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:
S £ P " 0 > •
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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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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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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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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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Response to Soil Conservation Service
1. Your correction concerning crested wheatgrass has been
noted and the text changed accordingly.
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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.
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4
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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.
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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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, 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.
-------
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.
-------
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.
-------
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
-------
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.
-------
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
-------
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.
-------
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
-------
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
-------
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
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©
©
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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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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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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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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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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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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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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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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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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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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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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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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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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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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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)
-------
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
-------
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
-------
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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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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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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