    be acted on by local governments in order to be imple-
    mented.  Regarding item 4. the attachment to the Final
    Environmental Impact Statement has been changed
    accordingly.

10. The nonpoint   source assessment will allow for evalua-
    tion of land use policies prior to expansion of the
    proposed treatment works.  The scope of services for
    this assessment is included as Enclosure 2.

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                          51
11.  We agree with the Northwest Colorado Council of
    Government's concern for the impact of proposed trans-
    basin diversions and other hydrologic modifications
    which may affect water quality.  However, this subject
    goes far beyond the scope of the proposed action and
    cannot be adequately addressed within the planning for
    this one project.  EPA has sent a letter to the state
    requesting priority treatment of hydrologic modifica-
    tions in their continuing planning process  ( Enclosure
    3).  Also, EPA has and will continue to request that
    the water quality implications of other federal pro-
    jects, such as transbasin diversions, be evaluated and
    considered during the EIS process.

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                                    52


             United States Department  of the Interior
                         OFFICE OF THE SECRETARY
                            MISSOURI BASIN REGION
                           DENVER. COLORADO  80225

ER 77/385
                                         June 9,  1977
   Mr. John A.  Green
   Regional Administrator
   Environmental Protection Agency
   Region VIII
   1860 Lincoln Street
   Denver, Colorado  80203

   Dear Mr. Green:

   This is in response to your request of April 23,  1977 for the Department
   of the Interior review and comment on the Draft Environmental Statement
   for the Upper Eagle Valley and Vail Wastewater Facilities Plan,  Eagle
   County, Colorado.  The following comments are offered for your consideration.

                                   General Comments
   "Although the 201 study area is predominantly recreation oriented,  the
   environmental statement includes no inventory of recreation resources in the
   description of the existing environment.   We believe that such resources,
   Including community-oriented recreation areas, should be included  in that
   _section.

   Any permanent or temporary impacts on recreation resources should  be
   delineated.  The streams along which interceptor construction is proposed,
   for example, presently have adequate water quality to support a good
   fishery.  While the draft document acknowledges the temporary impact which
   the proposed construction would have upon existing aquatic biota,  the effect
   on fishing activity is not, and should be, discussed.

   We also believe that the tourism industry depends, in part, on the aesthetic
   qualities found within the study area.  In terms of viewing duration and high
   use volume, the valley bottoms are perhaps the most sensitive areas of scenic
   quality.  The final document should acknowledge the direct impacts construction
   activity, stream turbidity, and interceptor placement (including the several
  	stream crossings) will have upon aesthetic enjoyment of the natural resource.

   We are particularly concerned with the secondary impacts of increased
   population, projected to nearly triple between 1975 and 1995, on recreation
   resources.  It is stated in the draft document that these impacts  have

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                                        53

      Mr. John A. Green,  EPA, Denver, CO
      Page  two
      June  9,  1977


      "already undergone  an  extensive evaluation  .  .  .  and  are  not  treated  here
      in depth."  The  reviewer  is  referred  to  two  Forest  Service  documents,  Final
      Environmental  Statement for  the Meadow Mountain  Planning  Unit and
      Environmental  Analysis Report, Beaver Creek  Winter  Sports Site and  Year-Round
      Recreation Area,  if more  information  is  needed.   It is  our  position that  the
      mitigation of  secondary impacts of  population growth  or recreation  resources
      is not  adequately addressed  in the  referenced Forest  Service  documents.   For
      example, in the  section of the Meadow Mountain environmental  statement
      dealing with mitigation of secondary  impacts on  the provision of urban services,
      the document "recommended that Eagle  County  work towards  designation  of  the
      general Avon area as an area of State interest."  (Under  the  State  Land Act,
      designation of an area as an "area  of State  interest" would permit  counties
      to control new development with regulations  established under State guidelines.)
      " A New Town Committee,"  the document continued,  "could be  appointed  to  look
      into  the criteria for  establishing  a  new town."   Nowhere  is it stated  that
      even  this marginal  mitigation is  actually being  contemplated  by either Eagle
      County  or the  State of Colorado.

      We believe the greatest effect of the proposal on the study area may  well be
      the secondary  impacts  of  population growth.   The final  document should either
      offer realistic  mitigation or acknowledge population  growth and increasing
      pressures on existing  recreation  and  other urban resources  as being an
      unavoidable adverse impact of the proposal.
©

©
©
                                 Specific Comments

 Of the five alternative plans,  those calling for expansion of existing plants
 are preferable to construction  of new facilities.  Subalternative 3b-d would
 result in an unnecessary loss of riparian habitat.   Alternative 3a-c would
 cause the least environmental damage and is,therefore,  the most acceptable
^alternative.

 The projected impact  of chlorine residuals as depicted  in Table 25,  page 141,
 is significant.   A chlorine residual of  .003 mg/1 in the receiving stream
_should be achieved to protect most aquatic life.

 Mitigative measures discussed on page 172-176 are commendable and should be
 implemented.   However,  no provision is made for replacing or compensating
 for terrestrial and aquatic habitat losses.  Discussions with the Colorado
 Division of Wildlife  indicate opportunity exists for stream habit improvement
_within the study area.

 The statement does not  clearly  confirm consultation with the State Historic
 Preservation Officer  for the State involved.  The final environmental
 statement should reflect that he was consulted to determine whether the
 proposal will affect  any cultural site which may be in  the process of
 nomination to the National Register of Historic Places.

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                                   54
Mr.  John  A.  Green,  EPA,  Denver,  CO
Page three
June 9, 1977
 We note from pages 38 and 61 that the State Archeologist has been contacted
 concerning this project.   While the State Inventory of Cultural Resource
 Sites is a valuable source of reference,  it is not complete.  Consequently,
 we believe it would be desirable to ascertain from the State Archeologist
 whether, in his judgment, there is a need for an archeological survey of
 the terrain that will be  disturbed by construction.  A certification by him
 that the likelihood of finding any archeological remains is minimal relieves
 an undertaking agency of  much of the urgency for making a professional survey.

 The final environmental statement should  include copies of all correspondence
 with the State Historic Preservation Officer and the State Archeologist
 concerning the project.  Such correspondence facilitates and expedites the
 final review process.

 To aid reader understanding, we suggest that the preferred alternative be
 designated in "No. 2 Brief Description of the action" appearing before the
 table of contents.  We also suggest the same information be supplied in the
_beginning of the Section  on alternatives  on page 113.

                                      Sincerely,
                                      (JOHN E.  RAYBOURN
                                      Regional Environmental Officer

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                           55
Response to Unitod States Department of Interior

1.    The major definable recreational resources are the Vail
     ski area itself, the golf course and the streams.  Although
     not singled out specifically as "recreation resources" in
     the description of the existing environment, they are
     discussed in great detail in this and other sections of
     the draft EIS in terms of their effect on the proposed
     project and/or the project's effects on them.

2.    Without question, there will be impacts during the time
     that construction of the improvements is underway.  Con-
     struction in or near the Eagle River, Gore Creek, or tribu-
     taries will limit access for fishing.  Such construction
     may also cause siltation which may temporarily interfere
     with fishing; and turbid water will temporarily degrade
     the aesthetic quality of the stream.  It is also possible
     that access to other recreational uses such as the golf
     course or the ski area itself could be temporarily inter-
     rupted depending upon the time of year and the duration
     of construction activities.   Final siting and selection
     of locations for interceptor lines was not made in the 201
     study and is, in fact, normally done in final design.  The
     environmental effects can be greatly mitigated depending
     upon how the construction activities are carried out.  The
     degree of impact will be much more dependent upon the way
     in which construction is performed than upon the number
     of potential interfaces between construction activities
     and recreational resources.   The designers will require,
     in the construction specifications, that construction
     contractors minimize the amount of open trench and also
     require that clean-up activities and restoration to pre-
     construction conditions be done within certain time frames.
     With this approach, the total impact on recreational
     activities should be minimal.

     There will be virtually no permanent disruptions to recre-
     ational resources since the  proposed interceptor construction
     will parallel or replace existing interceptor lines.  Thus,
     all of the area has been previously disturbed and once
     construction is complete, and the surface restored to its
     original condition, there should be no permanent change.

     The designers will be required to coordinate with, and
     include in their designs, the requirements of the towns of
     Minturn and Vail and Eagle County with respect to permissible
     times of year,  duration of open trenching and time require-
     ments for restoration to previously existing conditions for

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                          56
     the  construction  activities.   These requirements, along
     with required permits by county,  state and federal agencies
     will insure that  the expected temporary disruptions to
     recreational resources are minimized.

3.    Regarding secondary impacts of population growth in re-
     creational resources, the principal effects will result
     from the development of additional ski areas, which EPA
     believes would occur with or without federal funds for
     expanded and improved wastewater  treatment.  As indicated
     in the draft EIS, the potential secondary impacts of these
     developments have been previously evaluated by the U.S.
     Forest Service and resulted in approvals by them,the State,
     and Eagle County.  The effect of  additional wastewater
     capacity will not be to create excessive demands on re-
     creational resources, but rather  to maintain and improve
     water quality in  the area thus benefiting opportunities
     for water oriented recreation, including fishing, boating
     and aesthetics.  Since certain development decisions have
     already been made and approved by the  controlling authorities
     it is our belief  that growth will occur.  EPA, by condi-
     tioning the availability of funds for  construction of the
     wastewater facilities, expects significant mitigation of
     air quality, nonpoint pollution and water use impacts.
     Mitigation of these secondary impacts  should benefit recre-
     ation opportunities in the area.

4.    The project will  consist of expansion  and upgrading the
     existing facilities at Vail and Avon as described in the
     section entitled  "Proposed Action." A decision to build a
     new plant downstream near Squaw Creek  will not be considered
     by EPA at this time.  Any future  proposal to build such a
     downstream facility must be completely evaluated in a separate
     facility plan and include an environmental assessment of
     the project's direct and secondary impacts.

5.    The State is proposing to require an instream standard for
     chlorine residual of .002 milligrams per liter.  This will
     require dechlorination or use of  ozone instead of chlorine
     for disinfection.  EPA and the State will review the design
     specification to  insure that this instream level will not
     be exceeded.  The referenced table has been modified
     accordingly-

6.    Coordination with the Colorado Division of Wildlife to insure
     protection of fish and wildlife,  including possible habitat
     improvement  (where consistent with the project scope) will
     be required of the Sanitation Districts during construction
     of this project.

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                           57
7.   See letters from State Historical Society (historical
    preservation and archaeological resources)  and EPA
    responses.

8.   The format  of the final EIS has been revised to make it
    easier for  the reader to find and understand EPA's
    proposed action.

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                                             58
                         DEPARTMENT OF HEALTH. EDUCATION. AND WELFARE

                                            REGION VIII

                                       FEDERAL OFFICE BUILDING

                                       I9IM AND STOUT STREETS

                                      DENVER COLORADO BO294
                                          June  10,  1977
                                                      OFFICE OF THE REGIONAL DIRECTOR
No
Response
Required
 Mr.  John  A.  Green
 Regional  Administrator
 U.S.  Environmental  Protection Agency
 1860 Lincoln Street
 Denver,  Colorado 80203

 Dear John:

 Thank you for the  opportunity to review the draft environmental impact
 statement for the  Upper Eagle and Vail  Wastewater Facilities Plan.

 It appears  that the impacts expected to result from this proposed pro-
 ject and reasonable alternatives thereto have been adequately
_addressed.

                                        Sincerely yours,
                                                   Edwin R.  LaPedis
                                                   Acting Regional Director
            cc:
            Office of Environmental  Affairs
            HEW,  Washington,  D.C.

            Council  of Environmental  Quality
            Washington,  D.C.  (2 copies)

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              Department  of Local  Affairs
            Colorado Division  of Planning
                         Philip H. Schmuck, Director
                                                                  '876
                                                          Richard D. Lamm, Governor
June 13,  1977
Mr.  John A.  Green
Regional Administrator
U. S.  Environmental Protection Agency
1860 Lincoln
Denver,  Colorado  80203
              SUBJ:ECT  Draft Environmental Impact Statement
                        Upper Eagle  Valley and Vail Wastewater  Facilities

Dear Mr.  Green:

We are enclosing the comments of  the  State Engineer's Office which
supplements  our previous response to  the above-referenced Environ-
mental Impact  Statement.

                                  Very truly yours,
                                 /
                                   .    /
                                ( _ tu...~U N '
                                  Cnarles G. Jordan
                                  Senior  Planner
Reviewed:     ^	
          Philip H. Schmuck,  Director

CGJ/vt
Enclosure
cc:   Office of the Governor
     Department of Natural  Resources
     Northwest Colorado Council  of  Governments
 520 State Centennial Building,  1313 Sherman Street, Denver, Colorado 80203 (303) 892-2351

-------
RICHAflD D. LAMM
   ClOVtMINir
 C.J.
Stnte Engineer
                           DIVISION OF WATER RESOURCES
                                 Deportment of Natural Resources
                                 1313 f>li-'rm in r.ir-.-r  Room 81fl
                                    IllMW-l, CllUil.Kill  00203
                                 Administration (303) 892 3581
                                  Ground Water (303) 892 3587

                                     June 10,  1977
        MEMORANDUM

        TO:        PHILIP H. SCHMUCK, DIRECTOR, STATE CLEARINGHOUSE

        FROM:     DR. JERIS A. DANIELSON, DEPUTY STATE ENGINEER

        SUBJECT:  UPPER EAGLE VALLEY AND VAIL WASTE WATER FACILITIES PLAN  (201)
        This is to acknowledge receipt of the above referenced plan that we have
        reviewed in accordance with your request,  and the following comments are
        presented for your consideration:

               1.  The method of treatment selected should not detrimentally
                  affect the availability of water  in the Eagle River and its
                  tributaries.
               2. The statement on page 36 concerning the preference of
                  municipal use over other types of water use is not totally
                  correct. The preference can only be invoked by condem-
                  nation and payment of just compensation to injured water
              _  right  owners.

               3. The statement on page 44 on the consumptive use of exported
                  water contains an error in that the "water is not returned to
              _  the stream from which diverted."

               4. Table 6 on page 47 appears to contain erroneous values for
                  the amount of water to be diverted under various phases
                  of the Eagle-Piney Project proposed by the Denver Water
                  Board. It would appear that the  values  should be in thou-
                  sands of acre-feet rather than as  shown.

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                               61

Memo To:
Philip H. Schmuck                  -2-                    June 10, 1977
       5.  The discussion in the re-use of effluent should it become
           feasible in the future is only correct if the effluent  is used
           to irrigate municipal parks and golf courses.
JAD/HDS:mvf

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                          62
Response to Colorado Division of Water- Resources


1.  Page 3€ has been removed from the final text and on page
    149 of the Attachment to the Final EIS your comment is
    properly noted.

2.  This correction has been made on page 6 of the Attachment  to
    the Final EIS.

3.  These corrections have been made in Table 3 of the
    Attachment to the Final EIS.

4.  We agree.

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                                63
                Department  of  Local  Affairs

              (Colorado  Division of  Planning
                          Philip II. St-limucU, Dirci'loi
                                                            Richard D. Lamm, Governor
June 20,  1977
Mr.  John A.  Green
Regional Administrator
U.S. Environmental Protection Agency
1860 Lincoln
Denver,  Colorado  80203
               SUBJECT:  Draft Environmental  Impact Statement
                        Upper Eagle Valley and Vail Wastewater Facilities

Dear Mr.  Green:

We are enclosing  the comments of the State Historical Preservation  Officer
for architectural and historical properties   regarding the above-referenced
environmental  impact statement.   These  comments supplement our previous
submittals.
                                       Very truly yours,
                                        Charles G. Jordan
                                        Senior Planner
          Philip H./schmuck,  Director
Reviewed :
CGJ/vt
Enclosure

cc:   Office  of the Governor
     State Historical Society
  520 Stote Centennial Building, 1313 Sherman Street,  Denver, Colorado 80203 (303) 892-2351

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                           64
     THE STATE HISTORICAL SOCIETY OF COLORADO
                   Colorado State Museum, 200 Fourteenth Avenue, Denver 89203

                                               June 9,  1977
0
Mr. Philip H. Schmuck
Director
State Clearinghouse
520 State Centennial Building
1313 Sherman Street
Denver, Colorado 80203

     RE:  Upper Eagle Valley and Vail Wastewater  Facili-
          ties Plan  (201)                         ,
                                                  ,' f "
Dear Mr. Schmuck:

This office shall comment concerning only architectural
and historical properties that may be located within the
potential environmental impact area of this project;  the
office of the State Archaeologist will respond  separately
concerning archaeological properties.

It is our understanding that 40 CFR Part 1500.9 (a) in-
structs federal agencies to include compliance  with  Sec-
tion 106 of the National Historic Preservation  Act of
1966, as amended, in fulfilling the environmental impact
requirements of Section 102(2) (C) of the National Environ-
mental Policy Act.  This statement is inadequate  in  that
it does not demonstrate such compliance nor does  it  con-
tain provisions to insure future compliance.

As set forth in 36 CFR Part 800, the National Historic
Preservation Act of 1966, as amended, requires  a  federal
agency to identify and consider cultural properties  during
the planning stages of an undertaking.  These responsibil-
ities, which should be fulfilled in the environmental  im-
pact statement, have not been addressed by the  Environmen-
tal Protection Agency  (EPA).

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                           65
      Mr. Philip H. Schmuck
      Page 2
©
0
 We note that the EPA has consulted the publications of the
 National Register of Historic Places,  and the Colorado In-
 ventory of  Historic  Sites to identify  properties included
 in and  eligible  for  inclusion in the National Register
 (Page  61).   As  set forth in 36 CFR Part 800.4 (a) (1),  this
 is only the first step in identifying  cultural properties.
 Since  these registers are in a formative stage,  they do
 not include all  properties which possess architectural or
 historical  value that may exist within the project impact
 area.   As set forth  in 36 CFR Part 800.4 (a) (2),  it is the
 responsibility  of the federal agency to identify all  other
 properties  which may possess value.  There is no indication
 in this environmental impact statement that the  EPA has
_done this.

 Once cultural properties of value have been identified,  the
 federal agency  is directed to consult  with the State  His-
 toric  Preservation Officer (SHPO)  to evaluate the signifi-
 cance  of the identified properties,  and to assess the extent
 and nature  of impacts that the proposed project  may have
 upon them.   If  any significant properties are found that
 will be adversely affected by the project,  planning,  in-
 volving the Advisory Council on Historic Preservation should
 take place  to consider alternatives  that will avoid or miti-
 gate these  impacts.

 We look forward  to receiving information from the EPA that
 will establish  this  project's compliance with federal pres-
 ervation law.   If we can be of further assistance please
 contact Michael  Quinn at the above address or at  892-3394.
      FOR-. THE STATE HISTORIC PRESERVATION OFFICER
     .James Edward Hax/tm/ann
      Curator,  Historic Preservation

      cc:   Land Use Administrator
           Land Use Coordinator
        '   Regional Council of Governments

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                          66
Response to State Historical Society of Colorado -
  Historic Preservation
1.  Included in this Final EIS as Enclosure    4 is EPA's interim
    policy for identifying and protecting historical, architec-
    tural, archaeological and cultural resources.  This interim
    policy requires EPA to:  (1)  collect information and
    conduct surveys only for areas of primary effects;  (2) use
    a standard of "reasonably high probability of discovering
    important cultural resources" in deciding to conduct
    intensive  field surveys; and (3) use the information
    obtained from the identification activities for determina-
    tions of eligibility for listing in the National Register
    in accordance with Advisory Council procedures.

2.  Because the existing wastewater facilities are less than
    20 years old and due to the already disturbed nature of
    the project site (construction will occur at existing plant
    sites and within existing sewer line corridors), it was
    decided that there was a very low probability of finding
    any historical or archaeological properties of value.
    This determination was made in consultation with the Office
    of the State Historic Preservation Officer and is supported
    in the letter which follows,  signed by Bruce E. Rippeteau,
    State Archaeologist.  Therefore, a field survey was not
    considered necessary for this project.  EPA does not
    consider it our responsibility to identify properties which
    are outside the project's primary impact area.

3.  EPA agrees.

4.  EPA has contacted Mr. Michael Quinn about this project
    and believes the project to be in compliance with the
    federal preservation law.

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                                     67
COLORADO OPEN SPACE COUNCIL  1325 DELAWARE ST.
                                              DENVER,COLO. 8O204
                                              30 June 1977
303/573-9241
0

©
  Mr-  John Green, Administrator
  Region VIII U.  S.  Environmental Protection Agency
  ]860 Lincoln Street, Suite 900
  Denver,  Colorado  80295

  Re:   201 Facilities Planning Study, Upper Eagle Valley, Colorado

  Dear Mr. Green:

  The  Unit 1  Activities Facilities Plan Report for the Upprr Eap.lo Valley
  Sanitation  District, which serves the Vail area, does not adequately
  describe or present an optimized land treatment alternative as required
 _under PL 92-500.

  Alternatives 9  and 10 are based on buying land initially for the 1995
  dcnip.n levels.   The selected alternative ic based on the 3.5 MGD plant
  al  the Avon site beinp, sized for 1985 conditions.  This provides an
 _unfair cost effectiveness comparison.

  Under the land  treatment alternative 9,  the Vail Golf Course and other
  Gore Creek  green areas should be irrigated in the initial phase, par-
  ticularly in light of the water lessons  being taught in this drought
  year.   Return flow would help support Gore Creek low flows.   This
  could be done with the Vail plant effluent.   The report discusses such
  irrigation  but  does not include it as a  part of the plan.   Sludge is
	disposed of in  a sanitary landfill rather than being recycled.

  The  nitrification  towers proposed will be subjected to cold temperatures
  and  will be treating cold sewage.   We are concerned about those facili-
  ties'  ability to perform under low temperature conditions and the poten-
 _tial impact of  ammonia on aquatic life.

  The  Eagle Valley  and the Gore Valley are special places in Colorado,
  potentially subject to increasing population pressures and additional
 _non-point pollution.

  Further,  the 201  plan should be based upon the proposed 1983 stream
  water quality standards rather than the  present effluent standards
  and  present stream classifications.
      CC:   Tom  Jorling
           Evan Pildine
                                        Very truly yours,
                                        Phil Stern, Chairman
                                        Water Quality Subcommittee
                      a state-wide environmental coordinating council

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                           68
Response to Colorado Open Space Council

1.  The land treatment alternative was evaluated and briefly
    presented in the 201 Facilities Plan.  Subsequently,
    the Colorado Water Quality Control Commission requested
    and received from the Sanitation District an addendum  of
    file materials utilized and developed in evaluating  land
    treatment which was not presented in the facilities
    plan.  In summary, land treatment was rejected as  an
    alternative for final evaluation in the EIS due to lack
    of cost effectiveness, unsuitable soils, existing  land
    use patterns, high land costs, severe climate, water
    rights problem, possible stream flow depletion, and
    the lack of a local implementing entity.

2.  The economics of each alternative were evaluated and
    compared for total costs by the year 1995.  Regarding
    land purchase, the immediate purchase of the required
    land would lead to large economies due to the rapidly
    escalating real estate costs.  A per acre figure for
    land of $5,000 was utilized in the cost effectiveness
    analysis and is considerably below current market
    value with sizeable land cost increases occurring  each
    year,  Staging of land acquisition for land treatment
    for an incremental land requirement of 20-25 percent
    was not considered wise due to land price increases
    for lands bordering the original purchase.

3.  The plan recommends that reuse of effluent be in-
    corporated into water use such as golf course irriga-
    tion.  However, the critical discharge period is in  the
    winter when population levels are high and stream  flows
    low.  Therefore, savings in treatment costs cannot be
    realized since irrigation in the winter is impractical.
    In the summer when golf course irrigation with effluent
    is possible, flows are near their highest and stream
    flow benefits from reuse are presently minimal.  As
    water demand and use increases in the future, both
    economic and environmental benefits of reuse may be
    better realized.  The costs of conveying effluent  to
    golf courses will be considerable due to the need  to
    make major changes in the existing water supply systems.
    As competition for water increases, these effluent
    conveyance costs will be a more attractive alternative
    to development of other water supplies.  Regarding
    sludge disposal, see response (1)  to Eagle County
    Department of Planning and Development.

4.  Nitrification to be provided at both treatment
    facilities is based on demonstration grant evalua-
    tions conducted at facilities of the upper Thompson
    Sanitation District, Colorado.  Nitrification of 10-12

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                          69
    mq/1 influent nmmonia concentrations nt temperatures
    near 10°C have been demonstrated successfully at this
    facility with effluent values of 1.5 mg/1.  The upflow
    nitrification process recommended will afford media
    surface areas greatly in excess of those utilized
    in the demonstration plant work.  The recommended
    unionized ammonia toxicity limitation of 0.02 mg/1
    for protection of a cold water fishery will be met
    by the treatment facilities.

5.   We agree and a nonpoint source assessment for the
    area is being initiated by EPA.  See response (8)
    through (10) for the Northwest Colorado Council of
    Governments comments.

6.   The proposed 1983 standards were not available at the
    time of this study-  However, it is expected that
    effluent values will meet such instream requirements,
    including unionized ammonia and residual chlorine
    concentrations.

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                                70
               Department  of Local  Affairs

             Colorado  Division  of Planning
                          Philip H. Schmuck, Director
                                                           Richard D. Lamm, Governor
July 1,  1977
Mr. John A.  Green
Regional Administrator
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver,  Colorado  80203
              SUBJECT:  Draft Environmental Impact Statement
                        Upper Eagle Valley and Vail Wastewater  Facilities Plan

Dear Mr.  Green:

We are enclosing the comments of  the State Historical Preservation Office
for archaeological matters regarding the above-referenced Environmental
Impact Statement.  These comments supplement our previous submittals.

                                      Very truly yours ,
                                         .--
                                      Charles G. Jo/rdan
                                      Senior Planner
              /  .'//  .-;   '   '
Reviewed:
          Philip H. Schmuck, Director
CGJ/vt
Enclosure

cc:   Office of  the Governor
     State Archaeologist
  520 State Centennial Building,  1313 Sheiman Street, Denver, Colorado 80203 (303)892-2351

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                                   71
            THE STATE  HISTORICAL SOCIETY
                                                              130° Broadway
                                                    Denver, CO  80203
                                                      June 29, 1977
©
      Mr.  Philip H.  Schmuck
      Department of  Local Affairs
      Colorado Division of Planning
      520  State Centennial Building
      Denver,  CO  80203

      RE:   DEIS Upper Eagle Valley and Vail Wastewater Facilities
           Plan (EPA):  archaeological resources

      Dear Mr. Schmuck:

           The Office of the State Archaeologist of  Colorado  has
      received and reviewed the Draft Environmental  Impact  Statement
      for  the  Upper  Eagle Valley and Vail  Wasrewater Facilities Plan.
      We apologize for the delay in our response,  but we  received our
      copy for review two weeks after the  deadline and during our
      Staff Archaeologist's vacation.

           Staff Archaeologist David R. Stuart has verbally discussed
      the  proper considerations of archaeological  resources with  Ms.
      Pepper of Camp Dresser and McKee, preparers  of the  EIS  (see
      enclosed).  For the 1985 component addressed in the Statement,
      archaeological resources are adequately considered.
      We do,  however,  recommend the following clarifications.   (1)
 It should be emphasized that the Colorado Archaeological Survey
 Site Inventory (the state-wide data repository which we maintain)
 contains only recorded archaeological sites, hence  previously un-
 recorded—and possibly significant—sites could well be present.
 (cf. p. 61).  (2)   The disturbed nature of the project impact area,
 however, makes conducting archaeological surveys to identify  these
 previously unrecorded resources largely impractical—previous
Disturbance  would  likely have destroyed all surficial manifestations,

      (3)  If subsurface materials are uncovered (cf. p. 187), im-
 pacting work shall be halted until the site is evaluated in terms
 of the  National  Register of Historic Places eligibility criteria.
 (These  criteria  are specified in the Advisory Council on Historic
 Preservation's "Procedures for the Protection of Historic and
 Cultural Properties"  (36 CFR 800; see 16 U.S.C. 470f, as amended  90
 stat. 1320)—note  that Executive Order 11593 of 1971 is a separate
 mandate (cf. p.  187).)

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                             72
Mr. Philip H. Schmuck
Page 2
June 29, 1977
     (5)  If the site is determined to be eligible for the
National Register, then plans for the mitigation or avoidance
of adverse impacts shall be properly arranged  Csee 36 CFR800).
By definition, if a site is "potentially valuable"  (cf. p.  187)
then it will be eligible.

     In sum, the statement adequately considers archaeological
resources, but several minor misunderstandings of the 36 CFR
800 procedures are apparent.  We are available to assist Camp
Dresser and McKee clarify these few points in the final statement,
(Call upon Staff Archaeologist David R. Stuart at 892-3391.)

     (The State Historical Society's Department of Historic
Preservation has independently commented regarding architectural/
historical resources.)
                                 For the State Historic
                                  Presar-irati'op Officer
                                 Bruce ET.
                                 State Archae^
                                 Phone:   (303)
BER(DRS):ng
cc:  Hart, SHPO
Lst  Colorado
 -3391

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                          73
Response to State Historical Society of Colorado -
  Archaeological Resources


1.  EPA agrees that sites could be present which are not yet
    recorded in the site inventory, but that the probability
    is low due to the predisturbed nature of the site.  (See
    responses to Historic Society on historic preservation.)

2.  EPA agrees that measures must be taken to insure the
    integrity of any archaeologic find made during construction
    The following procedures will be required of the Sanitation
    Districts in a special condition to any grant for construc-
    tion of the facilities.

        "In the event that subsurface materials, possibly
        constituting an historical or archaeologic find,
        are uncovered during construction, the following
        procedures will be adhered to by the contractor.

        1.  Construction shall be halted with as little
            disruption to the archaeological or historical
            site as possible.

        2.  A representative of the Sanitation District
            shall notify the State Historic Preservation
            Officer and EPA of the find and ask for
            guidance.

        3.  The State Historic Preservation Officer may
            decide to have an archaeologist inspect the site,
            and make recommendations about steps needed
            to protect the site, before construction in
            the area is resumed.

        4.  The entire event shall be handled as quickly
            as possible in order to hold the loss in con-
            struction time to a minimum while still
            protecting archaeological or historical finds."

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                                      74
0
    COLORADO  DEPARTMENT  OF  HEALTH
     4210 E. 11TH  A/ENUE         IDENVER BO22O             PHONE 386-6111
                        ANTHONY ROBBINS.M.D..M.P.A. EXECUTIVE DIRECTOR

                                          July 7,  1977
Mr. John A. Green, Regional Administrator
Region VIII
U.S.  Environmental Protection Agency
1860  Lincoln  Street
Denver,  Colorado  80203

Dear  Mr. Green:

The Colorado  Water Quality Control Conmission  (WQCC) wishes to respond to
the draft  Environmental  Impact Statement on  the Upper  Eagle Valley and Vail
Wastewater Facilities  Plan, April, 1977, with  the  following comments:

1.  Neither the 201 Facilities Planning Study  nor  the  EIS adequately ana-
lyzed a  land  treatment alternative as  required by  EPA  regulations.  Neither
of the land treatment  alternatives  (Nos. 9 and 10) were reviewed by the
EIS,  having been  rejected at an  earlier stage.  The  201 states that "any
detailed study of land application could best  be conducted under the 208
Water Quality Management Activities of the NWCRCOG".   Interestingly, the
208 plan prepared by the Denver  Regional Council of  Governments does not
adequately address the land treatment  opportunities  in the DRCOG region
either with the excuse that land treatment is  site specific and should
therefore  be  analyzed  in the 201s.  If we and  EPA  continue to permit this
shifting of responsibility, land treatment will always fall between the
cracks.
©
 2.   The WQCC requested and has  received an Addendum from the Upper Eagle
 Valley Sanitation District,  dated June  27,  1977,  which attempts to explain
 in  more detail  why the land application alternatives were rejected.  EPA
 is  not on the list of recipients;  therefore,  we enclose a copy for EPA re-
_yiew and analysis as to adequacy and accuracy.

 3.   The 201 plan, the EIS, and  the Addendum,  all  mention that at some future
 date golf courses, etc. may be  irrigated with sewage effluent but it is stated
 that this is not cost effective now.  However,  the land treatment alternatives
 (Nos.  9 and 10)  do not include  these methods, nor do any of the other alterna-
 tives.  There are no costs,  application rates,  techniques, etc. presented re-
 garding such irrigation.   Instead of addressing this at some later date, the
 201 is the proper vehicle to fully analyze it.  It could then become part of
 Step II design  and Step III construction.  The 201 is a plan for 1995;
 irrigation with effluent should be integrated into the plan now.

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                                    75
©
©
       Mr. John A. Green
       July 7, 1977
       Page 2
 4.   The same can be said for sludge disposal.  Both the 201 and the EIS
 indicate that recycling of sludge is either possible (201 1-3) or already
 partially being accomplished (EIS 134).   Yet the proposed alternative is
 to dewater the sludge and truck it to a landfill site.   This is disposal
 instead of use of a resource, and such disposal can create additional
 pollution of groundwaters.  The 201 and the EIS should address recycling
_now.

 5.   The plan recommends transporting the waste activated sludge from the
 Vail plant several miles through an interceptor to the Avon plant for full
 treatment.  We question the advisability of separating the solids at the
 Vail plant and then mixing them with raw sewage only to be separated again
_at the Avon plant.  This does not seem prudent for a long-range solution.

 6.   The chosen alternative and all of the other conventional alternatives
 have been phased so that present construction would entail treating a total
 of 6.5 mgd (1985 design condition), with a new plant to be built in 1985 for
 an additional 2.3 (1995 design condition), making a total of 8.8 mgd, yet
 the land treatment alternatives are designated from the outset to provide
 for the total 8.8 mgd flow.  This puts land treatment at a distinct dis-
_advantage from a cost-effective standpoint.

 A recent news release quotes Assistant EPA Administrator Tom Jorling as
 stating that EPA will promote recycling of sewage water for irrigation
 and land treatment systems to use sludge for fertilizer or mulch.  Senator
 Wendell Anderson suggested that such innovative systems should receive
 priority funding.  With this new direction coming from Washington, the
 WQCC believes the time has come to be serious about implementing various
 forms of land treatment in Colorado.

 The WQCC has voted,  with some reservation, to approve the grant for Upper
 Eagle Step II.   This action was taken with the conviction that the EPA would
 participate in further analysis and encouragement of the possibilities of
 land treatment in this area.  We are hopeful that EPA will follow national
 guidelines in assisting Upper Eagle to implement more innovate forms of
 wastewater treatment and address these comments specifically.

                                  Sincerely yours,
                                                .
                                        Evan D.  Dildine, P.E.
                                        Technical Secretary
                                        Water Quality Control Commission
       EDD:rr

       Enclosure

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                            76
Response  to Colorado  Department  of Health
1.  Both  EPA and the  State must  continue and  increase  our
    efforts  to encourage land treatment and reuse of sewage
    effluent.   We agree  that the  investigation of land
    treatment alternatives could  have been better documented
    in both  the 201 facilities plan and draft EIS.  However,
    in our opinion, the  downstream land treatment alterna-
    tives were legitimately dismissed during  development
    of the facilities plan for reasons of cost,  environ-
    mental impact and difficulty  of implementation.  Basically,
    the  limited growing  season,  remoteness of suitable land,
    the  possibility of significant stream flow depletion and
    water rights conflict, high  land costs, limitation of
    suitable winter storage sites, and the winter limitations
    on discharge of ammonia, make land treatment neither the
    most  cost effective  solution  nor an environmentally
    sound alternative.

2.  We have  reviewed  this document and believe that evaluation
    of land  treatment is not sufficiently documented in the
    facilities plan or addendum.   In the future, EPA will
    require  a more complete documentation of  the evaluation of
    land  treatment and reuse alternatives, whether recommended
    or not.

3.  You are correct that this alternative was not adequately
    analyzed.  As a condition to approval of the facilities
    plan, we  will require the Sanitation Districts to fund a
    study of  wastewater  reuse in conjunction with the ongoing
    comprehensive water  study for the area.  We believe  this
    to be an  appropriate approach in that there appears  to be
    no obvious water quality benefits or cost savings from
    reuse of  effluent on golf courses and other open  space
    lands at  this time.  This situation occurs principally be-
    cause winter discharge  requirements are most restrictive and
    use of normal land application systems,  in this climate,
    will not  relieve this limitation and therefore will  not
    reduce treatment costs.  It is possible that, with the
    additional use of effluent for snow making and shallow
    groundwater injection,  reuse might become a very
    realistic option. However, to study the water requirements,
    costs, and environmental effects of such a sophisticated
    system at this date  would severely jeopardize already
    needed wastewater treatment improvements  in the area.
    Therefore, our approach for this project will be to  require
    study of these options, in the belief that economics may
    be favorable in the  future as water demands and costs  in-
    crease.  Because a very substantial redevelopment of

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                           77
    existing water supply systems and pumping of effluent
    would be required to develop a total wastewater reuse
    system in the area, the costs are not expected to be low
    in comparison to the proposed action.  Since the benefits
    of such a system are principally in the area of water
    supply, we believe the costs are best borne by the water
    users rather than under federal funds for water quality
    improvement.  In other words, the proposed action will
    insure the necessary water quality improvements without
    bearing the additional water supply costs.

4.   See response (1)  to Eagle County Department of Planning
    and Development.

5.   The proposed sludge handling system provides economics of
    scale by centralizing dewatering and hauling requirements.
    Clarifier sizing will not be affected at Vail and only
    minimally at Avon since the sludge wasted at Vail will be
    only 30,000 gallons per day compared with a 3.1 MOD
    capacity at Avon.  In addition, space is limited at the
    Vail plant site and sludge handling at Vail would require
    site and access acquisition resulting in greater costs
    than the proposed plan.

6.   All alternatives were costed for requirements to 1995,
    even though the construction will be staged, so that costs
    are comparable.

7.   EPA agrees that greater consideration of land treatment
    and reuse systems must be required in order to realize
    the benefits that such systems mny have over conventional
    treatment.  All things considered, we believe it would be
    seriously detrimental to water quality in Gore Greek and
    the Upper Eagle River to require a total reexamination of
    reuse for this area.  We believe that this position is
    consistent with that taken by the Water Quality Control
    Commission in approving the Step II grant for Upper Eagle.

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                                         78
                      U.S.  DEPARTMENT OF TRANSPORTATION
                           FEDERAL HIGHWAY  ADMINISTRATION
                                     REGION EIGHT
                              BUILDING 40. DENVER FEDERAL CENTER
                                  DENVER. COLORADO 80223
        «fjn»»
                                                        July 26, 1977
                                                                          IN RCPLT neria TO:
                                                                            HEO-08
0
 Mr.  John  A.  Green
 Regional  Administrator
 U.S. Environmental  Protection Agency
 1860 Lincoln Street
 Denver, Colorado   80203

 Dear Mr.  Green:

 Thank you for the opportunity to review the draft environmental statement
 for  the Upper Eagle and  Vail  Wastewater Facilities Plan.  We offer the
 following comments:

 The  EIS does not  address any possible conflicts with the existing trans-
 portation facilities that may occur during construction.  If any
 disruptions  of traffic do take place during the construction of collector
 lines or  other facilities, mitigation measures should be discussed as to
 how  traffic  will  be maintained.

 Also, if  the project does conflict with highway transportation facilities,
_th1s EIS  should  be coordinated with the Colorado Department of Highways.

                                   Sincerely yours,
                                         F.  S. Allison
                                         Director, Office of Environment
                                           and Design
    7>?e-i9i*

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                           79
Response to Federal Highway Administration

1.    The existing sewer lines, which will require replace-
     ment in many areas, run alongside and within the U.S.
     Highway 6 and 24 right-of-way  (ROW) near Avon to the
     junction of Interstate 70 and U.S. 24.  From there east
     to the Vail treatment plant, the lines run parallel to
     the Eagle River and Gore Creek and in some cases within
     the 1-70 ROW.  Another sewer line parallels the Eagle
     River along the ROW from U.S. 24 through Minturn.  In
     Vail and east of Vail, the sewer lines run alongside
     pedestrian streets and other residential access streets.
     Replacement of these sewers within the existing easements
     will require coordination with the State, County and
     Towns involved to insure safety to motorists, adequate
     traffic control and flow.  The construction contract will
     have special conditions for work along highways to in-
     clude compliance with State, County and Town requirements
     such as barricades, signs, lights, seasons when work can
     be done, etc.  This construction will temporarily disrupt
     the flow of traffic at various times during the construc-
     tion season on all of the previously mentioned roadways.
     Every reasonable effort will be made to minimize this
     disruption and provide for safe travel through coordina-
     tion with the responsible State, County and local
     authorities.

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                              81
Enclosure 1  - Nonpoint Source Control Program
              Joint Agreements

-------
                                              82
                                              REGION XII
                              NIIHIH WIM l»i" OIIAIJII v»oiFN(.M Ui UCIVMINMI KM:.

                                     Holiday Cunlui Building  Sintu 2
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                                  83


                            JOINT AGREEMENT
     The Environmental Protection Agency  issued  a  draft  environmental
impact statement  (EIS) on the Upper  Eagle Valley and Vail Wastewater
Facilities Plan in April, 1977.  This EIS recognized,  through  a  very
generalized evaluation, the potential significance of  nonpoint pol-
lution in the study area.  Comments  received from  the  North West
Colorado Council  of Governments 208  coordinator, the Eagle County Plan-
ning Commission,  and the Eagle County Board of County  Commissioners
indicated further assessment of the  nonpoint pollution problem is needed
to provide an integrated water quality management  plan.  As a  result
of these concerns, EPA is proposing  to fund a nonpoint pollution study
including a recommended plan for implementation  for the  201 study area.
This study should be managed by a team of representatives from Eagle
County, the North West Colorado Council of Governments,  the Town of
Vail, the Town of Minturn, the Upper Eagle Valley  Sanitation District,
the Vail Water and Sanitation District, the Colorado 208 Executive
Committee, and the Environmental Protection Agency.

     The undersigned hereby agree to provide active participation in
the management of a nonpoint source  pollution study leading to a recom-
mended plan of implementation for the Upper Eagle  Valley and Vail 201
facilities plan study area.  We recognize the need to provide  for im-
plementation of nonpoint source pollution controls in this area and,
given adequate public involvement in development of the  recommendations,
we will, to the best of our abilities and within jurisdictional authori-
ties, pursue the  implementation of the study recommendations. The local and
County governmental jurisdictions of Eagle County, Town  of Vail and Town
of Minturn will consider implementation of recommended nonpoint source
controls in action before the appropriate elected  policy body.  We recog-
nize that failure to institute nonpoint source pollution controls may
jeopardize the attainment and maintenance of water quality goals for the
area as well  as the effectiveness of wastewater treatment improvements.
Dale F. Grant                                   Jojxf/. Green
Chairman                                   f   Regional Administrator
North West Colorado Council of                  EPA Region VIII
  Governments

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                            84
                             Box 381
                        Minturn, Colorado 81645
                              September 9,  1977
United States Environmental
  Protection Apency
Region VIII
1800 Lincoln Street
Denver, CO   80203

     Reference:  SW-EE

     AttentJ on:  John A. Green, Regional Administrator

Dear Mr. Green:

     Enclosed is a signed joint Agreement by  the  Town of
Minturn on the non-point source pollution study to  be con-
ducted by your agency.

     The Town understands that it will not be  requested  to
participate in any manner in terms of funding, and  that  it
will not be under any commitment to implement  any of the rec
ommendations if said recommendations are not  practical  or
economically feasible for the community.

     I trust that this will be satisfactory with  you.

                              Sicerely,.
                              Robert Manzanares
                              Town Manager
cd

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                                  85


                            JOINT AGREEMENT
     The Environmental Protection Agency issued a draft environmental
impact statement (EIS) on the Upper Eagle Valley and Vail Wastewater
Facilities Plan in April, 1977.  This EIS recognized, through a very
generalized evaluation, the potential significance of nonpoint pol-
lution in the study area.  Comments received from the North West
Colorado Council of Governments 208 coordinator, the Eagle County Plan-
ning Commission, and the Eagle County Board of County Commissioners
indicated further assessment of the nonpoint pollution problem is needed
to provide an integrated water quality management plan.  As a result
of these concerns, EPA is proposing to fund a nonpoint pollution study
including a recommended plan for implementation for the 201 study area.
This study should be managed by a team of representatives from Eagle
County, the North West Colorado Council of Governments, the Town of
Vail, the Town of Minturn, the Upper Eagle Valley Sanitation District,
the Vail Water and Sanitation District, the Colorado 208 Executive
Committee, and the Environmental Protection Agency.

     The undersigned hereby agree to provide active participation in
the management of a nonpoint source pollution study leading to a recom-
mended plan of implementation for the Upper Eagle Valley and Vail  201
facilities plan study area.  We recognize the need to provide for im-
plementation of nonpoint source pollution controls in this area and,
given adequate public involvement in development of the recommendations,
we will, to the best of our abilities and within jurisdictional  authori-
ties, pursue the implementation of the study recommendations. The local and
County governmental jurisdictions of Eagle County, Town of Vail  and Town
of Minturn will consider implementation of recommended nonpoint source
controls in action before the appropriate elected policy body.  We recog-
nize that failure to institute nonpoint source pollution controls may
jeopardize the attainment and maintenance of water quality goals for the
area as well as the effectiveness of wastewater treatment improvements.
                  s£ //„.
^    	
Bob Manzanares                                 v'phA." Green
Town Manager                                 '  Regional Administrator
Town of Minturn                                 Region VIII

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                          86
     I-I-I-1.1--1  K.UJU1'. VAI.U'.'i  .SAMTATKXX  h'LVIM-.'K ' I'
                        I) I I" Avon Un.xl

                          I'.O. Hu\ ^
                       \ViHI. Colulililn UI(
                                 September 9, 1977
                                                 i;:
Mr. John A. Green
Regional Administrator
United States Environmental
Protection Agency, Region VIII
1860 Lincoln Street
Denver, Colorado  80203

Dear Mr. Green:

     Enclosed per your request of August 29, 1977  is  an
executed joint agreement, in which the Upper Eagle Valley
Sanitation District commits to provide active participation
of the management of a nonpoint source pollution study -

     You will notice that the proposed agreement is modified
somewhat to reflect our understanding that the point  source
solutions that Upper Eagle Valley Sanitation District has
worked so hard to arrive at will not be jeopardized by delays
in the implementation of nonpoint solutions or by  someone's
perception that the solutions implemented were not satisfactory
We believe we are serving the environment well by  solving  the
wastewater pollution problems and can see no reason why  these
efforts should be linked to nonpoint pollution problems.
     We understand the need to solve the nonpoint pollution
problems and commit to work diligently in seeing solutions
implemented.  We hope you agree with our position and will
and return to us a copy of the enclosed amended
                                                 joint
              sign
         agreement
                                 incerely,
ins
                                James P. Cof
                                 istriytt Mdftager
                                     "• '
                                /John V. Amato,
                                President
JPC:ajh
Enc.
cc:  Thomas T. Grimshaw
     Robert Doyle
     Kent Rose
     Phil Overevnder

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                               87
                           JOINT AGREEMENT
     The Environmental Protection Agency issued a draft  environmental
impact statement  (EIS) on the Upper Eagle Valley and Vail  Wastewater
Facilities Plan  in April, 1977.  This EIS recognized, through a  very
generalized evaluation,  the potential significance of nonpoint pol-
lution in the study  area.  Comments received from the North  West
Colorado Council  of  Governments 208 coordinator, the Eagle County Plan-
ning Commission,  and the Eagle County Board of County Commissioners
indicated further assessment of the nonpoint pollution problem is needed
to provide an integrated water quality management plan.   As  a result
of these concerns, EPA is proposing to fund a nonpoint pollution study
including a recommended  plan for implementation for the  201  study area.
This study should be managed by a team of representatives from Eagle
County, the North West Colorado Council of Governments,  the  Town of
Vail, the Town of Minturn, the Upper Eagle Valley Sanitation District,
the Vail Water and Sanitation District, the Colorado 208 Executive
Committee, and the Environmental Protection Agency.

     The undersigned hereby agree to provide active participation in
the management of a  nonpoint source pollution study leading  to a recom-
mended plan of implementation for the Upper Eagle Valley and Vail 201
facilities plan study area.  We recognize the need to provide for im-
plementation of nonpoint source pollution controls in this area  and,
given adequate public involvement in development of the  recommendations,
we will, to the best of  our abilities and within jurisdictional  authori-
ties, pursue the implementation of the study recommendations. The local and
County governmental  jurisdictions of Eagle County, Town  of Vail  and Town
of Minturn will  consider implementation of recommended nonpoint  source
controls in action  before the appropriate elected policy body.   We recog-
nize  that failure to institute  nonpoint source pollution controls may
jeopardize the attainment and maintenance of water quality goals for the
area.as well as the  offcctivonooo of wootewator tr-eotinc-nt improvements.

       *The  Environmental  Protection  Agency specifically agrees
 that future funding  for  the sewage  treatment facilities  required
 in  the Upper E;ij;lc Valley will  not  be affected  by  actions re-
 sulting or related to this study.
  Jcvhn V.  Amato,  President
 /Upper  Eagle  Valley  Sanitation
  District
John  A. Green
Regional Administrator
Region VIII

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                                88
                            JOINT AGREEMENT


     The Environmental  Protection Agency issued a draft environmental
impact statement (EIS)  on the Upper Eagle Valley and Vail  Wastewater
Facilities Plan in April, 1977.   This EIS recognized, through a very
generalized evaluation, the potential significance of nonpoint pol-
lution in the study area.  Comments received from the North West
Colorado Council of Governments  208 coordinator, the Eagle County Plan-
ning Cormiission, and the Eagle County Board of County Comnissioners
indicated further assessment of  the nonpoint pollution problem is needed
to provide an integrated water quality management plan.  As a result
of these concerns, EPA is proposing to fund a nonpoint pollution study
including a recommended plan for implementation for the 201 study area.
This study should be managed by a team of representatives from Eagle
County, the North West Colorado  Council of Governments, the Town of
Vail, the Town of Minturn, the Upper Eagle Valley Sanitation District,
the Vail Water and Sanitation District, the Colorado 208 Executive
Committee, and the Environmental Protection Agency.

     The undersigned hereby agree to provide active participation in
the management of a nonpoint source pollution study leading to a recom-
mended plan of implementation for the Upper Eagle Valley and Vail 201
facilities plan study area.  We recognize the need to provide for im-
plementation of nonpoint source pollution controls in this area and,
given adequate public involvement in development of the recommendations,
we will, to the best of our abilities and within jurisdictional authori-
ties, pursue the  implementation of the study recommendations. The local and
County governmental jurisdictions of Eagle County, Town of Vail and Town
of Minturn will consider implementation of recommended nonpoint source
controls  in action before  the appropriate elected policy body.  We recog-
nize  that failure to institute  nonpoint source  pollution controls may
jeopardize the attainment  and maintenance of water quality goals for the
area  as well-as-~the effectiveness of wastewater  treatment  improvements.
 Terrel  J.  Minger                        £S  V\Johj£A. Green
 Town Manager                               / Rqyronal Administrator
 Town of Vail                                    EPA Region VIII

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                                89
                            JOINT AGREEMENT
     The Environmental Protection Agency issued a draft environmental
impact statement (EIS) on the Upper Eagle Valley and Vail Wastewater
Facilities Plan in April, 1977.  This EIS recognized, through a very
generalized evaluation, the potential significance of nonpoint pol-
lution in the study area.  Comments received from the North West
Colorado Council of Governments 208 coordinator, the Eagle County Plan-
ning Commission, and the Eagle County Board of County Commissioners
indicated further assessment of the nonpoint pollution problem is needed
to provide an integrated water quality management plan.  As a result
of these concerns, EPA is proposing to fund a nonpoint pollution study
including a recommended plan for implementation for the 201 study area.
This study should be managed by a team of representatives from Eagle
County, the North West Colorado Council of Governments, the Town of
Vail, the Town of Minturn, the Upper Eagle Valley Sanitation District,
the Vail Water and Sanitation District, the Colorado 208 Executive
Committee, and the Environmental Protection Agency.

     The undersigned hereby agree to provide active participation in
the management of a nonpoint source pollution study leading to a recom-
mended plan of implementation for the Upper Eagle Valley and Vail  201
facilities plan study area.  We recognize the need to provide for im-
plementation of nonpoint source pollution controls in this area and,
given adequate public involvement in development of the recommendations,
we will, to the best of our abilities and within jurisdictional  authori-
ties, pursue the implementation of the study recommendations. The local and
County governmental jurisdictions of Eagle County, Town of Vail  and Town
of Minturn will  consider implementation of recommended nonpoint source
controls in action before the appropriate elected policy body.  We recog-
nize that failure to institute nonpoint source pollution controls may
jeopardize the attainment and maintenance of water quality goals for the
area as well^a^tbe-effectiveness of wastewater treatment improvements.
Larry Burdick, President                   /  J«nn A/'Green
Vail Water & Sanitation                       yTtegional Administrator
  District                                      Region VIII

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                                    90
                         ^W&WVml&m&
                          EXECUTIVE  CHAMBERS
RICHARD O. LAMM

   Governor
                                      September 2,  1977
 Mr.  Alan Merson
 Regional Administrator
 Environmental  Protection Ayency
 1860 Lincoln
 Denver, CO  80203

 Dear Mr. Merson:

      This is in response to the letter of August 29,  1977,  from John Green
 regarding the  proposed study of nonpoint sources of pollution within the 201
 study area for the Upper Eagle Valley and the Vail  Wastewater Facilities study
 area.

      I  have signed and am returning the joint agreement attached to Mr.  Green's
 letter.  We share your concern over the present and potential impacts of develop-
 ment related nonpoint sources of pollution within this Upper Eagle Valley.
 The team effort proposed should provide for maximum opportunity for developing
 an effective,  implementable approach to controlling this problem.   From our
 perspective, it would seem appropriate to address nonpoint  source controls
 both in terms  of land use and development decisions and in  terms of remedial
 measures once  development is in place.

      This study effort is closely related to the 201  grant  program.  Therefore,
 we are asking  the Water Quality Control Division to represent the State on the
 management team.   This would enable the Division to relate  nonpoint source
 features with the wastewater facilities being proposed and  to coordinate those
 results with the activities of our 208 program.  In that regard, we need to
 be fully cognizant of the interrelationship of both point and nonpoint sources
 on water quality management and the need to proceed promptly with the facilities
 grants concurrent with this nonpoint source effort.

      I trust that this effort will be of particular importance to not only the
 Upper Eagle area_, but to other areas of Region 12 and the State.  Please have
 your staff contact,Gary Broetzman regarding any further needs on this matter.
                                      Sincerely,
                                                    V/-
                                             «..-.-
                                      JintyMonaghan, Chairman
                                      208 Executive Committee
 enclosure
          Water

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                            JOINT AGREEMENT
     The Environmental Protection Agency issued a draft environmental
impact statement (EIS) on the Upper Eagle Valley and Vail Wastewater
Facilities Plan in April, 1977.  This EIS recognized, through a very
generalized evaluation, the potential significance of nonpoint pol-
lution in the study area.  Comments received from the North West
Colorado Council of Governments 208 coordinator, the Eagle County Plan-
ning Commission, and the Eagle County Board of County Conmissioners
indicated further assessment of the nonpoint pollution problem is needed
to provide an integrated water quality management plan.  As a result
of these concerns, EPA is proposing to fund a nonpoint pollution study
including a recommended plan for implementation for the 201 study area.
This study should be managed by a team of representatives from Eagle
County, the North West Colorado Council of Governments, the Town of
Vail, the Town of Minturn, the Upper Eagle Valley Sanitation District,
the Vail Water and Sanitation District, the Colorado 208 Executive
Committee, and the Environmental Protection Agency.

     The undersigned hereby agree to provide active participation in
the management of a nonpoint source pollution study leading to a recom-
mended plan of implementation for the Upper Eagle Valley and Vail 201
facilities plan study area.  We recognize the need to provide for im-
plementation of nonpoint source pollution controls in this area and,
given adequate public involvement in development of the recommendations,
we will, to the best of our abilities and within jurisdictional authori-
ties, pursue the implementation of the study recommendations. The local and
County governmental jurisdictions of Eagle County, Town of Vail and Town
of Minturn will  consider implementation of recommended nonpoint source
controls in action before the appropriate elected policy body.  We recog-
nize that failure to institute nonpoint source pollution controls may
jeopardize the attainment and maintenance of water quality goals for the
area as well as the effectiveness of wastewater treatment improvements.
   !j •'          /     -
James Monaghan
Assistant to the Governor on              '  /RegyrfFal Administrator
  Natural Resources                             Region VIII

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                               93
Enclosure 2 - Nonpoint Source Assessment Program
              Scope of Services

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                                  94
                  UPPER EAGLE VALLEY NONPOINT SOURCE
                      ASSESSMENT AND CONTROL PLAN
1.  Objectives

  (1)  Detailed identification of existing non-point source
       problem areas within the Upper Eagle Valley.  For pur-
       poses of this effort, the following source categories
       will be considered: urban runoff, construction activi-
       vity  (highway and urban development) .highway runoff, mining
       activities.

  (2)  Detailed identification of potential non-point source
       problem areas within the Upper Eagle Valley.

  (3)  Development of site specific solutions for problems
       identified in objectives 1 and 2 needed to significantly reduce
       non-point source pollution and to meet water quality standards.

  (4)  A recormiended management system, model regulations and
       guidelines shall be provided to local governments for
       implementation of site specific solutions.

  (5)  Integration and program compatibility with water manage-
       ment and recreation objectives established for the area
       should be achieved.  (This includes minimum streamflow,
       groundwater quality and recharge and water supply systems;
       Example - Infiltration of runoff.)

  (6)  Public acceptance of recommendations of implementation pro-
       gram.

  (7)  Provide an assessment of existing land use policies and plans
       and provide recommended changes.

  (8)  Results from the program shall build on data and recommenda-
       tions of Northwest Colorado Council of Governments'  208 Plan.

2.  Scope of Work (Outline)

    TASK A - Preliminary  Investigation  and  Planning

         1.  Evaluate Existing  Data
         2.  Develop Water Quality  Monitoring  Program
         3.  Collect Water Quality  Data
         4.  Correlate Data  with  Published  Pollutant Loading Rates

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                               95
TASK B - Water Quality Problem Definition
     1.  Define Land Use/Water Quality
         Interface for Existing Problem
     2.  Define Land Use/Water Quality Interface for Future
         Development.
TASK C - Solution Definition and Assessment
     1.  Develop Potential Solutions to Nonpoint Pollution.
     2.  Assess Implications of Proposals
TASK D - Public Involvement
TASK E - Develop Final Recommendations

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                               97
Enclosure 3 - Letter to State of Colorado Regarding
              Transbasin Diversion Issue

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                                  98


        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                 U\ > ,l('tj VIII

                             IHI.O UN-: f H N si Ml F 1

                           DfNVtH (C.IOKAI.O I'fi.'f
Ref:  8W'EE
Mr. James Monaghan
Assistant to the Governor
  on Natural Resources
Office of the Governor
State Capitol
Denver, Colorado 80202

Dear Mr. Monaghan:

     This letter is to bring to your attention recent  correspondence
that EPA has received from the Northwest Colorado Council  of  Governments
concerning the importance of future hydrologic modifications  on  the
attainment and maintenance of water quality standards  in  that area.
The attached letter from Mr.  Phil Overeynder, 208 Coordinator for
NWCCOG, comments on the draft EIS for the Upper Eagle  Valley  and Vail
wastewater facilities plan.  Starting on page 7 of this letter,  the
potential impact of future water diversions is discussed.

     EPA agrees that the future trans-basin water diversion has  the
potential for degrading water quality on the Western Slope and there-
fore, may also reduce the effectiveness of federal and local  government
investments in wastewater treatment facilities.  Although  the extent
to which future trans-basin diversion, as well as future  in-basin
water use, will present a water quality problem on the Vail and  Upper
Eagle Valley area is unknown, the issue deserves greater  attention
on a statewide basis.  We also believe that federal agencies  must
evaluate to a greater extent, such impacts in funding or  approving
such projects.  Therefore, we recommend that the potential effects
of hydrologic modifications,  such as trans-basin diversions be given
high priority attention through your State Continuing Planning Process.
We believe that such attention should lead to effective state measures
to control and mitigate any adverse water quality effects of  proposed
hydrologic modifications.

     I would appreciate your careful consideration of this matter and
a response as to the level of attention that will  be given to this
area in developing the State  Water Quality Management Plans.
                                  incerely yours,
                                            ($6L*^	
                                   in A. Green
                                 Regional Administrator

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                               99
Enclosure 4 - Interim Policy on Field Surveys to
              Identify Cultural Resources

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                  UNIT ED STATES ENVmONMEWAL PROTECTION AGENCY ;
                                     inn             Program Guidance Memo  #52
                                                     (INTERIM  POLICY)
SUiSJF.CT:  Field Surveys to Identify Cultural Resources           DATE:
         Affected by EPA Construction Grants Projects
                                                                          2   $75
FROM:    John  T.  Rhett,  Deputy Assistant Administrator
         for Water Program Operations (WH-446)

         Sheldon Meyers, Director
         Office of Federal Activities  (A-104)

  TO:    Regional Administrators
         Regions I - X

         IWOSE.

              This memorandum sets forth Agency policy to guide decisions  in  the
         EPA Title II construction grants program on field surveys for the  purpose
         uf identifying historical, architectural, archaeological and cultural
         resources (nereafter referred to as "cultural resources") in accordance
         with the ''Procedures for the Protection of Historic and Cultural  Proper-
         ties" (16 C.F.R. Part 800.4(a)) issued by the Advisory Council on
         Historic Preservation.

         BACKGROUND

              Section 106 of the National Historic Preservation Act of 19fi6 anH
         fix'jcuti ve Order  11593  impose responsibilities on Federal agencies  tc
         consider t.Kc effects of Federal, federally assisted, and Federally
         liccnr.eu undertakings on properties included or eligible for inclusion
         in I he  National  Register of Hir-tO'-ic Places and to afford tne Advisory
         Council on  Historic Preservation an opportunity to comment on such
         undertakings.  The Advisory Council has  issued "Procedures for th?
         r'roiectir.n  of  Historic and Cultural Properties'  (3fi C.F.R. Part 300)  to
         ("iid°  ?.gc-ncies  in meeting their responsibilities unde1" the Act and the
         Executive Order.

               Several Regions  have raised guestions about EPA's specific reooav.si-
         bil-ities  for historic  preservation within the Grants program.  The c?.r.~
         t*-al  issue  is  as follows:  '-Ihat are  EPA's responsibilities for conducting
         fiel'i  surveys  to identify cultural resources under the procedures  of .h3
         Advisory  Council  on  Historic Preservation (30 C.F.R. Part 800.1(0)?
Rqs'jonsib'l ity to Conduct Field Surveys in Areas of Primary Effects Cnlv

     EPA has the responsibility to conduct field surveys to identify cjl -
tural resources that may be affected by vastewnter treatment grant projects
only in the primary impact areas of the grant projects.   Primary
                                                                .           impa
          are t.hose whsre ground will  be disturbed for the project, such as the o
          site, pumping station sites, access roads,  and
                                                                                  areas
 EPA FOLK ; 320.6 (I*,. *-72)

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                                   101
                                                  -    • • —  -'
Areas in which the wastewater treatment facilities will have direct visual,
odor, or aerosol effects may also be primary impact areas if they are likely
to contain cultural properties of a type which are susceptible to such  im-
pacts and if the proposed project has  been designed so as to be exposed to
view or will  emit odors or aerosols.

Use Standard of Probability

     In areas where there are likely to be orimary effects on cultural
resources, EPA must identify all properties  listed in  the National
Register of Historic  Places by consul tinq the  latest,  issue of the
National Register-,  including monthly supplements.  The current compi-
lation  is found in  the  Federal Register of February 4, 1975  (Federal
Register, Vol. ^0,  Mo.  24, pp. 5248 -  5345); sunolements are pub-
lished  in the Federal Register,  usually on the first  Tuesday of each
month.

     EPA must also  identify ?.ll  properties eligible for listing in  the
National Register within  the primary impact  area.  To  do this, EPA
shall consult v.-ith  the  State Historic  Preservation Officer  (SHPO) to
determine the extent .and  adequacy of existino  information.

     If existing  infonncition is  insufficient tc  identify affected
properties  that nay be  eligible  for the National  R Roister,  EPA shall
conduct or  fund cultural  resources  surveys at  a  level  adequate to do
so.  EPA's  --esDCPjihil ity  to conduct or  fund such surveys on primary
uncact  cress  ^hall  be limited  by the fci ".owing standard:  The extent
of  survey activities  should  be  bssed OP the  degree of probability with
.:h1cii cjitural  resources  con be  expected  to  be found.

      Intensive  surveys  should  be conducted only  when  a sufficient amount
of  information  exists to  indicate,  that there is  a reasonably high prob-
  ability of  discovering -Mmortart  cultural resources.   In areas where
such  information  does net  exist, seme  or  all of  the  following usually will
suffice to  determine  whethe1" an  •"Mtensivs  survey is  justified:  a
doc'.:rrfcn"?ry  search  of reference  nwterials  on the cultural  resources of
the area, a  walKover reconnaissance  survey  fcr  ;rci:aeolonical  properties,
~ond a  "windshield"  or photocir.ipli !.;  survey  of historic and  architectural
       Lies.
      When necessary,  intensive surveys may includp ground testing for
 archaeological  resources, or t'ic preparation of a comprehensive map
 locating historical  and architectural resources.  The information obtained
 from any identification activities conducted shall provide the basis for
 determinations  of eligibility for listing in the National Register in
 accordance with Part 800. 4(a) of the Advisory Council procedures.

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                                102

                                 3

Determine Eligibility of Survey  Costs  Case-hy-Case

     The decisions  as to what  are reasonable  survey  activities  and costs
should oe made on a case-by-case basis applying  the  standard of
probability described above.   Reasonable  costs  for  surveys  and  other
identification activities are  to be  considered  grant eligible.   Early
assessment of survey needs should be undertaken  to  avoid  project delays.
Many survey decisions will  require  some degree  of historical  or archaeo-
logical expertise in order to  weigh  the probabilities of  discovering
particular properties.   Regional  personnel  may  find  it advantageous to
retain the services of a historian  or  an  archaeologist if they  anticipate
numerous problems in this area.

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                                  103
                           DISTRIBUTION LIST

                  Final Environmental Impact Statements
      Upper Eagle Valley and Vail 201 Wastewater Facilities Plan
Federal Agencies

Regional Forester
U.S. Forest Service
Building 85, Denver
   Federal Center
Denver, Colorado  80225

Federal Highway Administration
Building 40, Denver Federal Center
Denver, Colorado  80225

State Conservationist
U.S. Soil Conservation Service
2490 West 26th Avenue
Denver, Colorado  80221
                                      Forest Supervisor
                                      White River National Forest
                                      U.S. Forest Service
                                      Glenwood Springs, Colorado
                                         81601

                                      Regional Director
                                      U.S. Department of Health,
                                         Education and Welfare
                                      9017 Federal Building
                                      Denver,  Colorado  80202

                                      Director  (18)2
                                      Environment Project Review
                                      U.S. Department of the Interior
                                      Office of the Secretary
                                      Washington,  D.C.   20240
1
2
             Council on Environmental Quality (5)
             722 Jackson Place, NW
             Washington, D.C.   20006

5 copies provided for Council on Environmental Quality
18 copies provided for Department of the Interior  Offices
State Agencies

Colorado Division of Planning (101
State Clearinghouse
1313 Sherman Street   Rm 520
Denver, Colorado  80203

Air Pollution Control Division
Colorado Department of Health
4210 East llth Avenue
Denver, Colorado  80220
                                      Water Quality Control Division
                                      Colorado Department of Health
                                      4210 East llth Avenue
                                      Denver,  Colorado  80220
   10 copies provided to State Clearinghouse for review by state agencies

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                                    104
                           DISTRIBUTION LIST

                  Final Environmental Impact Statements
      Upper Eagle Valley and Vail 201 Wastewater Facilities Plan
Federal Agencies

Regional Forester
U.S. Forest Service
Building 85, Denver
   Federal Center
Denver, Colorado  80225

Federal Highway Administration
Building 40, Denver Federal Center
Denver, Colorado  80225

State Conservationist
U.S. Soil Conservation Service
2490 West 26th Avenue
Denver, Colorado  80221
                                      Forest Supervisor
                                      White River National Forest
                                      U.S.  Forest Service
                                      Glenwood Springs, Colorado
                                         81601

                                      Regional Director
                                      U.S.  Department of Health,
                                         Education and Welfare
                                      9017  Federal Building
                                      Denver,  Colorado  80202

                                      Director  (18)2
                                      Environment Project Review
                                      U.S.  Department of the Interior
                                      Office of the Secretary
                                      Washington,  D.C.   20240
1
2
             Council on  Environmental  Quality (5)
             722  Jackson Place,  NW
             Washington, D.C.   20006

5 copies provided for Council  on Environmental  Quality
18 copies provided for Department of the  Interior  Offices
State Agencies

Colorado Division of Planning (10)
State Clearinghouse
1313 Sherman Street   Rm 520
Denver, Colorado  80203

Air Pollution Control Division
Colorado Department of Health
4210 East llth Avenue
Denver, Colorado  80220
                                     Water Quality Control  Division
                                     Colorado Department  of Health
                                     4210 East  llth Avenue
                                     Denver, Colorado   80220
   10 copies provided to State Clearinghouse  for  review  by  state  agencies

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                                 104
 Local Agencies

 Lee Woolsey, Executive Director
 Northwest Colorado Council of
    Governments
 Box 737
 Frisco, Colorado  80442

 Mr. Erik Edeen
 Eagle County Sanitarian
 Eagle, Colorado  81631

Town of Red Cliff
c/o Mr. Bob Manzanares, Manager
Vail, Colorado  81657
                       Town of Eagle
                       Eagle, Colorado
Eagle County Commission
c/o Mr. Mike Blair, Planning
   Director
Box 789
Eagle County, Colorado  81631

Town of Vail
c/o Mr. Terry Minger, Manager
Vail, Colorado  81657

Town of Minturn
c/o Mr. Bob Manzanares, Manager
Minturn, Colorado  81645
 81631
Interest Groups

Vail Associates, Inc.
c/o David Mott
Box 2076
Vail, Colorado  81657

Colorado Open Space Council
1325 Delaware Street
Denver, Colorado  80204

Rocky Mountain Center on
   Environment
4260 East Evans Avenue
Denver, Colorado  80222

Thorne Ecological Institute
2305 Canyon Blvd.
Boulder, Colorado  80302

Alfie Packer Chapter
Trout Unlimited
P.O. Box 98
Dillon, Colorado  80435

Colorado Wildlife Federation
P.O. Box 347
Boulder, Colorado  80302

Arrowhead at Vail
Box 1669
Vail, Colorado  81657
National Wildlife Federation
1412 16th Street, N.W.
Washington, D.C.  20036

Environmental Action Committee
1100 14th Street
Denver, Colorado  80202

Environmental Impact Assessment
   Project
1717 Massachusetts Avenue, N.W.
Washington, D.C.  20036

Environmental Defense Fund
Suite 1100, Capitol Life Center
1600 Sherman Street
Denver, Colorado  80203

Colorado Rivers Council
P.O. Box 1815
Aspen, Colorado  81611

Friends of the Earth
2239 East Colfax Avenue
Denver, Colorado  80206
Eagle-Vail
Box 1308
Vail, Colorado
81657

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                             105
Eco-Center Environmental Clearing House
835 Arapahoe Avenue
Boulder, Colorado   80302
                          Benchmark
                          Box 5
                          Avon, Colorado
                                                          81620
League of Women  Voters  of  Colorado
1375 Delaware,  #406
Denver, Colorado  80204

The Wilderness  Society
4260 East Evans  Avenue
Denver, Colorado  80222

Colorado Mountain  Club
1723 East 16th Avenue
Denver, Colorado  81218
John Vanderhoof
Club 20
Grand Junction, Colorado
Others

Conservation Library
c/o Denver Public Library
1357 Broadway
Denver, Colorado  80203

Vail Public Library  (3)
Town of Vail
Box 100
Vail, Colorado  81657
          81501
KVMT Radio
Box 1047
Vail, Colorado
81657
The Vail Trail
Vail, Colorado  81086
 Sierra Club
 1325 Delaware
 Denver, Colorado  80204

 Mr. Martin Sorensen
 Seven Spruce Canyon Cr.
 Route 2
 Golden, Colorado  80401

 Izaak Walton League
 108 Palisade Circle
 Manitou Springs, Colorado
   80329

New Zersey Zinc Co.
 Gilman,  Colorado  81634
Denver Board of Water
   Commissioners
144 West Colfax
Denver, Colorado  80202

Colorado State Library
1362 Lincoln Street
Denver, Colorado  80203

Colorado Mountain College
   Library
3000 114 Road
Glenwood Springs, Colorado
   81601

Eagle Valley Enterprise
Eagle, Colorado  81641

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