EPA-908/5-77-004
    FINAL ENVIRONMENTAL IMPACT STATEMENT
    WATER QUALITY MANAGEMENT PLAN
    EL PASO and TELLER COUNTIES
                MAY, 1977
      UNITED STATES ENVIRONMENTAL PROTECTION AQENCY

                REGION VIII

           DENVER COLORADO 8O295

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                                  EPA-908/5-77-004
      FINAL  ENVIRONMENTAL IMPACT STATEMENT
      208 WATER QUALITY MANAGEMENT PLAN FOR

      EL PASO AND TELLER COUNTIES, COLORADO
Prepared by

U.S.  Environmental Protection  Agency
Region VIII        Denver, Colorado
Approved by
     u Green
Regional Administrator
May. 1977
Date

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                                                      .  EASTERN EL
                                                      V      >  *
WATER QUALITY MANAGEMENT
      PLANNING AREA

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                             SUMMARY SHEET
                    Environmental  Impact Statement
                 208 Water Quality Management Plan for
                 El Paso and Teller Counties, Colorado
                     EPA Project Number:  P 008070
               (   )   Draft                     ( X  )   Final


!•  Name of Action:   (X) Administrative       (  )  Legislative


2.  Description of Action:

    Pursuant to EPA policies, guidelines, and regulations under
    section 208 of the Federal Water Pollution Control  Act,  EPA ap-
    proval, conditional  approval, or disapproval  of water quality
    management plans is subject to NEPA review.   EPA has determined
    that its action on the Water Quality Management Plan for El  Paso
    and Teller Counties is a major Federal  action that  may have sig-
    nificant effects on the environment and that  an environmental
    impact statement is necessary in order to provide an opportunity
    for public review of EPA's decisions on plan  approval.  The for-
    mat of the EIS is unique in that it highlights  the  issues raised
    by the plan while incorporating, by reference to the plan itself,
    the basic information and analyses that normally constitute an
    EIS.  This unique approach is made possible by  the  water quality
    management planning process, which is designed  to incorporate and
    document all of the elements of an environmental  impact statement
    in the planning/decision-making process.

    The Water Quality Management Plan for El  Paso and Teller Counties
    makes recommendations regarding stream classifications and criteria,
    wastewater treatment facility needs, and the  regulatory/fiscal/in-
    stitutional programs to implement the plan.   The plan addresses
    the problems of point and nonpoint sources of water pollution
    in the two-county area.

    The water quality management plan is based on a projected population
    for the urbanizing area of 550,000 by the year  2000.  This compares
    to a 1976 estimated population of 304,000. Facility needs and
    feasibility studies were prepared for the two-county area based on
    these projections.  Numerous other recommendations  were  made which
    relate to septic tank operation and maintenance,  urban stormwater
    management, subdivision reviews, water quality  monitoring and
    enforcement of regulatory programs, and designation of management
    agencies to implement the plan.

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3.  Environmental Impacts;
A.  Growth Related Impacts
    (1)  Air quality modeling predicts an air quality standards vio-
         lations for three hour hydrocarbon and twenty-four hour par-
         ti culates by the year 2000.
    (2)  Natural ecologic systems and open space will be impacted.
    (3)  Neighborhood stability may be impacted.
    (4)  Noise pollution will increase.
    (5)  Need to reuse wastewater will increase.
    (6)  Raw water needs will increase the demand for western slope
         diversions.
    (7)  Demand for groundwater supplies will increase.
    (8)  Less water will be discharged to Fountain and Monument Creeks,
         resulting in smaller flows and slightly altering the visual/
         recreational characteristics of these streams.
    (9).  Need for other community services will increase (schools,  health
         care, police protection, transportation).
    (10)  Stormwater runoff will  increase.
B.  Wastewater Collection and Treatment Facility Related Impacts
    (1)  Water quality will be maintained and/or improved.
    (2)  Some construction will  occur in the flood plains.
    (3)  Provision of excess sewerage capacity may remove a growth  con-
         straint imposed by present lack of such service.
    (4)  Urban growth will tend to occur in areas providing sewerage
         treatment capacity.
                                    VI

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4.  Alternatives:
A.  Growth
    (1)  Infilling and satellite cities - moderate growth (550,000
         people by year 2000)
    (2)  Infilling and slow growth (365,000 people by year 2000)
    (3)  Satellite cities (550,000 people by year 2000)
    (4)  Current trends (550,000 people by year 2000)
B.  Wastewater Collection and Treatment Systems
    (1)  Large scale regionalization
    (2)  Subbasin regionalization
    (3)  Existing treatment configurations
    (4)  Reuse - agricultural, industrial, landscape, culinary/potable
         water supply
C.  Institutional Arrangements for Water Quality Management
    (1)  Status Quo
    (2)  Subbasin associations - joint exercise of powers agreement
    (3)  Contracts
5.  Distribution:
    Appendix B shows the agencies, groups, and individuals to whom
    this EIS is being circulated.
6.  Draft Statement Sent to Counci 1  on Eriyironmeiital  Qua! ity:
                  March 25, 1977
7.  Final Statement Sent to Council  on Environmental  Quality:
                  May 19,  1977
                                   Vll

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                           Table of Contents

                                                                  Page
Introduction	     1
EIS Format	     1
Pikes Peak Area Council of Governments Action	    5
State of Colorado Action 	   11
EPA Action	   15
Comments on Draft EIS and EPA Responses...	    27
                            List of Tables
Table I     Documents Incorporated in this EIS by
            Reference 	      3
Table II    Recommendations and Conclusion of the Water
            Quality Management Plan for El Paso and Teller
            Counties 	     7
Table III   Issues Related to the Water Quality Management
            Plan for El Paso and Teller Counties	   17
Table IV    Comments on Draft EIS and EPA Responses	    27
                          List of Appendices
Appendix A  Comment Letters Received by the Pikes Peak Area
            Council of Governments, and Responses 	    A
Appendix B  EPA Mailing List for Distributing the EIS	    B
Appendix C  Comment Letters Received by EPA 	   C

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                         List of Abbreviations

AQMA -      Air Quality Maintenance Area
AQMP -      Air Quality Maintenance Plan
EIS -       Environmental Impact Statement
EPA -       Environmental Protection Agency
NEPA -      National Environmental Policy Act
NPDES -     National Pollution Discharge Elimination System
PPACG -     Pikes Peak Area Council of Governments
PRPC -      Pueblo Regional  Planning Commission
IDS -       Total Dissolved Solids
TSS -       Total Suspended Solids
USGS -      United States Geological Survey
WQCC -      Water Quality Control  Commission  (State  of Colorado)
208 -       Section 208 of the Federal  Water  Pollution Control Act,
            which provides for the development of the water quality
            management plans.

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Introduction

Section 208 of the Federal Water Pollution Control Act provides for
water quality management planning on an areawide basis.  These area-
wide water quality management plans are designed to deal  with existing
or potential water quality problems of urban or industrial  complexes
and other areas.  The plan must address a number of functional aspects
of water quality management, such as estimating wastewater treatment
facilities' needs and development programs to control pollution from
dispersed or nonpoint sources.  Through a combination of technical
planning, intergovernmental coordination, and involvement by elected
officials and the public at large, the 208 planning process is de-
signed to give rise to water quality management plans that solve
water quality problems while being sensitive to air quality management
needs, land use planning, and other environmental  concerns.

EIS Format

This EIS does not use the standard EIS format which is normally used
by Federal agencies.  The reason for using a modified format is that
the water quality management plan developed by the Pikes Peak Area
Council of Governments (PPACG) includes the requirements of the National
Environmental Policy Act as an integral part of the plan.  This inte-
gration of the NEPA process with the water quality management planning
process is required by EPA regulations and guidelines.  Throughout the
two-year planning process, the Pikes Peak Area Council of Governments
utilized the NEPA process to evaluate the environmental impacts of
various alternatives which were under consideration.

EPA has a responsibility under NEPA to conduct an  independent, objective
evaluation of this plan before making a final decision.  EPA has com-
plied with this responsibility by participating with the Pikes Peak
Area Council of Governments in the development of the plan over the two-
year period.  While the recommendations in the plan represent the results
of a local decision-making process, EPA assigned staff personnel to
work with the Pikes Peak Area Council of Governments in an advisory capa-
city throughout the two-year planning period.

Since the NEPA requirements were integrated into the planning process
and EPA personnel participated in the development  of the plan, EPA does
not consider it necessary to prepare a separate EIS document in the
standard EIS format.  Hence, this EIS consists of  the following docu-
ments:

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     1.  A summary of the significant environmental issues and EPA's
         recommended course of action (see Table III).  This is the
         document you are now reading and was prepared by EPA.

     2.  A summary of the plan prepared by the Pikes Peak Area Council
         of Governments entitled "Areawide Water Quality Management Plan
         for El Paso and Teller Counties," and November 23, 1976,
         Addendum.

     3.  A document entitled "Options for the Future:  What Do They
         Mean?" (PPACG, February 27, 1975), which presents the land
         use alternatives considered in the plan.

     4.  A report entitled "Environmental  Resources Study:  Summary
         Report," prepared by PPACG.

The complete water quality management plan prepared by the PPACG con-
sists of several reports.  All  of these reports are incorporated by
reference as part of the EIS and should be consulted for further de-
tailed information.  Complete copies of the plan (including all  volumes)
are available for public use at the EPA Region VIII Library, 1860
Lincoln Street, Denver, and at the offices of the Pikes Peak Area Council
of Governments, 27 East Vermijo Street, Colorado Springs.   The water-
quality management plan consists of more than seventy reports, working
papers, etc.   The most important documents for the purposes of this
summary are itemized in Table I.

Other documents that EPA has used in its evaluation of the plan  are
listed below:

     *   Preliminary Evaluation of Water Quality of Proposed Fountain
         Lake, Colorado.  U.S.  Army Corps  of Engineers.   November, 1976.

     *   Stream Segment Analysis (draft report).   Pueblo Regional  Plan-
         ning Commission.  December, 1976.

     *   Biological Inventory of Pueblo Waterways.   Pueblo Regional
         Planning Commission.   December, 1976.

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                                TABLE I

            Documents Incorporatedjri This EIS by Reference


 1)  Areawide Water Quality Management Plan for El  Paso and Teller
     Counties.  August, 1976

 2)  Addendum to the Areawide Water Quality Management Plan for Teller
     and El Paso Counties.  November 23, 1976

 3)  Options for the Future:  What Do They Mean?  February 27,  1975

 4)  Environmental Resources Study for Teller and El  Paso Counties,
     Colorado.  1974

          Part A.  Perspective
          Part B.  Geology
          Part C.  Vegetation
          Part D.  Wildlife Hazard
          Part E.  Wildlife Appendices
          Part F.  Visual  Resources
          Part G.  Climate and'Design
          Part H.  Environmental  Hazards,  Constraints, and Limitations

 5)  Year 2000 Air Quality in the Pikes Peak Region.   April  12,  1976

 6)  Recommendations for Stream Classifications - Fountain/Monument
     Subbasin (Including Results of  Aquatic Sampling).   August,  1975*

 7)  An Evaluation of Waste Treatment Regulatory Practices.

 8)  Comments on Draft Plan and'Responses.

 9)  Water Quality Management Plan for Stratmoor Hills Sanitation
     District.  August, 1976.

10)  Facility Plan for Wastewater Reuse Applications  in the  Town of
     Calhan, El  Paso County, Colorado.  July, 1976

11)  Security Sanitation District Facilities Plan.  July,  1976

12)  Fountain-Widefield Wastewater Study.   September,  1976

13)  Solids Residuals Plan.   August, 1976

14)  Wastewater  Facility Study for Victor  and Cripple  Creek, Colorado.
     September,  1976          •

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15)  Wastewater Facility Plan  for  Florissant  and Divide, Colorado.
     September, 1976

16)  Facility Plan for Wastewater  Reuse Applications  in the Upper
     Monument Creek Area, El Paso  County, Colorado.   September, 1976

17)  Alternative Population  and  Employment  Forecasts, El Paso County
     1980-2000, Detail  Report.   1976

18)  An Evaluation of Alternative  Wastewater  Management Systems -
     Constraints and Opportunities.  December,  1975

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Pikes Peak Area Council of Governments Action

In May of 1974 the Pikes Peak Area Council  of Governments was desig-
nated a water quality management planning agency by the Governor of
Colorado and provided $955,000 in EPA Section 208 planning funds to
develop an areawide water quality management plan for El  Paso and Teller
Counties.  The two-year project was given the name Project Aquarius.
The planning effort involved extensive technical  analyses and public
involvement, and it resulted in several  recommendations for water quality
management.  The major recommendations of the plan are summarized below,
and the planning documents which are incorporated in this document by
reference are cited in Table I.

     1)  The plan recommends that a total of $82,022,000 (1976 dollars)
         be spent to construct municipal  wastewater treatment facilities
         and improvements through the year 2000.   Of this amount,
         $32,052,000 are needed in order to meet the 1983 water quality
         goals identified in Table 3 of the November 23,  1976, Adden-
         dum to the plan (pages 15-16).   (For a detailed discussion
         of these wastewater treatment needs see Chapter VI, pages
         177-227, and pages 300-301 of the  main report:   "Areawide
         Water Quality Management Plan for  El  Paso and Teller Counties."
         These needs are also discussed in  the November 23, 1976,
         Addendum to the plan.)

     2)  The plan recommends changes in the majority of the present
         State stream classifications in  the two-county area.   The most
         significant change is for Fountain Creek from its confluence
         with Monument Creek to the El  Paso County line.   For this stream
         segment, the plan recommends exemption from the  chlorine residual
         and unionized ammonia limitations  required by the present class-
         ification of the stream for fish life.  The recommendation is
         based on the plan's conclusion  that habitat conditions in this
         reach of Fountain Creek are not  suitable for aquatic life because
         of natural  conditions and low flows due  to diversions for
         agricultural and municipal uses.  (Further discussionof this:
         subject is contained in:   (1)  Chapter IV, pages  155-176 of
         "Areawide Water Quality Management Plan  for El  Paso and Teller
         Counties;"  (2) Table 3, pages  15-16»  of the November 23, T976V-
         Addendum to the plan; and (3)  "Recommendations  for Stream^Classr
         ification and Results of Aquatic Sampling - Fountain/Monument-
         Subbasin.")

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      3)  The plan  recommends designation of six point source management
         agencies'  to carry out the function of Section 208 (c)(2) of
         the Act and recommends agencies for designation in other
         functional aspects of water quality management.  The point source
         management agencies or associations are consolidations of several
         existing  local entities based on general hydrologic subbasins
         in the two-county area.  (The agencies are identified and the
         recommendations are discussed in greater detail in Chapter III,
         pages 124-139, and Chapter VIII, pages 235-241 of the "Area-
         wide Water Quality Management Plan for El Paso and Teller
         Counties.")

      4)  The water quality management plan concludes that water quality
         problems resulting from silviculture, mining, agriculture,
         and construction are not significant in Teller and El Paso
         Counties.  The plan recommends that nonstructural  "best manage-
         ment practices" be implemented to control pollution resulting
         from urban runoff and septic tanks.  (These conclusions are
         discussed in more detail  in Chapter II, pages 54-76, and Chapter
         VII, pages 229-234 of the "Areawide Water Quality Management :
         Plan for El Paso and Teller Counties.")

Other recommendations and conclusions of the plan are summarized in
Table II of this report.
Throughout the two-year plan development period, the PPACG staff con- '
ducted an extensive public participation program.  Highlights of this
program were three all-day workshops, which were scheduled at key decision
points during the 208 project.  These workshops were well  attended by
elected officials, public officials, and other interest groups.  A
similar series of thirteen neighborhood meetings was held  durinq the
month of March, 1975, to consider the impacts,of the land  use and growth
alternatives that were proposed for use in Project Aquarius.   In addi-
tion to the workshops and neighborhood meetings, three local  and one
state advisory groups were formed to advise the,208 staff  on  technical
and policy issues.  Twenty letters commentingion the draft plan were.
received by the PPACG (see Appendix A).

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                                TABLE II

     Recommendations and Conclusions of the Water Quality Management
                     Plan for El Paso and Teller Counties
The following table summarizes the recommendations and conclusions of the
208 plan.  The reference after each Item refers to the documents listed 1n
Table I of this EIS.
1.  Finalize the formation of point source management agencies (Reference 1,
    pages 235 - 236).

2.  Implement the plan's recommended stream classifications and criteria
    (Reference 1, pages 172 - 176, 290).

3.  Change the State's criteria for setting priorities for construction
    grant funds (Reference 1, pages 219 - 220, 282 - 291, 300 - 301).

4.  State should adopt plan's recommendations for permits (Reference 1,
    page 224)°.

5.  National Pollution Discharge Elimination System (NPDES) permits should
    specify a fecal col 1 form limitation consistent with A or B stream
    classification requirements (Reference 1, pages 170, 176, 186, 189, 297),

6.  Local review and evaluation of all newly issued and reissued permits
    (Reference 1, page 290).

7.  Colorado Springs dispose of sludge at Hanna Ranch site and seek
    related improvements at the Las Vegas Street wastewater treatment
    plant (Reference 1, pages 224 - 225 and Solid Residuals Plan, PPAC6,
    August 1976).

8.  General purpose governments adopt the "Stormwater Criteria Manual"
    (Reference 1, page 296).

9.  State should develop a stormwater policy (Reference 1, page 232).

10. Local entitles should improve stormwater housekeeping practices
    (Reference 1, page 233).

11. State should update list of "Identified Areas" not suitable for septic
    systems (Reference 1, page 286).

12. City/County Health Department should modify existing septic tank
    regulations to include a 5 year permit and also institute a post-
    installation inspection program (Reference 1, pages 286, 294, 296).

13. Expand the City/County Health Department's staff to Include a sani-
    tary engineer for purpose of reviewing adequacy of wastewater design
    during subdivision review (Reference 1, page 296).

                                    7

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14. Transfer responsibility for compliance monitoring from the State
    to the City/County Health Department (Reference 1, page 290).

15. Counties and cities should amend building codes and subdivision
    regulations to Include water quality component for subdivision
    reviews including requirements for building moratoriums 1f facil-
    ities are at 90% capacity (Reference 1, pages 292, 294).

16. General purpose government should adopt grading ordinances
    (Reference 1, pages 74, 297).

17. Water Quality Advisory Committee should develop a budget and a means of
    payment for the local share of continuing 208 planning (Reference 1,
    page 270).

18. State should contract with City/County Health Department for moni-
    toring and laboratory services (Reference 1, page 293).

19. State/locals should continue monitoring of ambient stream quality,
    wells and septic tanks (Reference 1, pages 75, 232, 243, 293, 296).

20. Colorado Springs should amend contracts and building codes require-
    ments to comply with EPA pretreatment, user charge, and industrial
    cost recovery regulations (Reference 1, pages 268, 293).       °

21. PPACG should obtain ratification of plan as an element of local com-
    prehensive plans and capital Improvements budget (Reference 1, pages
    299, 370).
22. State should define "significant discharger" for variety of non-
    point source categories (Reference 1, page 294).

23. State should modify NPDES self-monitoring requirements for smaller
    communities (Reference 1, page 297).

24. Counties should develop and Issue guidelines (regulations) for con-
    trolling the proliferation of new special districts (Reference 1,
    page 291).

25. Copies of NPDES self-monitoring reports should be sent to the 208
    planning agency (Reference 1, page 293).

26. Codification of all Colorado Revised Statutes and Regulations pertain-
    ing to water pollution control (Reference 1, page 290).

27. State should rewrite solid waste regulations to eliminate conflicts
    with local regulations and provide better definition of roles between
    the two levels of government (Reference 1, page 295).

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28. State should revise guidelines and regulations pertinent to evapora-
    tive lagoons (Reference 1, page 295).

29. State should develop agricultural Best Management Practices (Reference 1,
    page 292).

30. Funding sources for the development of Individual farm management
    practices plans are recommended (Reference 1, page 292).

31. U. S. Forest Service should Increase funding for maintaining recreational
    forests (Reference 1, page 232).

32. Pikes Peak Forest District should develop solution to lack of sani-
    tary facilities on hiking trails (Reference 1, pages 66, 232).

33. HB 1041 should be used to designate mining Impact areas as areas of
    State Interest.  Develop appropriate regulations and require permits
    to be Issued by counties (Reference 1, pages 292 - 293).

34. The State should modify the proposed "Rules for the Disposal of Mine,
    Mill, and Mineral Processing Wastes" to Include A-95 review of all
    applications received by the State (Reference 1, page 295).

35. State should assume responsibility for planning/enforcement activ-
    ities relative to orphan and active mines, as well as future mining.
    (Reference 1, page 296).

36. Municipalities and Districts should review rate structures for non-
    potable wastewater (Reference 1, page 270).

37. EPA should fund wastewater re-use schemes (Reference 1, page 227).

38. Locals should re-use wastewater for landscape Irrigation and indus-
    trial purposes (Reference 1, pages 226 - 227).

39. Soil Conservation Districts should be included 1n review of proposed
    subdivisions and included as members of the Pikes Peak 208 Water
    Quality Advisory Committee (Reference 1, page 231).

40. General purpose government should encourage growth in those areas where
    service already exists (Reference 1, page 291).

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State of Colorado Action

EPA's regulations governing the water quality management planning
process require that areawide 208 plans be submitted to the Governor for
review and certification (40 CFR Part 131.20).  On August 5, 1976, the
Pikes Peak Area Council of Governments submitted their plan to the
Governor for review and certification.  On February 7, 1977, after
careful review of the plan by State agencies and advisory groups with an
interest in water quality management, the State conditionally certified
that the plan was consistent with 40 CFR Part 131, the regulations gov-
erning the preparation and content of water quality management plans, and
that the plan could adequately serve as the State's official water quality
management plan for El Paso and Teller Counties.  This certification was
conditioned on resolution of ten issues that were raised during the State
review process.  These conditions are summarized below:

     1)  Stream Classification.  The State agreed to the exception re-
         quested by the plan only for the segment of Fountain Creek
         below the Colorado Springs wastewater treatment plant.  The
         State's position on the upper part of the stream segment (i.e.,
         Fountain Creek from its confluence with Monument Creek down
         to the Colorado Springs wastewater treatment plant) is that
         it should remain classified for fisheries and that the present
         water quality criteria should remain in effect.  (Under
         Colorado's water quality statutes only the Water Quality Con-
         trol Commission has the authority to change stream classifica-
         tions and water quality criteria, and all such changes must
         be submitted to a public review process, including formal
         hearings.  Because of these legal requirements, the Water
         Quality Control Commission must act to fulfill this condition.)

     2)  Sludge Handling Facilities.  Recognizing that sludge disposal
         at the Colorado Springs wastewater treatment plant is one of
         the most serious and immediate point source problems in the
         two-county area and a major contributing factor in the need for
         stream classification and water quality criteria exceptions, the
         State conditioned certification of the 208 plan on improved
         sludge handling receiving highest priority action on the part
         of EPA, the State, and the local  water quality management agency.
         The 208 plan's recommendations for sludge disposal include im-
         mediate upgrading of the sludge handling facility at the Colorado
         Springs wastewater treatment plant and future land disposal at
         the Hanna Ranch site.  At Hanna Ranch, the sludge would be used
         for growing agricultural crops and generating electric power at
         the R. D. Nixon power plant, which is under construction.

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3)  Effluent Monitoring.  Following completion of the sludge    ,
    handling facilities discussed above, the State desires that
    a two-year effluent monitoring program be initiated at the
    Colorado Springs wastewater treatment plant in order to deter-
    mine whether or not better than secondary treatment is needed
    in order to meet water quality goals in Fountain Creek.  As
    long as the problem of sludge disposal at this facility con-
    tinues, the need for advanced wastewater treatment cannot be
    evaluated.  The principal source of the necessary data would
    be the self-monitoring program required under the present
    National Pollution Discharge Elimination System (NPDES) permit.

4)  Stream Monitoring.  Following completion of the sludge handling
    facilities discussed in Condition #2, the State also desires
    a two-year stream monitoring program to gather the data needed
    in order to evaluate stream conditions and form a basis for
    making decisions on long-term water quality goals for Fountain
    Creek and the need for advanced treatment at the Colorado
    Springs facility.  The monitoring program will be a joint state/
    local effort and will  concentrate on stream conditions during
    biologically critical  times of the year.

5)  Re-evaluation of Stream Classification arid Water Duality
    Cri teria Exceptions^  Pursuant to the proposed "Water Quality
    Standards for Colorado" and EPA regulations on water quality
    standards revisions (40 CFR Part 130; see also Chapter 5
    of the State Water Quality Management Handbook), the State
    will  require a schedule for re-evaluating all  exceptions
    recommended by the plan.   This condition requires that the
    re-evaluation be aimed at upgrading or restoring water quality
    in Lower Fountain Creek to the extent that it is technically
    and economically feasible, rather than relying on continued
    criteria exceptions.

6)  State Action on Stream Classifications and Water Quality
    Criteria.This condition identifies the factors that  the
    Water Quality Control  Commission  will  consider in their de-
    cisions regarding recommended changes in stream classifications-
    and water quality criteria.   They are:

         a)  Recommendations  of the 208 plan;

         b)  Testimony presented at public hearings;

         c)  Recommendations  and requirements  of the 208 plans
             for adjoining regions;  and

         d)  Requirements  of  appropriate Federal  laws  and.regulations.
                              12

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     7)  Priorities for Construction Grants.  This condition specifies
         that the wastewater treatment facility priorities recommended
         in the 208 plan for using EPA grant funds to construct waste-
         water treatment facilities will be considered by the State
         Water Quality Control Commission in carrying out its authority
         to set priorities for such grants throughout the state.

     8)  Population Projections.  The State conditionally certified the
         208 plan pending resolution of differences between the State's
         growth projections for the two-county area and the projections
         used in formulating the plan.  This condition calls for a
         resolution of the technical and policy differences on population
         growth and development of mutually acceptable growth projections
         within one year.  In the meantime, the design capacities of
         wastewater treatment facilities submitted for grants assistance ..
         will be scrutinized for compatibility with State growth policies 1
         and projections.

     9)  Management Agency for'Upper Fountain Subbasin.  The State
         rejected the 208 plan's recommendation that both El Paso
         County and Green Mountain Falls be designated as point source
         management agencies for the Upper Fountain Creek Subbasin.
         This condition requires that a single agency be recommended
         for designation within one year.

    10)  Local Ratification of 208 Plan.  The state conditioned its
         certification of the plan on presentation of the plan to the
         appropriate local  units of general purpose government for
         ratification as an element of their respective comprehensive
         plans.  This action is to be completed within six months of
         EPA's approval of the plan.

In the State's conditional  certification of this plan, the Governor
also designated five of the six point source management agencies recommended
in the plan (see condition  #9) and designated the Pikes Peak Area
Council of Governments as the continuing water quality management planning
agency for El Paso and Teller Counties.  The State did not specifically
designate management agencies for land use review and nonpoint sources;
thus, the current situation will continue with general purpose gov-
ernment exercising control  over these sources.
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EPA Action

EPA's approach to review and approval  of water quality management plans
stems from the Agency's regulations, 40 CFR Part 131.21.   Under these
regulations EPA has three options:

     1.  Plan approval, or certification that the elements required
     of a 208 plan pursuant to 40 CFR Part 131.11(a) - (p) have been
     fully satisified and no more work is needed to complete the
     plan;

     2.  Conditional approval, which amounts to a determination that
     the requirements of 40 CFR Part 131.11 (a) - (p)  have not been
     fully satisfied, and identifies the steps that the planning
     agency must take in order to achieve full approval if its plan;
     and

     3.  Disapproval, or a determination that the agency has not and
     will not satisfy the requirements of EPA's regulations on plan
     content or the conditions of the approved work plan.

The significance of 208 plan approval  lies in the fact that Congress
created the 208 planning process to be the primary mechanism for (1)
identifying treatment needs and establishing priorities for Federal
assistance in the construction of wastewater treatment facilities,
(2) developing the institutional and financial arrangements needed
in order to meet the water quality goals of the Federal Water Pollution
Control Act, and (3) controlling pollution that arises from dispersed,
or non-point sources.  Section 208 of the Act prohibits EPA from making
grants for construction of publicly owned treatment works  to management
agencies that are not approved and designated pursuant to the 208 plan;
no EPA grants for publicly owned treatment works may be made for pro-
jects that do not comply with the plan; and no National Pollutant Dis-
charge Elimination System (NPDES) permits may be issued if they are
in conflict with the plan.

EPA has determined that its decision regarding approval, conditional
approval, or disapproval of this 208 plan constitutes  a major Federal
action that falls in the category of actions subject to review under
Section 102(2)(c) of the National Environmental Policy Act.  Furthermore,
EPA has determined that the 208 plan for El Paso and Teller Counties
meets the criteria for mandatory preparation of an environmental im-
pact statement pursuant to EPA regulations for the preparation of en-
vironmental impact statements (40 CFR Part 6.510).  Approval of the
plan may contribute to significant changes in land use and patterns of
growth; it may have adverse effects on parklands, open space, and lands
of significant recreational, scenic, archaeological and historic value;
and it may directly or Indirectly have an adverse effect on local ambi-
ent air quality, local ambient noise levels, and the amount and quality
of both surface and subsurface water resources.  Thus, this EIS is being
prepared and circulated for review 1n order to focus on the significant
issues raised by the plan and provide an opportunity for public comment
before EPA makes Its final decision on plan approval.


                                   15

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The PPACG was one of the first agencies 1n the country (May, 1974) to be
designated by a State to prepare a 208 plan 1n accordance with the Fed-
eral Water Pollution Control Act.  The PPACG developed the 208 study over
the two-year period 1n accordance with a "work plan" which EPA approved
at the beginning of the planning process.  EPA has determined that the
208 plan submitted by the PPACG does fulfill the grant obligation as
Identified 1n the "work plan."

The PPACG planning process was well underway by the time the EPA regula-
tions (40 CFR Part 131, dated November 28, 1975) for the 208 program
were finalized.  As a result, neither the "work plan" nor the final 208
plan submitted by the PPACG completely reflected all of the requirements
of the EPA regulations.  EPA has reviewed the 208 plan to determine how
well the plan complies with the requirements specified in the EPA regu-
lations (40 CFR Part 131).  However, EPA has used a reasonable, rather
than a strict, application of the regulations in view of the discrepancy
between the time the plan was initiated and finalization of the EPA regu-
lations.

Issues related to the Water Quality Management Plan for El Paso and Teller
Counties are presented in Table III.  This table summarizes the issues;
presents the proposed EPA action for each issue; and outlines the ratio-
nale for the proposed EPA action.  EPA will, by reference, include 1n its
approval all the conditions enumerated in the State's certification letter
(see prior discussion under "State Action" for details of the State's con-
ditions).  Elements of the plan which EPA proposes to approve are:

     1.  Planning boundaries  (40 CFR 131.11(a))

     2.  Point source inventories  (40 CFR 131.11(c))

     3.  Industrial waste treatment needs (40 CFR 131.11 (1))

     4.  Residual waste control needs (40 CFR 131.11(k))

     5.  Urban and industrial stormwater system needs (for developing
         areas only)  (40 CFR 131.11(1))

     6.  Management agencies (for point sources only as designated by
         the State)  (40 CFR 131.11(o))
                   -X
The PPACG will be developing a new work plan to continue the planning
and Implementation activities specified in the 208 plan.  This work plan
will be submitted to EPA and the State for approval.  Frequent reference
is made to this new work plan 1n Table III.  It 1s EPA's Intent to use
the work plan as the basis for PPACG receiving continuing 208 funding.
                                    16

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                                    TABLE III
                  Issues Related to the Water Quality Management
                        Plan for El Paso and Teller Counties
Statement of the Issue
EPA's Recommended Action and Rationale
A.  The plan recommends and the State
    has granted temporary exceptions
    for un-1on1zed ammonia (NHs) and
    chlorine residual for municipal
    effluents 1n a segment of Foun-
    tain Creek below the Colorado
    Springs wastewater treatment
    plant discharge.  Included 1n
    this exception is a lowering of
    the instream dissolved oxygen
    standards from 5 mg/1 to 4 mg/1.
    The Pueblo 208 agency, their ad-
    visory committee, the Pueblo
    Planning Commission and Council
    of Governments, the Fountain
    Creek Commission, and the Colo-
    rado Open Space Council have all
    objected to these exceptions
    based on their possible effect
    on the proposed Corps of Engi-
    neer's Fountain Creek Reservoir,
    1n particular and Fountain Creek,
    in general.
EPA's Recommended Action:

1.  Conditionally approve the 208 plan
by accepting the State's Condition
Number 6.  Also request that the State
Water Quality Control Commission (WQCC)
give Fountain Creek a high priority
for reelassiflcation.

2.  If Fountain Creek 1s reclassified
require a re-evaluation within three (3)
years as mandated by EPA regulations.

Rationale:

1.  The objective of 208 as conveyed to
PPACG by EPA was to evaluate the.attain-
ability of the 1983 fishery and body con-
tact goals as set forth in the Federal
Water Pollution Control Act.  Attain-
ability was defined as attainment of both
water quality suitable for the specified
use, as well as attaining the use.

2.  Based on the above criteria PPACG,
after sufficient investigation, con-
cluded that although water quality
could be attained for a fishery, the
actual use of the stream as a fishery
could not be attained.  This is the basis
for PPACG requesting the exceptions.

3.  EPA requires by regulation that all
exceptions be re-evaluated every three
(3) years.

4.  The report:  "Preliminary Evaluation
of Water Quality of Proposed Fountain
Lake, Colorado" prepared by the U. S.
Army Corps of Engineers concludes that
nutrients, mercury, and col1 form are
the only potential water quality pro-
blems associated with the proposed reser-
                                        17

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                                           voir.  A letter has been sent to the
                                           Corps requesting clarification on the
                                           affects these exceptions will have on
                                           the proposed reservoir.

                                           5.  The draft report:  "Stream Segment
                                           Analysis" prepared by the Pueblo Regional
                                           Planning Commission (PRPC) indicates that
                                           from a water quality viewpoint the Foun-
                                           tain Creek in Pueblo County has suffici-
                                           ent quality to support a fishery although
                                           the water quality data show several
                                           parameters exceeding the recommended cri-
                                           teria for aquatic life (e.g. un-ionized
                                           ammonia, arsenic, mercury, cadmium, lead,
                                           IDS, and TSS).

                                           6.  The final report "Biological Inven-
                                           tory of Pueblo Waterways", December 1,
                                           1976, prepared by Southern Colorado
                                           University for PRPC concludes that
                                           Fountain Creek could not support a
                                           fishery due to a lack of suitable habi-
                                           tat and food supply.  This report re-
                                           commends that Fountain Creek be used as
                                           an agricultural stream.

                                           7.  The Water Quality Control Commission
                                           has the responsibility to reclassify the
                                           streams of the State.  No official action
                                           has been taken by the WQCC to reclassify
                                           lower Fountain Creek from B2 to A2~C as
                                           recommended by the plan.
B.  The report "Year 2000 Air Qua-
    lity in the Pikes Peak Region"
    indicates that the EPA primary
    standards for three (3) hour
    hydrocarbon and twenty-four
    (24) hour particulates will be
    violated if the population
    growth projections used by the
    PPACG are realized.  Increased
    degradation would be likely for
    NOX and S02.   EPA policy states
    that a 208 plan cannot be ap-
    proved if its implementation will
EPA Recommended Action:

1.  EPA will not participate in the fund-
ing of any construction (Step 3) of
wastewater treatment plant expansions in
the affected air quality areas until the
air quality studies are completed.  This
would affect Fountain (priority 145) and
Security (priority 164) as they are due
for expansion; but they are not high
enough on the State's priority list to
receive EPA funds during this fiscal year.

Note:  The Air Quality Maintenance
Area consists of El Paso County only.
                                       18

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result 1n air quality standards
violations.  The issue is one of
growth (I.e. to what extent would
the 208 plan, particularly the
provision for expanded sewerage
service, contribute to this
growth).  Air quality modeling
efforts in other metropolitan
areas have concluded that the
actual on-ground location of
this growth is not the critical
factor in air quality degradation
but that total size of'the growth
and resultant population is the
determining factor.  The under-
standing of the causes of air
quality problems in Colorado
Springs will be expanded by the
completion of the Air Quality
Maintenance Plan in 1978 and 1979.
2.  The sewerage system expansion aspects
of the 208 plan would be conditionally
approved pending the results of the air
quality studies.  These studies may
result in revisions to the size of
sewage plant expansion and in other
mitigating measures aimed at air
quality protection.

Rationale:

1.  The Pikes Peak area has been de-
signated as an Air Quality Maintenance
Area (AQMA) for which an Air Quality
Maintenance Plan (AQMP) for particu-
lates is to be prepared.  The AQMP is
scheduled for completion during the
summer of 1978, and will evaluate the
effects of the proposed growth (550,000
by year 2000) on air quality, also.

2.  The number of data points used to pre-
pare the Year 2000 Air Quality Report and
recent advances in air quality modeling
may require major modifications of the
work done to date.  Modeling to date shows
a continued worsening of particulate air
quality through 1986.  This situation can
be expected to continue beyond 1985 if
mitigating measures are not implemented.

3.  Discussions are being held with PPACG
to develop a "Transportation Control
Plan."

4.  EPA has drafted for publication in the
Federal Register a request that the State
Implementation Plan for Colorado Springs
be revised for carbon monoxide.  An AQMP
for carbon monoxide will be due in
January 1979.

5.  The significant wastewater treatment
plants scheduled for expansion are Secur-
ity and Fountain.  Neither community has
a high priority for receiving EPA grant
funds on the State's 11st (priority num-
bers 164, 145 respectively).

6.  Conclusion:  EPA is not certain whether
the existing and proposed population will
result 1n air quality violations if
appropriate mitigating measures are
implemented.
                                    19

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C.  The Colorado Division of Plan-
    ning has projected year 2000 popu-
    lation projections ranging from
    397,000 to 484.852 for the 208 study
    area Including Park County.
    This compares to the plan's pro-
    jection of 573,000 for the two
    county area excluding Park
    County.  Total population growth
    and Its on-the-ground location
    1s critical to the future envi-
    ronmental quality of the area.
EPA's Recommended Action:

1.  EPA will conditionally approve the 208
plan based upon a resolution of the dif-
ferences between the two population
forecasts and on acceptance of State
condition #8.

Rationale:

1.  Population forecasts are the basis for
projecting wastewater treatment facility
needs and related water quality Impacts.
Provision of sewerage facilities may be
related to population growth.  Growth 1n
total population is critical to mainten-
ance of air quality.  The actual location
of this population in the area 1s critical
to the protection of flood-plains and uni-
que ecological and scenic resources; cost
of public services; protection of neigh-
borhoods; and control of non-point (ero-
sion and sedimentation) sources of water
pollution.
D.  Comments were received on the plan
    alleging that Implementation of
    the Pikes Peak plan would result
    1n groundwater degradation in the
    Security-Fountain water supply
    aquifers.  Also, some of the com-
    ments stated that these communi-
    ties have nitrate levels exceed-
    ing the recommended drinking
    water standards.
EPA's Recommended Action:

1.  Approve this part of the plan re-
lying on future studies and plan updates
to resolve this issue.

Rationale:

1.  The data used in the 208 study do
not show increased degradation in these
groundwater aquifers, nor do they show
any nitrate problems.

2.  More recent data are being collected by
the U. S. Geological Survey (USGS) at sev-
eral well sites throughout this aquifer.
This work 1s part of a five party contract
with the USGS and 1s due for completion 1n
summer, 1977.
                                       20

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E.   Nonpoint Sources
    1.   Priority sources
        a.   Urban Stormwater - the
        plan states that not enough
        data were collected to re-
        quire structural controls
        or conclude that stormwater
        is a significant water qual-
        ity problem.  The plan did
        develop an Urban Stormwater
        Criteria Manual  which in-
        cludes Best Management
        Practices for stormwater
        control.
        b.   Septic Tanks - the plan
        states that water quality
        standards violations have
        been measured in the Ute Pass
        area for fecal  and total
        coliform.  There is disagree-
        ment between the homeowners
        and the 208 as  to the cause of
        this problem (i.e., overland
        runoff from horse corrals ver-
        sus septic tank leaching).
        The recent position of the 208
        agency is that  the septic tank
        situation in Ute Pass is not
        a significant problem.  The
        208 would rely  on the proposed
        5-year permit program to con-
        trol the problem.
EPA's Recommended Action:

1.  Approve the Urban Stormwater Criteria
Manual for use where possible (e.g. Colo-
rado Springs).

2.  Suggest modification/simplification of
the "Manual" for use by smaller communities
as part of the plan update, subject to avail-
ability of additional 208 funds from EPA.

Rationale:

1.  Colorado Springs Department of Public
Works and the El Paso County Department
of Transportation, have accepted the Urban
Drainage Criteria Manual for use in
drainage design and subdivision reviews.

2.  Studies elsewhere show that tracing
the source of urban stormwater problems is
expensive and may not be a worthwhile
effort.

3.  Require reassessment of monitoring
needs and the possibility of including
compliance monitoring in the "manual" or
other regulations.

EPA's Recommended Action:

1.  Approve the plan using the results of
most recent sampling as part of plan up-
dates.

2.  If State agrees with sampling results,
request from the State a certification
that septic tanks in Ute Pass are not a
problem.

3.  Require in the work plan for continuing
funding the details of implementing the
5-year permit program for septic tanks.

Rationale:

1.  Recent information from the 208 agency
indicates that the water quality standards
violations are not frequent and septic
tanks in Ute Pass may not be a significant
problem.

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                                       2.   The proposed controls (i.e.  5 year
                                       permit which is reissued only after pro-
                                       viding adequate evidence that the septic
                                       tank system has been properly maintained)
                                       may mitigate the problem.  If the problem
                                       is  not mitigated, other controls will  need
                                       to  be considered.
2.  Non Priority Sources
    a.  Silviculture - the plan
    indicates that minimum har-
    vesting of forests occurs in
    the study area and that the
    major forest activity is re-
    creation.  The plan also
    states that the Forest Ser-
    vice has adequate Best Manage-
    ment Practices to control
    water quality problems re-
    sulting from recreational use
    of the forests; however,
    funding and manpower pre-
    vent their proper implemen-
    tation.

    b.  Agriculture - during two
    years of sampling of agri-
    cultural return flows,
    measured at a chosen site on
    a major irrigation ditch
    draining into Fountain Creek,
    no problems were found.
    The plan did not inventory
    the percentage of agricultural
    activities presently imple-
    menting agricultural BMP's.

    c.  Construction - only one
    community has grading ordi-
    nances and the plan recom-
    mends that the other com-
    munities develop and adopt
    such regulations.   Many of
    the construction activities
    relate to new subdivision
    development for which the
    "Urban Stormwater Criteria
    Manual" provides guidance
    and control.

    d.  Mining -  the 208 planning
    effort resulted in the conclu-
    sion that mining is not a sig-
    nificant water quality problem
    at this time.                    22
EPA's Recommended Action:

1.  EPA will not fund any further work in
these categories unless a need is shown.

2.  EPA will approve these portions of the
plan upon receipt from the State, cer-
tification that they are not problems.

3.  EPA will require as part of the work
plan, provisions for implementing the
grading ordinances in conjunction with
the Stormwater Criteria Manual.

4.  The Statewide 208 (208 planning for
all of Colorado not designated as "Area-
wide" 208 - conducted by the State) is
reviewing abandoned mine drainage problems.

Rationale:

1.  If these non point sources are deter-
mined not to be a water quality problem,
then EPA should not expend further funds
to study them.

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F.  The State did not designate a man-
    agement agency for any of the non-
    point source categories.  The
    State did not designate a point
    source management agency for the
    Upper Fountain Sub-basin (Ute
    Pass).  EPA regulations require
    designation of management agen-
    cies for point and non-point
    source problems unless the State
    certifies that a problem does
    not exist.
EPA's Recommended Action;

1.  Conditionally approve the State's
certification and the 208 plan contin-
gent on PPACG preparing a summary of
who is expected to Implement the re-
commendations outlined in Table II.
This summary would be required as part
of the documentation prior to plan
adoption by local government and as
required by the State's condition num-
ber 10.

Rationale:

1.  Further study of the Ute Pass (Upper
Fountain) area septic tank situation is
underway.  The designation of the final
management agency will depend upon the
outcome of this study.

2.  The timing of the designation of
agencies for non-point source control
is dependent upon the development of
State policy for non-point pollution
and on development of implementation
programs at the local level.
G.  For non-point source pollution,
    the plan indicates that regula-
    tory programs are inadequate or
    lacking.  The plan makes several
    recommendations regarding these
    programs but did not develop any
    regulations, etc. which would
    correct the deficiencies.  Also,
    the plan makes several other
    recommendations (See Table II)
    but does not identify, 1n many
    cases, who 1s responsible for
    Implementing them.
EPA's Recommended Action:

1.  Conditionally approve the recommen-
dations made in Table II contingent on
development of the summary document
referred to in "F" above and prepara-
tion of a detailed work plan which out-
lines future 208 activities 1n this
area.

Rationale;

1.  It is EPA's policy to require as much
as possible 1n terms of developing and
implementing these regulations, etc.  This
EPA policy was established after the 208
plan was well underway.

2.  The PPACG did not have the benefit of
this EPA policy guidance in time to affect
the outcome of their program.
                                        23

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H.  Teller County 1s presently not
    a member of the Pikes Peak Area
    Council of Governments.  The
    plan calls for Teller County's
    participation 1n implementing
    point and non-point source
    programs.
EPA's Recommended Action:

1.  None.

Rationale:

1.  El Paso County has rejoined the PPACG
and Park County is considering doing
the same.

2.  Plan implementation 1s not neces-
sarily tied to PPACG membership; to wit,
special districts.

3.  A resolution was obtained from Teller
County at the initiation of the 208
effort indicating their willingness to
make 208 a successful program.
I.  Some local  government agencies
    and special districts have not
    yet signed  the agreement to
    become a member of the manage-
    ment association.  Therefore,
    all wastewater operating agen-
    cies are not represented by a
    management  agency, which could
    jeopardize  their receiving EPA
    wastewater  treatment grants.
EPA's Recommended Acti on:

1.  Approve the agencies as designated
and require the work plan, that will be
developed, to outline PPACG's efforts
1n solidifying and finalizing these
agencies, as a high priority.

Rationale:

1.  All the management associations have
been formed and have participating members.

2.  The State has designated these en-
tities as the point source management
agencies.

3.  Acceptance of the State's designation
will  encourage stragglers to sign the
agreement.
    The 208 plan Includes eight pro-
    posed wastewater treatment facil-
    ity plans.   EPA grants for waste-
    water treatment facilities are
    normally awarded in three steps.
EPA's Recommended Action:

1.  Approve the 208 plan, but not the eight
facility plans as Step I documents.  Each
facility plan will need to obtain a se-
                                       24

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    Step I 1s for development of a
    facility plan.  Step II  is for
    detailed facility design.  Step
    III is for actual facility con-
    struction.  The Step I facility
    plan must be  approved before a
    Step II design grant can be
    awarded.  In this case,  does
    State certification and/or EPA
    approval of the 208 plan con-
    stitute Step I approval  of the
    eight wastewater treatment facil-
    ity plans included 1n the 208
    plan?
parate approval as a Step I Plan.  Approval
of the 208 plan would include those con-
ditions cited elsewhere related to treat-
ment levels and design capacities (e.g. re-
solution of population difference, adoption
of stream classifications, etc.)

2.  Complete review of the four outstand-
ing facility plans.

Rationale;

1.  EPA guidance states that facility
plans prepared under 208 will not con-
stitute Step I plans.

2.  The eight facility plans were pre-
pared by PPACG knowing that they are
deficient as Step I plans.

3.  Comments have been prepared by EPA on
four of the eight facility plans identify-
ing the deficiencies.  These comments were
forwarded to the PPACG.
K.   The City of Colorado Springs
    had many problems with treating
    and disposing of Its sludge
    using the porteous process, in
    addition, alleged discharges of
    sludge directly into Fountain Creek
    are currently being investigated.
    These allegations, however, were
    made after the completion of Pro-
    ject Aquarius and, as such, are
    not addressed in the 208 plan.
EPA's Recommended Action;

1.  Approve the plan accepting the
State's conditions # 2, 3, and 7.

2.  If EPA funding will be pursued, re-
sponse to EPA's questions on the "Solids
Residuals Plan" will be needed.  The
EPA letter is dated February 3, 1977.
The State is currently reviewing this
plan and their questions will need a
response also.

3.  EPA supports the 208 plan's emphasis
in the timely correction of sludge pro-
blems.

4.  EPA's enforcement function will con-
tinue to follow that situation.

Rationale:
                                           1.   Sludge handling  at Colorado Springs
                                           is  the number 1  water  quality problem
                                           for the area at  this time.
                                        25

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                                          2.  Step I approval win need to be
                                          obtained separate from 208 approval (see
                                          0 above).
L.  The plan makes priority recom-
    mendations for using EPA grant
    funds to meet wastewater treat-
    ment needs.  These priorities
    were not derived using the State's
    priority system.  State condition
    #7 indicates that the plan's pri-
    orities will be integrated into
    the State's priority 11st.  It
    is not clear how this will be
    accomplished since both lists
    were derived using different
    criteria.
EPA's Recommended Action:

1.  Conditionally approve the plan con-
tingent on the State implementing con-
dition #7.

Rationale;

1.  Setting priorities for use of EPA
construction grant funds is a State
function.
M.  The plan makes several recommen-
    dations related to land use con-
    trols as a means to protecting
    water quality (e.g., develop
    engineering capability in City/
    County Health Department to
    conduct water quality review
    of subdivision proposals).
    The plan does not identify speci-
    fically wh£w1ll be responsible
    for Implementing these recommen-
    dations or when implementation
    will occur.
EPA's Recommended Action:

1.  Conditionally approve this part of
the plan contingent on development of a
work plan which delineates the details
for attaining plan Implementation.  Also,
EPA would expect a summary to be prepared
by PPACG and presented to local government
for their ratification.  This summary
would Include the who, what, and when of
plan Implementation.

Rationale:

1.  The PPACG was instructed that 208
was to generate an "Implementable plan,"
not a plan that has been implemented.
EPA expects PPACG to present to local
government for their adoption as part
of satisfying State Condition #10, a
summary which identifies the who, what,
and when, of plan implementation.

2.  Early implementation will continue
to be an objective of the 208 program and
an expectation of EPA.  However, EPA will
be realistic and not expect total Imple-
mentation during the two year planning
cycle, especially since the 208 plan
covers a 20 year planning period.
                                        26

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Comments on Draft EIS and EPA Responses
Comments on the draft EIS are summarized in Table IV below, together
with EPA's responses to each comment.  Changes in the draft EIS that
were made in response to the comments are identified.  All letters
of comment received prior to release of this final EIS are reproduced
in Appendix C.

Table IV Comments on Draft EIS and EPA responses

Comment                                       Response

Pikes Peak Area Council of Governments (PPACG)

1.  PPACG did not prioritize the recommenda-
dations and conclusions as shown in Table II
of the draft EIS.
2.  The EIS does riot adequately reflect the
State's position on the stream classifica-
recommended in the plan for lower Fountain
Creek.
3.  PPACG objects to the statement in the
draft EIS regarding alleged discharge of
sludge by the Colorado Springs wastewater
treatment plant into Fountain Creek.

4.  The lack of formal designation of non-
point source management and land use  review
agencies by the State does not imply  that
these agencies do not exist.
1.  The distinction between high
and low priorities has been
deleted from Table II and the text
of the final EIS.

2.  The intent of the EIS was to
distinguish between the plan's
recommendations and what the State
certified for the segment above the
Colorado Springs wastewater treat-
ment plant to the confluence of
Monument Creek.  This has been
clarified in the final EIS.

3.  The reference to alleged sludge
discharges has been modified in
the final EIS.
4.  EPA's statement at the bottom
of page 13 of the draft EIS does
not imply that agencies with
responsibilities in the areas of
non-point sources management and
land use review do not exist in
the State of Colorado.  EPA
recognizes that agencies with
these authorities do exist, however
we believe that formal designation
of these agencies as entities res-
ponsible for protecting, and,
where necessary, improving the
quality of Colorado's water is
desirable.
                               27

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Table IV.  Comments on Draft EIS and EPA Responses (cont.)
Comments

PPACG  (Cont.)

5.  Withholding sewerage treatment plant con-
struction funds in an attempt to control
growth that will result in unacceptable deter-
ioration of air quality places an unjust
burden on water quality and will not lead
to achievement of water quality goals.
Further, the Air Quality Maintenance Area
(AQMA) of concern consists only of El Paso
County.
6.  Both the Colorado Springs Public Works
Department and the El Paso County Trans-
portation Department have adopted the Urban
Drainage Criteria Manual.
7.  Implementation of the 208 plan depends
on the availability of continuing funding
from EPA.
State Historical Society of Colorado

1.  The draft EIS does not address histori-
cal and archaeological resources.  These
values should be addressed as early as
possible in the planning process, before
the range of mitigative alternatives has
been reduced by planning decisions.
                               28
 Response
5.  The  statement on  page  18 arises
from the observation  that  the
availability of urban services,
such as wastewater treatment, can
greatly  influence the speed and
direction of urban growth.  To
induce growth that would adversely
impact air quality by using EPA
funds to provide these services
would be in violation of EPA's
regulations and policies against
solving one environmental  problem
while creating another.  The recom-
mended restrictions on EPA funding
of sewerage treatment facilities
would only apply in areas  where
such funding would contribute to
air quality problems.  The final
EIS has been revised to reflect
the fact that only El Paso
County is included in the  Colorado
Springs AQMA.

6.  Page 21 of the EIS has been
revised to reflect the fact that
both agencies have administra-
tively accepted the Manual for use
in review of drainage designs and
subdivisions.

7.  EPA agrees, however the con-
tinuing planning and implementation
processes should ultimately become
self-sufficient and require no
further Federal financial  assis-
tance.
1.  EPA agrees; historic and
archaeological resources were not
emphasized in the regional water
quality management planning process.
These values, since they are site
specific values, will be addressed
in the site specific facility plans
and their environmental assessments
or environmental impact statements.

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Table IV.  Comments on Draft EIS and EPA Responses (cont.)

Comment                                        Response
State Historical Society (Cont.)
U.S. Army Corps of Engineers

1.  The water quality criteria exceptions
for unionized ammonia, residential chlor-
ine, and dissolved oxygen could have an
adverse effect on water quality and
establishment of a warm water fishery in
the Corps' proposed Fountain Creek Dam
and Reservoir.
U.S. Department of Agriculture, Soil
  Conservation Service (SCS)

1.  The draft EIS does not contain sufficient
information concerning the sites upon which
wastewater treatment facilities will  be
built.
                                               Under EPA regulations it is the
                                               responsibility of the grantee to
                                               assure that cultural resources
                                               are protected.  EPA is sensitive
                                               to the need to protect cultural
                                               resources and remains committed to
                                               working with historic preservation
                                               interests to identify these re-
                                               sources early in the facility plan-
                                               ning process and insure that they
                                               receive adequate consideration and
                                               mitigation during planning and con-
                                               struction.  EPA's reviews of the
                                               facility plans prepared under the
                                               208 effort reflect this commitment.
1.  EPA agrees that further study
of these matters is needed, how-
ever, the water quality criteria
exceptions are not irrevocable or
irreversible.  Indeed, stream
classifications and water quality
criteria must, by regulation, be
reviewed every three years in
order to assure continuous progress
towards attaining the water quality
goals of PL 92-500.  The water
quality needs and impacts of the
proposed project will be taken into
consideration in future reviews and
revisions of stream classifications
and water quality standards.
1.  Site specific impacts and
mitigation measures of
individual wastewater treatment
plants will be addressed in detail
in the environmental assessments
and/or environmental impact state-
ments prepared for each individual
project.
                               29

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Table IV.  Comments on Draft EIS and EPA Responses (cont.)
Comment

U.S. Department of Agriculture, Soil
  Conservation Service(SCS) (Cont.)

2.  The final EIS should describe the impacts
of £he 208 plan on prime and unique farmlandss
rare or endangered species, archaeological
sites, flood plains and wetlands.
3.  The draft EIS does not provide suf-
ficient documentation of the conclusion
that "agriculture, mining, and silvi-
culture activities are not now a signi-
ficant source of pollution (page 75,
PPACG 208 Plan)."
4.  SCS suggests that the final EIS
address the problem of non-point sources
of pollution as it relates to construction
activities for wastewater treatment
facilities.

U.S. Fish and Wildlife Service (USF&WS)

1.  USF&WS recommends close coordination
with the Colorado Division of Wildlife
should the plan be implemented.
 Response
 2.   Some  of  these  factors were
 taken  into account in  identifying
 areas  that are  suited  for develop-
 ment and  those  that are not.  A
 more thorough inventory of  these
 resources and analysis of the
 impacts of the  program will, how-
 ever,  follow in  the environmental
 assessments  and/or environmental
 impact statements  on the individual
 wastewater treatment facilities
 proposed  in  the  plan.

 3.   EPA agrees that  the 208 plan
does not completely  document
 this conclusion; however, there
 is sufficient documentation to
warrairt-the cuncrlnsinns.  These
categories of pollution sources
were not given high  priority in
the  initial  203 plan, however,
they may be addressed  in more
detail  in the future as higher
priority issues are  resolved.

4.  See response to SCS Comment
#1.
1.  The Colorado Division of Wild-
life was represented on a special
task force during the study, and
EPA hopes that the agency will
continue to be involved in the
formulation and implementation of
water quality management plans.
                               30

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Table IV.  Comments on Draft EIS and EPA Responses (cont.)
Comment

USF&WS (cont.)

2.  USF&WS disagrees with the plan's con-
clusion that a fishery is not attainbble
in lower Fountain Creek, and does not
believe that exceptions for unionized
ammonia and residual chlorine are justi-
fied simply because a fishery does not
exist there at the present time.  The
agency is also concerned about the im-
pacts of these exceptions on water quality
further downstream.
U.S. Department of Health, Education,
  and Welfare

1.  The impacts expected from the proposed
action and reasonable alternatives thereto
appear to have been adequately addressed.
Response
2.  The present criteria are
justified on the basis of the
absence of a fishery at the
present time, the current status
of the stream due to discharges of
wastewaters, and depleted flow
regimes caused by water diversions.
EPA, however, views the periodic
review of stream classifications
and criteria as an opportunity
to continually upgrade these
waters toward attainment of the
goals of PL 92-500.  EPA antici-
pates that the downstream impacts
of the criteria exceptions will be
insignificant beyond the El Paso
County line.
1.  Thank you.
                               31

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Table IV.  Comments on Draft EIS and EPA Responses (cont.)

Comment                                 Response
U.S. Department of Housing and
  Urban Development

1.  Little effort is made in the
draft EIS to show how a water
quality management plan will affect
growth.
2.  There is no discussion of
what could be done to mitigate the
adverse effects of projected growth.
3.  Many of the impacts iden-
tified in the draft EIS are not
thoroughly discussed.
1.  EPA believes that the provision
of excess sewerage capacity may re-
move a growth constraint imposed by
the present lack of such services^.	
Once this constraint to arowth is
removed and growth accelerates, the
adverse impacts of growth can come
into play.  This notion is elucidated
in some detail in the Council of
Environmental Quality publication en-
titled, "The Growth Shapers: the Land
Use Impacts of Infrastructure Invest-
ments" (May, 1976).

2.  The section of the EIS entitled
EPA Action  discusses alternatives
that are available to EPA and outlines
the rationale behind the recommended
course of action.  These recommendations,
especially as they pertain to conditional
approval of elements of the 208 plan
and guidance for further planning, are
attempts to mitigate the adverse growth-
related impacts of the Pikes Peak 208
plan.   Further efforts to mitigate these
impacts will be made during the facilities
planning process.

3.  The impacts mentioned in the sum-
mary EIS on the 208 plan will be ad-
dressed in detail in the individual
environmental assessments and environ-
mental  impact statements prepared during
the planning stages of the wastewater
treatment facilities recommended in  the
plan.
                                  32

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Table IV.  Comments on Draft EIS and EPA Responses (cont.)

Comment                                 Response
State of Colorado

1.  The Colorado Springs area
should, as rapidly as possible,
develop implementable air pollution
reduction and maintenance strategies.

2.  The Air Pollution Control
Division is unable to judge the
accuracy of the statement on page 19
of the draft EIS that "on ground
location of growth is not the critical
factor in air quality degradation."
The Division would not like to see a
208 plan that completely locks out an
alternative population distribution
as a potential  air pollution re-
duction strategy.
3.  The draft EIS presents the
State's and EPA's reaction to
the proposed 208 plan with little
explanation of what the plan for
El Paso and Teller Counties looks
like or accomplishes.
4.  The Highway Department
would like to see the following
concerns addressed in the develop-
ment of the work programs for the
next round of water quality manage-
ment planning by PPACG:
1.   EPA agrees.
2.  The final EIS has been revised
to state that it appears that the
location of growth is not the critical
factor in air quality degradation.
The Air Quality Maintenance Plan for
El Paso County will provide a clearer
understanding of the air quality situ-
ation and the measures that are needed
to reduce air pollution and prevent
future air pollution standards vio-
lations.  EPA intends that both pro-
grams be coordinated so that the re-
sulting plans are both effective and
compatible with one another.

3.  The draft EIS package included
a summary document prepared by EPA
and the main output of the planning
process, the Areawide Water Quality
Management Plan for El Paso and Teller
Counties, which was prepared by the
Pikes Peak Area Council of Governments.
The latter document is an integral part
of the whole EIS package and, we believe,
provides sufficient explanation of the
plan to serve as an adequate basis for
evaluating the proposed plan and its
environmental impacts.

4.  EPA appreciates these positive
and very thoughtful suggestions and
will encourage that they be given
serious consideration in the develop-
ment of future PPACG water quality
management work programs.
                                  33

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 Table IV.  Comments on Draft EIS and EPA Responses (cont.)

 Comment                                 Response

 State of Colorado (cont.)

 4.  (Cont.)

      a.  Have the Colorado
^Springs Transportation Improve-
 ment Program and the PPAC6 input
 to the CDH Five-Year Highway Con-
 struction Program been formulated
 incorporating Project Aquarius ob-
 jectives?

      b.  How does the current
 Five-Year Construction Program
 contribute to changes in land use,
 thereby affecting plans for control
 of stormwater runoff and for waste-
 water treatment facilities?

      c.  Have the growth-stimulus
 effects of transportation projects
 been considered with plans for
 regionalized or consolidated waste-
 water treatment?

      d.  Who will continuously
 coordinate planning for transporta-
 tion and water quality management?

      e.  Will the responsibilities
 of PPACG Transportation Advisory
 Committee change to reflect the
 concerns for water quality?  If so,
 what will these new responsibilities
" include?

      f.  Will the Environmental
 Protection Agency through the PPACG
 promulgate criteria to be applied
 during highway project impact assess-
 ment studies to ensure consistency be-
 tween transportation and water quality
 goals, policies, programs and plans?
                                   34

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Table IV.  Comments on Draft EIS and EPA Responses (cont.)

Comment                                 Response

State of Colorado (cont.)

4.  (Cont.)

     g.   What additional  erosion
controls and standards for highway
project construction, if any, are
anticipated by the Environmental
Protection Agency, and will potential
chemical pollutants such as de-icers,
pesticides and herbicides be restricted?
                                  35

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                              APPENDIX A



                    COMMENT LETTERS RECEIVED BY THE

                PIKES PEAK AREA COUNCIL OF GOVERNMENTS
 1.  City of Colorado Springs
 2.  City of Manitou Springs
 3,.  City of Fountain
 4.  City of Woodland Park
 5.  Cimarron Sanitation District
 6.  Woodmoor Water and Sanitation District
 7.  Security Water and Sanitation District
 8.  Widefield Homes Water Company
 9.  J.H.W. Investment Company
10.  Chipita Park Homeowners' Association
11.  Colorado Open Space Council
12.  U.S. Air Force Academy
13.  Colorado Springs, El  Paso County, City-County Health Department
14.  Teller County Health Services
15.  Teller County Planning Department
16.  El Paso County Land Use Department
17.  League of Women Voters, Pikes Peak Region
18.  Fountain Creek Commission
19.  Pueblo Regional Planning Commission
20.  Mr. James Monaghan, Assistant to the Governor for Natural  Resources

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                           CITY  OF COLORADO SPRINGS
                                  OFFICE OF THE MAYOR
                          P. O. BOX  IS7S             COLORADO B09O1
                                   August 3, 1976

LAWRENCE D. OCHS                           .                              TEL. OO3> 471-eeoo
      MAYOR
          Mr. Roland Gow
          Assistant Director
          Pikes Peak Area  Council
           of Governments
          27 East Vermijo
          Colorado Springs, CO 80903

          Dear Mr.  Gow:

          The City of Colorado Springs has reviewed the draft of the Water
          Quality Management Plan for Teller and El Paso Counties.   The
          City agrees  with the basic concepts presented in the draft for man-
          agement, continued planning,  stream standards and facility  needs.
          We are pleased to have cooperated in this major effort to preserve
          the quality of the  area's waters.

          Our major concern rests with implementation of the plan. The docu-
          ment presents a realistic  approach but without the cooperation of all
          levels of government and  continued construction grants, the  timing
          of  specific events will have to change.  We must also reserve our
          decision on the specifics of advanced waste treatment for landscape
          irrigation and industrial reuse.  In general,  however,  Colorado
          Springs looks forward to continued cooperation with all entities dur-
          ing the plan implementation phase of Project Aquarius.
          Sincerely,
          Lawrence D. Ochs
          Mayor

          md
                                     A-l

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                 CITY  OF  MANITOU   SPRINGS
                                 "At the foot of Pikes Peak"

606 AAANITOU AVENUE                                        MANITOU SPRINGS, COLORADO, 80829

                                                                July 9, 1976
          Mr. Michael J. Meehan
          Executive Director, PPACG
          27 East Vermijo
          Colorado Springs, Colorado  80903

          Dear Meehan:

          At our City Council meeting of July 6, 1976, we reviewed the draft
          report on Project Aquarius and asked several questions of Mr. Roland
          Gow of your staff.  After considerable discussion on the report, we
          were in general agreement with the proposals set forth in it and we
          are generally, pleased with the A-l classification for Fountain Creek.

          Though this letter does not represent a formal position of the Gity
          Council, I wanted to inform you of our feelings toward this extensive
          work which we feel is exemplary of the purpose of PPACG.-
                                           Geprge N. Miller
                                           Mayor
                                    A-2

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0,j
                     FOUNTAIN.  COLORADO
116 M A I N  S T R f E T

TELEPHONE 302-5604

SIGURD  AGA. Mayor
                                  3uly 13, 1976
Mr." Rowland Gow
Pikes Peak Area Council of•Governments
27 E. Vermijo Avenue
Colorado Springs, Colorado
Re:  Project Aquarius
Dear Roland,

     The City Council of the City of Fountain acted in a regular
mce.ting on July 12, 1976 to strongly endorse the technical standards
portion of the final draft report of Project Aquarius.  However, the ; ..-'
Council members also indicated that they strongly disagreed with tho
creation and utilization of a technical subcommittee to recommend
priorities to the PPACG for the Areav/ide Plan and its annual udpate,
and the Council members asked me to propose an alternative
organizational structure to you.

     Basically, the concern of the Council is no.t with the ability of
the PPACG elected officials or staff to make effective decisions,
rather the concern is primarily witli the inherent poll tical- instability
of the organization.  The PPACC was structured to function in a
manner which is supposed to be superordinate to the parochial
political interests of.the members while not infringing upon the
rights and authorities of the members.  Given an adherence to the  •
regional concept of goals and benefits, the PPACG is better structured
than any other agency to utilize the A-95 review process and technical
staff to provide an objective ..ova lua tion of projects to insure
optimum use of funds and resources.  It is on these strengths that we
would propose to build, while avoiding the negative aspects of the
PPACG's ueak and unstable political arrangement.

     The problem of the instability is reflected in the variable
membership'oF the PPACG.  The County of L.L Paso, as well as other
general governments, have not demonstrated either a continued
effective presence in the organization or participation based upon
regional needs.   It is imperative that the governments responsible
                              A-3

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vov land use control hove a strong role in the decision making process,
and, with El Paso County not being an effective member of the PPACG.,
that is .not possible.  It is also of utmost criticality that tin;
agencies responsible for the actual treatment or wastcwater have a
strong voice in the decision making process, and, given the associate
member status of most of these entities, that is impossible..  The
structure of the technical subcommittee would only magnify these
inequities and weaknesses, and the lack of proper representation in
tiie voting structure of the PPACG would only serve to exclude a
significant number of taxpayers and utility users who are responsible
for amortizing the debt service on the various bonded capital improvements
in the .region from the decision making process*

     It was my proposal for an alternate structure that the members
of the Council asked me to transmit to you for consideration, and I
have attached a preliminary draft of a Joint Exercise of Powers
Agreement which was designed for use at the sub-basin level for your
convenience.  As you will notice, the draft built upon "che basis
document prepared by the PPACG, and was expanded to deal in greater
detail with organizational stability; the authority, responsibility,
and accountability of the Joint [joard; and a more viable voting
structure.  1 believe that some type of weighted voting which clearly
recognizes the comparative capital investments and service obligations
of the constituent .members is clearly needed,  However, I believe
that this weighted voting should only be invoked under specific
conditions., and then only as a negative cheek upon the'actions of
the Joint Board.  Final affirmative action would have to be tolcen by
the majority of the voting members.  Tills would protect each member
from usurpation by the strongest and largest members5 as:d protect the •• •-'
entitles with the greatest commitment in In vestment fror.i being
jeopardized by a coalition of smaller entitles.

     The draft Agreement is not of course applicable to a ocp;;roi'c!itiOte
organization as It Is currently written.  However., the essential:; that
JL see for an agency with the designated responsibility for thy pre-
paration, and review of the Annual Plan are within the areas iv.ontioncd
abovco  I envision a Joint Exercise of Powers Agreement among the
sub-basin associations delegating voting representation as provided
i.i paragraph 6 of the attached document, and with the weighted
voting as also described.  The actual weighting, of the vote should
be established so as to give the weight to the entities that have
actual capital investments in v/astcv/atcr treatment facilities rather
than on the basis of population.  The formula can be established
upon technical standards without too much difficulty.  The sub-basins
would have equal representation- wich the weighted voting designed
to address the problem of the larger and small entities.

     This Association would be responsible for the areas of concern
for the designated planning agency as those areas affect actual cioeisicn
making in the establishement of construction and funding priorities
and in the preparation, review, and update of the annual pla.n.

     The PPACG would provide all technical and staff input and support
i:'or the Association.  The Association would not control or direct the
staff of the iPPACG, but coordination would be forced between the Joint
board and the elected officials of the PPACG.  The PPACG would retain..
a strcngthcd A-9S review authority over the submittai of finding
requests.
                               A-4

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This function is designed to  ho a  negative  over  the  notions of
"•'"•- Board, and would not grant the  PPACG  the  authority to
      priorities.  The
i. ii L; -J u J. > i i» LJ wa L u , n i iu iv vjii j. n  11 u i.  i| I el I! i.  bin:  i i /\v, vi  1.11 u ci 11 i. mi L i i. v  i u
reallocate priorities.  The negative  authority  would require  o.  ro-
<•• r.r.essment of the proposal , and the  goals and objectives of the
.'Joint; Board as  they relate  not  only  to  the Federal Water Pollution
Control Act but also to the reg.ional  goals and  objectives  established
through the PPACG.

     This is essentially the basis o f my  proposal, and it  needs rs
terrific amount of work and discussion.   I.would  be most happy
to discuss it with you at your  convenience.  If I  can provide any
additional information, please  do not hesitate  to  contact  me.  V/ith
kindest regards, I am
                                   tru ly  yours ,
                             Richard G.  Drown
                             City  Manager   /
                          A-5

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       PIKES PEAK AREA COUNCIL OF  GOVERNMENTS

                          MICHAEL J. MEEHAN
                            Executive Director
27 EAST VERMIJO
COLORADO SPRINGS. COLORADO 80903
PHONE  (303)471-7080
July 29, 1976
Mr. Richard G. Brown
City Manager
116 Main Street
Fountain, Colorado  80917

Dear Dick:

Thank you for your letter of July 13, 1976, reporting the
endorsement of the technical portions of Project Aquarius
by the Fountain City Council, and your concerns over the
PPACG as the designated planning agency.

I reviewed the contents of your letter, as fully as possible,
with the PPACG at its regular meeting of July 14, 1976.
During discussion, the Council members noted that PPACG
was in fact a stronger organization than any of the new
water quality management associations; that the question of
political stability woul»d be answered outside the water
quality management plan; that previous actions, and Workshop III,
had endorsed the designation of PPACG as the planning agency;
and that if changes in the proposed organization of the
committee were necessary then they would be identified and
accomplished during the updating process.  The result of the
discussion was that the recommended designation of PPACG as
the planning agency should remain in the plan as proposed.

I realize this does not satisfy your concerns, but if we
continue to cooperate, as we have in the Aquarius program,
I think any difficulties can be overcome.
Roland Gow
Project Director

ka
                            A-6

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                                  ' ''\

                                   '
                                 .
          '.-f- •**••• ,\'".-  •    -•,•:'•'. A  •; •» .'! - r".
1 '  v^''^:::'''rt''!;     -^ W*
             *                  -
                                                                   MAYOR
                                                                   ^AI^fUM
{.     , •:,.,, '.-""'   ..•-•„.> 4" •!£• ^^^^'C-5*^    CLERK-TREASURER       AJLV1N E. BORN     CITY MANAGER
      :  -.{..... \  "„-,.* :««.ii>>^V^V!> »^^3    RUE ANN VORHIES                          GLENN W. BOLSEN
                                                   .
  BEST VIEW OF PIKES PEAK           220 w. SOUTH AVE. BOXG  WOODLAND PARK, cosoaea PHONE oosj 687-9243
                                                                 July 7, 1976
      Mr. Rowland Gow,  Asst.  Director
      Pikes Peak Area Council of Gov'ts.
      27 East Vermijo
      Colorado Springs,  CO 80903

                                  Re:  Project Aquarius Report

      Dear Roland:

      This letter is to advise you that the Woodland Park City Council,
      after complete review of the report  submitted, voted unanimously
      to approve the Project  Aquarius "draft" as prepared by you,  your
      office and staff;  a job well done.

                                               Sincerely,
                                              Glenn W.  Bolsen
                                              City Manager
      GWB:jw
                                       A-7

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CIMARRON  SANITATION  DISTRICT
           702 WESTERN DRIVE • COLORADO SPRINGS,  COLORADO 80915 • (303)597-5080

           P.  0. Box 9908  .
           Colorado Springs,  CO 80932                     July  9,  1976
           Pikes Peak Area  Council
             of Governments
           27 East Vermijo  Avenue
           Colorado Springs, CO 80903

           ATTENTION:  Mr.  Roland Gow
           Dear Mr. Gow:

                      The  Board of Directors of the Cimarron Sanitation
           District hereby  endorse the draft and contents of Project
           Aquarius as projected on May 26, 1976.

                      We commend you and your people for an excellent
           job done in the  last few years.  We are well aware of  a  lot
           of time and effort spent on this project.
           Sincerely,
           . -
           Charles B. Parker
           Chairman/President
            rnest L. Niemeyer
           Vice-President
XA). 0.  Carmichael
 Secretary-Treasurer

 GNF:dl
                              Raymond H. Christensen
                              Director
                                 .
                              Thomas J.
                              Director
                                       G. N.  Free, Jr.
                                       Manager
                               A-8

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      WOODMOOR WATER AND SANITATION  DISTRICT NO. 1
                        P. O. BOXS32
                  MONUMENT, COLORADO 80132
                                        July 9, 1976
                                                    f
Mr. Roland Gow
PPACG
27 E. Vermijo,
Colorado Springs,
Colorado 80903

Dear Roland,

     Woodmoor Water and Sanitation District concurs in the
Draft Areawide Water Quality Management Plan For El Paso
and Teller Counties.

     We would like to provide some general comments:

     1.   We feel that the viewpoints of all were represented.
The document discussed the evolution of associations into
authoritative agencies on page 148 in the summary.  In
conclusions on page 158 the sentence, "It is the start of an
evolutionary process which can develop as the need arises.",
implies to us that this evolution is a foregone conclusion.
We submit this is not so, and that evolution beyond the
management systems finally defined by Aquarius will take
place if rather than "as" necessary.  This may seem a small
point, ~Fut we feel the management systems developed . as a
result of Aquarius were, by far, it's most important aspect.

     2 .   Direct coordination on financial matters would
have been helpful.  For example, on page 294, Table IX-5 ,
our 1980 assessed valuation is forecast at 10.35 million.  We
are now at 8.99 million, and expect to be at about 10 million
for 1976.  We feel that our 1980 valuation will be closer to
12 million than 10.35.

     3.   We were impressed with Recommendations for Regulatory.
Programs as a type of information which could apply to assist-
ing in implementing the current plan of organization as
established by Aquarius.  We recommend such information be  .
added to the plan before it is dispatched for State approval
by the  Governor.

     4.   As a final note, we emphasize again that the PPACG
is in our eyes not only the primary planning agency, but is
also the primary coordinating agency should this plan be
implemented.
                              Very truly yours ,
                              J.B. Price"
                              Manager
                          A-9

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                    ater and feyanitatwn

         231 Security Blvd.                       392,3475
                     Security, Colorado 80911
26 July 1976
Mr. Roland Gow, Project Director
Project Aquarius
Pikes Peak Council of Governments
27 East Vermijo
Colorado Springs, Colorado  80903

Dear Roland:

The Security Water District has long been  concerned about degradation
of the quality of water in the Widefield Aquifer, which  is the source
of its municipal water supply.

The Colorado Springs Treatment Plant lies  only 3 miles  upstream of  the
Widefield Aquifer.  The plant discharges into  the No. k  Ditch and
Fountain Creek.

Fountain Creek water recharges the Widefield Aquifer under natural
conditions.  Artificial direct recharge of the Widefield Aquifer using
Fountain Creek water has been practiced for many years by Clear Springs
Ranch which is owned by Colorado Springs.   Further, the Widefield Aqui-
fer is recharged by seepage from the No. k Ditch which carries effluent.

The 208 Plan refers to the Widefield Aquifer and to our  12,000 citizens
who are furnished water from the Widefield Aquifer.  The 208 Plan does
not speak directly to our concern over aquifer water quality, however.

Once the 208 Plan is approved, it is the official water quality plan of
the State.   Therefore, it is incumbent upon me to bring  to your attention
that:

    1.   Nitrate levels have risen in the Widefield Aquifer over
        the years.  During my 1970 monitoring  program of municipal
        water, NO^ was regularly in excess  of  50 mg/1 in September,
        October, and November.

    2.   Clear Springs municipal  water supply NO? levels were in the
        80  to 100 mg/1  range in  the fall of 1968, and well above
        k6  mg/1 in 1969-
                           A-10

-------
Mr. Roland Gow, Project Director
Project Aquarius                                             Page  2
    3.   In 1975 and 197& the Fountain Creek stream quality below
         the Widefield WTP had a mean of 19.** mg/1 of total ammonia.
         At Stratmoor, Fountain Creek had a mean total N  expressed
         as N03  of 58 mg/1.  This is very high nitrogen content for
         municipal water supply aquifer recharge.

    k.   Phosphorous in Fountain Creek below Stratmoor has been
         running at a mean of 3-9 mg/1 for 1976.  Stream water
         quality standards should control this at about 1.0 mg/1
         for municipal water supp.ly classification.

    5.   In May of 1970 our laboratory measured drinking water from
         Security Well Numbers 10, 17, 1**, *», and 12 to have ABS
         levels ranging from 0.5 to 1.2 m'g/1.  This measuring was
         done as a result of customer complaints of foaming water
         from household water faucets.

We have  been waiting for a water quality management plan which would
lead to  a cure of the stream pollution problem.  The 208 Plan does not
appear to adequately address our Widefield Aquifer water quality ques-
tions related to municipal water supply.

In addition to nitrogen, phosphorous and ABS for which we have made
tests, questions exist relative to carcinogens, pesticides, virus,
various organic compounds and other pollutants which might be identi-
fied under the Clean Drinking Water Act enforcement efforts.

As Manager of the Security Water District, I would like to state that
I  am not at all sure that the 208 Plan will  protect our underground
municipal water supply aquifer.   Yet, once the Plan is adopted, it is
the official State plan.  At that time it would be too late to do any-
thing about the quality of recharge water.

By copy of this letter to Mr. George Prince of the Colorado Department
of Health, I am asking him to advise on monitoring needs and other means
to protect our water supply.
Yours very truly,
Thomas K. Remple, Manage r
TKRrjlb
cc:  Mr. George Prince
                            A-ll

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          PIKES  PEAK AREA COUNCIL  OF GOVERNMENTS
f^^'^
-------
Mr. Thomas K. Remple               2                     July 29,  1976
    measurements.by Colorado Springs in the Clear Springs  Ranch area
    range from 0.8 to 1.0 mg/1.  The major concern with phosphorous
    is eutrophication in streams and lakes.  Little of this  exists in
    Fountain Creek and the levels of phosphorous actually  in the
    aquifer are generally within the groundwater pollution indicator
    level you mentioned.

5.  Few ABS measurements have been made recently and there have also
    been few, if any complaints about foaming tap water.   Your state-
    ment is the first reported to the 208 program.   I understand that
    since detergent manufacturers started making more bio-degradable
    products in the early 1970's, ABS has decreased markedly.   As
    noted we have received no reports of foaming water other than yours.

By pointing out the pollution levels above,'it is not suggested that
there are no problems or that nothing should be done until the
difficulties achieve crisis proportions.  In essence,  the  problems
are considerable, but they do not appear to be as insurmountable as
you imply.  Project Aquarius has examined the Widefield aquifer situa-
tion and has proposed the following actions in order to further
identify problems and progress towards meeting clean water goals:

1.  Continued monitoring of nitrate levels in the Widefield  aquifer
    and in the stream.

2.  Major improvements to the Colorado Springs treatment facilities
    including sludge handling.

3.  Major improvements to the Security treatment facilities.

4.  Connection of Stratmoor A and B Plants to Colorado Springs,  thus
    eliminating two point sources.

5.  Connection of Garden Valley to Colorado Springs,  eliminating a
    further point source.

6.  Connection of the Fountain Valley Shopping Center to Security,
    eliminating another potential pollution source.

7.  Preparation of a storm drainage manual for adoption by local
    governments to assist in the control of non-point  sources  of
    pollution.

8.  Reuse of Colorado Springs wastewater for landscape irrigation and
    industrial use in order to reduce waste loads delivered  to the
    stream and make more efficient  use of water resources.
                                A-13

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Mr. Thomas: K. Remple               3                    July 29,  1976
These steps, if implemented, can and will reduce the difficulties and
will help to meet our goal of protecting groundwater in the Widefield
aquifer.  I hope that on re-examination you will agree.

I have taken the liberty of sending a copy of your letter and this
response to Wright-McLaughlin Engineers.  Because of their involvement
in the regional sludge handling plan, in your facilities, and in those
of the City of Colorado Springs, all under the auspices of Project
Aquarius, it is important that they are fully aware of your concerns
and the nature of recent data.
Sincerely,
Roland Gow
Project Director

srb

cc:  George Price, Colorado Department of Health
     Wright-McLaughlin Engineers
                               A-14

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                                                                               UL •  6 1.9
                 WIDEFIELD HOMES WATER COMPANY
                             3 WIDEFIELD BOULEVARD
                      COLORADO SPRINGS. COLORADO 8O911
                                  PHONE: 392-3411


                                        1  July 1076
i.-'ikes Peak Area Council of Governments
27 2. Vermijo
Colorado Springs, CO  80903

Attn: Mr. Roland Gow
Dsar Roland:
RE:  Project Aquarius-Draft of Area Wide
       Water Quality Management Plan,
       El Paso and Teller Counties.
The Widefield Homes  Water Company  supplied  Peaceful  Valley  Lake  Estates Company
with a letter on 6 June 1972, stating  that  this  company  will operate  and main-
tain the Peaceful Valley water distribution  and  sewer system services when the
systems are. completed.

We verbally emphasized to Mr. R. F. Hammond, General  Partner,  Peaceful Valley
Laks Estates that this company could not, and would not  operate or maintain
thu systems except under a labor contract.

S.inca no contract for labor has been offered or  negotiated by tho. principles
involved, the Widefisld Homes Water Company  denies any and all responsibility
fiVi. operation ood maintenance of the Peaceful V.il.loy  Water and/or Sewer system.1;.

'.:<•. ':!T?.rRcovc request that pages 230 and  231  of  the Area  Wide Water Quality
Mr.p;;:.?nc.nt Plan for El Paso and Teller counties  be corrected as follows:

      Page 230, last paragraph:  Delete  last .sentence

      Page 231, fourth (4th) paragraph:  Delete  third (3rd)  sentence
                                        ,'ery  truly yours,
                                           £ C. Per
                                       Vice- P resident
jr.p/jal
                                   A-15

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                J. H. W.  Investment Company
                              3 Widefield Boulevard
                        Colorado Springs, Colorado  80911
                                         29 June  1976
Pikes Peak Area Council of Governments
27 E. Vermijo
Colorado Springs,  CO   80903

Attn:  Mr. Roland  Gow                    RE:   Project Aquarius-Draft of Area Wide
                                                Water Quality Management Plan,
                                                El  Paso and Teller Counties.

Dear Roland:

The following information is submitted at the  request of the Widefield Homes Water
Company.

On the second (2nd) day of June 1972, a "Water Production Agreement" was entered  ir.to
between the J.H.W.  Investment Company, a Limited  Partnership, and Peaceful Valley Lake
Estates Co., a Limited Partnership.

This agreement pertains to water only, and under  the terms,  the J.H.W. Investment Company
a;;roed to deliver  water, in certain quantities and under certain conditions, into a
viter .-ysten constructed by Peaceful Valley Lake  Estates, and deeded to J.H.W. Investment
Company, WHEN MUTUALLY AGREED.

J.H.KY Investment  Company entered into an agreement with the Widefield Homes Water
Company to negotiate  a "Labor Only" contract for  operation and maintenance of the Peace-
ful Valley Lake Estates Company Water system,  at  an unspecified future time.

Peaceful Valley Lake  Estates Company agreed to install the water system in accordance
with Widefield .Homes  Water Company specifications.  Peaceful Valley Lake Estates  Company
failed to install  the first phase of their system in accordance x>?ith specifications.
Several conferences were held in April and May of 1973 with Peaceful Valley Lake  Estates
Company personnel.  The discrepancies were pointed out.  After each conference Peaceful
Valley Lake Estates Company agreed to correct  discrepancies and bring the water system
up to an acceptable standard.

To date, the corrections have still not been made.

The J.H.W, Investment Company will not agree to accept a quit claimdeed on the existing
water '.ystem until discrepancies have been cured, at which time a Labor Contract,  for  •
Operation and Maintenance will be negotiated with Widefield Homes Water Company,  or with
oorae other company  to provide maintenance service.

At a meeting with  Peaceful Valley Lake Estates  Company personnel on 19 April 1973, they
expressed a desire for "Widefield" to operate  and maintain the sewer and lagoon system
upon completion.


                                         pa^o  1  of 2
                                      A-16~

-------
                                          page 2 of 2


This was followed by a letter on 26 April ]c>13 from Peaceful Valley Lake Estates
Corr.p.uiy to J.H.W. Investment Company, in 'which they stated  they would quit claia
Stiwsr liner, and lagoon to J.H.W. Investment Company when completed.  This was not.
a^'i'-Hi to by tlio J.H.W. Investment Company.

The above letter also stated, "It was a£r«?0'.i  that Widefield Hones Water and Sanitation
Company will operate and maintain the Peaceful Valley Lake  Estates Water and Sewer
systems, whan  the systems arc complete, as per letter of agreement dated 1 June 1972."

This statement is in reference  to a letter from Widcfield Homes Water Company to
Peaceful Valley Lake Estates Company, dated 6 June 1972, in which they stated they
would oparate and maintain the Peaceful Valley Lake Estates system when completed.

This letter was provided by  the Widefield Homes Water Company at the request of
Peaceful Valley Lake Estates Company and J.H.W. Investment Company in anticipation
of a negotiated "Labor Only" contract.

To date, no contract has been signed between Widefield Homes Water Company and J.H.W.
Investment Company.

In visw of the above, all reference to Widefield Homes Water Company in connection
with Peaceful Valley Lake Estates sewer system should be deleted.

Under the present circumstances, all operation and maintenance responsibility is with
Peaceful Valley Lake Estates Company for their-own system.

                                              ''
                                          'Jules H. Watson
                                          General Partner
                                        A-17

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       L^hlpita  l^am  ^Svomeowner 6
                        Chipita Park, Colorado'

                                             July 5,  1976
 Roland  Gow
 PPACG
 27  East Vermijo
 Colorado Springs, Colorado  80903

 Dear Mr. GOWJ

     The draft report on Project Aquarius furnished with the
 PPACG memorandum of May 26, Draft Summary of June 1976,  have
 been reviewed.  It is noted that the- comments and recommenda-
 tions of the Upper Fountain Creek representatives at the con-
 clusion of the January workshop were not incorporated in the
 report*

     The draft report again includes speculative irateria! pre-
 sented  in such a way that it might be construed as factual.   The
 following are suggested rewrites of material pertaining  to
 Upper Fountain Creek Management Sub-Region which would result
 in  the  report being consistent with the present status of in-
 vestigations.

 Page 64 , under 'Individual Sewage Treatment Systems*

 Table 11-15A on page 70 shows that the wording for Uppar Foun-
 tain Creek Area should read,

 "•  The upper portion of this reach of the stream does not meet
Al  standards for fecal coliform, but the entire reach meets  Bl
 standards."

Page 65 » under 'Upper Fountain or Ute Pass Area*

Change wording to read,

 "•  The stream system will be classified at a level necessary
    to  protect and propagate aquatic life and provide for
    limited body contact recreation.   This is the only segment
    recommended for aquatic life in the Fountain/Monument basin.

 •  This will require a Bl classification.

 •  Waters in the stream now conform to Bl standards."

     66 , second and third paragraphs
Change wording to read,      •

"The nature of the terrain within  the Ute Pass area is such
that septic-tank type sewage disposal must be used carefully.

                           A-18

-------
 Page  2

 Roland  Gow
 Small-scale  variations  in soil types, variable groundwater
 tables,  steep  slopas, proximity to other septic systems,
 shallow  and/or exposed  bedrock must be taken into account.
 Inadequate installations will result in septic system and
 leaching field failures characterized by raw sewage surfacing
 upon the ground.   The El Paso City/County Health Department has
 estimated that an  average of approximately 20 to 30 septic
 system failures occur annually in the area.

 Another  possible result of septic system failures is the con-
 tamination of  groundwater and adjacent surface waters.  The
 extent of their actual contribution, if any, has not been
 established, but is currently under investigation by sampling
 of  the stream  and  of walls in the aquifer."

 Pages  68.  70,   Tables

    Use Table 11-15 and II-15A to place the sampling locations
    in  proper geographical sequence, and make corresponding
    changes in  text references on pp. 66,69.  It is pertinent to
    note  the degradation of stream quality between station 90
    and CDH station west of Manitou Springs.

 '   Resolve apparent errors in mathematics in deriving the roaan
    values  in the table II-15A from the detail data that we were
    given,

 •   Re-caption  Station 95 as 'Western One-fifth of Chipita Park*

 •   Re-caption  Station 94 as 'Mid-point of Chipita Park*

 •  Add the State B-l standards in the footnote.

 Page 69,  last  paragraph, continuing to page 71

 •   Give  statistics dating back to 1970 at leasts  to show whether
    failures are indeed increasing.

 •  Verify that  the count of failures is the number of separate
    systems that failed,  not including multiple problems with
   any single  system.   (NOTE:   installation of a  new septic tank
    should not  by itself  be interpreted as a failure, as conver-
    sion from summer to year-round use often involves this step),,

   Rather than state 'To date in 1976...'  give specific date.

Pape_ 71,  second paragraph,

Change to read,

"Although no  definite  conclusions can ba  drawn at this time,  it
appears that  fecal orictamination of  Fountain Creek is centered
in Groan Mountain Falls.   Table  II-15A shows that coliform counts
improve rapidly thereafter.   To  date,  no  specific evidence has
                              A-19

-------
 Page  3
 Roland  Gow
 bean located to identify  the  exact source of pollution.  Al-
 though  runoff from the stables has not bean eliminated from
 consideration as a source,  the data does not wholly support this
 theory  at this time.'

 Page 119

 Put  Woodland Park and  Ute Pass in separate paragraphs, as they
 are  treated  separately everywhere else.  The encouragement of
 basic industries and selective annexation is Woodland Park's
 plan, and is not applicable tc the Upper Fountain Creek Manage-
 ment Sub-Region.

 Page..127

 Verify  the figures for Ute  Pass population in 1964 and 1973.
 Neither of the numbers seems  realistic; as our best information
 is the  maximum summer  population is less than 3000.

 Page 128

 Verify  the figures for Ute  Pass employment in 1964 and 1973.
 Do they indicate 'employed  in Ute Pass', or 'living in Ute Pass
 and  employed anywhere'?

 Pap;e 3.67,  (map)

 •  Under  'A.  Legend1,  delete  the word 'dense*.

 •  Under  'D.  Non-point Source Characteristics'

 Change  to  read,

 "No  agricultural or mining activities,  Silvicultural activities
 are  strictly controlled as  the highlands to the southwest of
 Fountain Creek are watershed  for municipal water supplies,

 The  nature of  the  terrain within the Ute Pass area is such that
 septic-tank  type sewage disposal must be used carefully.   Small-
 scale variations in soil types,  variable groundwater tables,
 steep slopes,  proximity to other septic systems,  shallow and/or
 exposed bedrock must be taken into account.   Inadequate instal-
 lations will result in septic system and leaching field failures
 characterised  by raw sewage surfacing upon the  ground,  with
 possible contamination of groundwater and adjacent surface waters.
 High septic-system densities occur in limited areas."

 Page 176,  under  'Upper Fountain',

Change vises to read,

 "Water supply; aquatic life; wildlife; recreation?  limited body
contact."                                                      .

 (There is  no agricultural use).

                            A-20

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 Page  4

 Roland Gow
 Page  197,  Table V-3, and page 6 of Summary Table 1, entries
      for  'Fountain Creek from Crystola Creek to confluence
      with  Monument*,

 Change as  follows:

 Under 'Recommended 1983 State Classifications and Exceptions*
 enter B-l, instead of A-l.

 Under *Recoimended Uses'
 enter 'Aquatic/wildlife, Limited body contact/Recreation, Water
      supply/recharge *.

 Page  241,  £, second paragraph,

 Change to  read,

 "Chapter II assessed the present water quality problems and the
 nonpoint source situation in the Ute Pass area.  Water quality
 data  presently available indicate that there is a high fecal
 coliform count in the waters of about a 3-mile stretch of Upper
 Fountain,  which does not emanate from its tributaries.  This is
 under investigation by a stream and well sampling rpogram whose
 results are as yet inconclusive."

 Pase  265,  second paragraph,

 It is noted that this 1976 population estimate of 3000 is smaller
 than  the 1973 population estimate of 3850 on page 127.

     After you have had an opportunity to revise the Draft Report,
 and the Draft Summary, the representatives of Upper Fountain Creek
would like to have a meeting to discuss the final version of the
 Project Aquarius report as it pertains to us.

      These requests represent the consensus by the following
 representatives of the Upper Fountain Creek Management Sub-Region:

     Green Mountain Falls:  Robert L. Palmer, Mayor
     Chipita Park:          Louis G. Feil, Pres. Homeowner's Assn.
                            Jamss T. Dicker,  V-Pres.  "
                            Win.  A.  Coates, Board      "        "
     Cascade:               Robert L, Andr^son, Repr.  Prop. Owners Assn.
                            Fern Johnson, Secretary     "      "     "
L-6uis G. Feil, Chairman of           •'""""Robert LV  Palmer",'
Representatives of the Upper            Mayor, Green Mountain Falls
Fountain Creek Management Sub-Region

                             A-21

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        PIKES PEAK AREA COUNCIL OF  GOVERNMENTS
                           MICHAEL J. MEEHAN            27 EAST VERMIJO
                             Executive Director             COLORADO SPRINGS, COLORADO  80903
                                                     PHONE (303)471-7080
July 19, 1976



                          MEMORANDUM


TO:       File

FROM:     Roland Gow

SUBJECT:  Response to Ute Pass Concerns
Met with Ute Pass representatives on July 13, 1976,  at 7:00 p.m.
in Marcroft Hall.  Discussed point by point all their concerns
and the actual changes that were to be made in the document.
All their points were covered.  Only point of disagreement
was the Al - Bl classification.  I noted that an interpretation
of the law was that A classes only were acceptable.   They
expressed concern over meeting standards that were too high
for the use of the stream.  I suggested that a recommendation
be included regarding the public health risk levels of fecal
coliform.  This has been included.  The meeting concluded to
the satisfaction of both parties at 7:41 p.m.

Present were George Feil, James Dicker, Bill Coates,  Bob
Andreason, .Claudia Ely,  and Roland Gow.
                            A-22

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COLORADO OPEN SPACE COUNCIL   1325 DELAWARE ST.  DENVER,COLO. 80204   303/573-9241

                                                       July 2, 1976

       Mr. Roland Gow
       Project Director
       Project Aquarius
       Pikes Peak Area Council of Governments
       27 East Vermijo
       Colorado Springs,  CO 80903
                                                      Re:  Draft PPACOG 208 Plan
       Dear Mr. Gow:

            The Water Quality Workshop  of  the Colorado Open Space Council has reviewed
       the draft of the Areawide  Water  Quality Management Plan for El Paso and Teller
       Counties.  Our analyses have led us to conclude that the Draft Report is inadequate
       and is unacceptable  as a 208 Water  Quality Management Plan.

            More specifically,  the Draft Plan is inadequate in at least six major areas.

         1.  The Draft Plan  does not achieve the goals or requirements of a 208 Plan.
            The Draft Plan  does not set forth a plan for achieving fishable and svritn-
            mable v,rater quality in the  region by 1983-  The Draft Plan does not
            achieve the goals put  forward  on pages 176-177 of the Draft Plan.

         2.  The Draft Plan  is based upon stream water quality exceptions,  and there-
            fore,  in  effect,  tends to be a negative plan.  The Draft Plan is based
            upon the  attainment of several stream classification exceptions (Class
            C).   The  Water  Quality Control Commission has not granted these excep-
            tions.  Further,  such  exceptions are for short term periods.  No plan
            alternatives  are  presented for meeting national water quality goals.
            Commission policies require that an "economic hardship" be demonstrated
            for a C classification.  Wo such hardship is demonstrated in the Draft
            Plan.

         3.  The Draft Plan  does not adequately address population and land use issues
            in  regard to water  quality management..  The Draft Plan is based upon am-
            bitious growth  projections (83/« over the next 25 years; which are not
            consistent with state  population distribution policies.  Furthermore,
            the impact of these ambitious .population projections on the ability to
            achieve the 1983  goals of PL 92-500 are not specifically identified.

         4.  The Draft Plan  is based primarily on secondary treatment.  The apparent
            approach  to the Draft  Plan  has been to provide primarily secondary
            treatment. In  areas where  this is not sufficient to achieve state wa~
                          a state-wide environmental coordinating council
                                         A-23

-------
Mr. Holand Gow
July 2, 1976
Page 2

     ter quality standards, exceptions are requested.  Too much emphasis
     is placed upon the construction of interceptors and higher capacity
     plants to serve population growth rather than higher quality treat-
     ment for more reasonable levels of growth.  Adequate planning has not
     been demonstrated for the protection of downstream water supplies
     from nitrates, viruses, organic compounds, etc.

  5. The Draft Plan does not adequately address the land treatment alterna-
     tive.  Land treatment is dismissed as a major alternative without
     adequate analyses even though Colorado Springs in earlier years was
     a recognized leader in recycling sewage effluent.  Assumptions in re-
     gard to land treatment — such as 10/a consumptive use, prefiltration
     requirements, no public acceptance, irrigation of new lands,  etc. —
     are not adequately explained.  The use of such constraining and non-
     optimizing assumptions illustrated a bias against a revenue-produc-
     ing facility which is capable of treating to a high level of  quality.
     Reference can be made to the July 1973 American Public Works  Associa-
     tion Publication, Survey of Facilities Using Land Application of
     Wastewater,  which is probably in the PPACOG library.

  6.  The Draft Plan would lead to further problems with municipal water
     supplies at Security, Widefield, and Stratmoor Hills.  Water quality
     problems have existed in the past.  There have been complaints of
     foaming tap water due to ABS.      Fountain Creek is considered to
     be one of the most polluted streams in Colorado according to  Colora-
     do Department of Health data.  Stream water is used for direct re-
     charge of the municipal aquifer.

     For the above reasons we find the Draft Plan unacceptable.  In its present
forrnj  we recomend that the Water Quality Control Commission reject the plan and
the gubernatorial certification riot be granted •.

                                              Sincerely yours,
        .                                      COLORADO 0PM SPACE  COUNCIL
                                              Mary C.. Taylor
                                              President
cc:  Governor Pd. chard Lamm
     Jim Monaghan
     Gary Broetzman
     Harris ..Sherman
     Water Quality Control Commission
     John Green, Region 8 EPA
                                     A-24

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      PIKES PEAK  AREA  COUNCIL OF GOVERNMENTS
                         MICHAEL J. MEEHAN            27 EAST VERMIJO
                           Executive Director              COLORADO SPRINGS, COLORADO 80903
                                                    PHONE (303)471-7030
July 9, 1976
Ms. Mary C. Taylor
President
Colorado Open Space Council
1325 Delaware Street
Denver, CO  80204
Dear  Ms. Taylor:

I am in receipt of your letter of July 2 regarding the Pikes
Peak Region's "208" plan, and am frankly surprised at the
lack of depth and understanding your analysis displays.   Since
you took no time to ask questions of anyone connected with
Project Aquarius or to secure background material on the
plan the inadequacy of your remarks is, in retrospect, not
so hard to understand.

The purpose of the "208" planning process is to develop
environmentally sound, publicly acceptable, implementable
plans for managing water pollution on an area-wide basis.
You apparently understand neither the nature of the planning
process nor the vital need to implement what is being pro-
posed.  Our plan is aimed at getting certain things done
for the local region as part of the overall state plan for
water quality.  A pragmatic approach rather than an ivory
tower perspective was demanded by the elected officials of
this area.  Indeed, if implementation were not the key to
our approach we would have wasted two years and the money
provided by EPA.

Achievement of the 1983 goals of the Water Pollution Control
Act Amendments of 1972 is, as stated in the plan, a goal
of this area.  In spite of your comments we will achieve
those goals in the Teller County, Upper Fountain and Upper
Monument areas.  The Act also points out that goals shall
be achieved on a "where attainable" basis.  We do not
believe, and neither do some eminent ecologists, that it is
possible to gain the fishing and swimming goals on Monument
and Lower Fountain Creeks.  Instead, our plan strives to
maintain and improve existing aquatic habitat, protect health
                           A-25

-------
Ms. Mary  C. Taylor               2                July 9, 1976
 and water  supply,  and provide  for recreational use of the
 streams.   Because  of the  inability of the streams, from a
 physical environmental  standpoint, to support major aquatic
 life  i.e.  fish,  the region decided it would be inappropriate
 to recommend  spending substantial money to try to make them
 support fish.  Hence, we  have  requested exceptions for ammonia,
 chlorine residual, and  in a short stretch below the Colorado
 Springs plant, dissolved  oxygen.

 I am  not aware of  the Colorado Water Quality Control Commission's
 "policy" on economic hardship  relative to the granting of
 exceptions.   Indeed, many people, including, I suspect, COSC,
 consider the  justification of  exceptions based solely on
 economic factors to be  unacceptable.  Our main justification
 for the exceptions is environmental, and I believe that is a
 proper way to seek such variations from the standards.  The
 plan  fully meets the requirements of the "208" program, the
 goals set out within it,  and the national goals, where attainable.

 Your  comments on the population projections used for planning
 purposes are most  illustrative of your ignorance of the local
 process.  Had you  taken the time to familiarize yourself with
 the issues and their resolution your discussion might have
 been  less vitriolic.  The figures represent the mid range
 of projections for the  Pikes Peak Region; figures that were
 subjected to  local scrutiny and discussion before they were
 employed.  Given what many believe to be "the economic advantages
 of this area, the  figures are  quite attainable and for planning
 purposes may even be conservative.  Furthermore, they do not
 contravene State population distribution policies because
 such policies have not, in fact, been adopted by the State.
 You must be aware that  the Colorado Division of Planning is
 only just embarking on  the development of growth policies
 for the State.  Should you wish to participate in that decision
 making process, you might wish to contact the CDP.

 It is impossible to separate growth from the attainment of
 water quality goals.  Growth will cause great environmental
 pressures,  but our analysis indicated that,  given the appro-
 priate exceptions, based on environmental considerations, we
 can have growth and clean streams with secondary treatment.
 Our proposal to use 1983 effluent limitations will protect
 downstream users.  The continuation of our monitoring program
will provide an early warning system to let  us know when, if
 ever,  further treatment steps are necessary.

The land application of sewage was considered and dismissed
 as not being a cost-effective treatment method at this time.
The current infatuation with land application as the ultimate
                            A-26

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 Ms.  Mary C.  Taylor              3                July  9,  1976
 treatment method may have led you to miss  the  fact  that  the
 plan is vitally concerned with the reuse of water for  industrial
 and landscape irrigation purposes.   The  plan notes  the need  for,
 and provides for special local studies of,  landscape irrigation
 reuse on golf courses,  medians,  and other  areas.  Whenever eco-
 nomically feasible these practices have  been and will  be
 recommended.  We did not consider reuse  as  a major  treatment
 alternative but as a wise use of water resources that  will have
 the added benefit of reducing pollution  loads  in our streams.

 Your remarks regarding  water supplies in the Lower  Fountain
 Area are again indicative of a lack of knowledge of the
 area.  Over the past decade or so there  have been no
 problems with the quality of drinking water in the  area
 as far as we have been  able to determine.   If  you have recent
 documented cases I am sure the managers  of  the appropriate
 water supply systems would like to know.   Incidentally,
 Colorado Springs draws  significant water from  the Widefield
 Aquifer and, of course,  has some concern for the quality of
 its raw water supply.

 In conclusion,  it is my opinion that your remarks are  ill-
 considered.   Mad you contacted local COSC representatives,
 even the Vice President of your own organization, you  might
 have had something more constructive to  say.   That, we would
 have welcomed!   But when a State special interest group  does
 not even contact its local people and shoots strictly  from
 the hip, no positive purpose can be served.  While  local
 COSC members may not be fully enamored with the exception
 process they did and do 'realize that the plan  is a  major
 and concrete step towards the improvement of water  quality
.in the Pikes Peak Region.  It is worthy  of  acceptance  and
 certification by all parties as a positive  practical approach
 to solving water pollution problems. And  in an era when plans
 have sat on shelves too often, the plan  is  a significant
 departure.
 Sincerely,
 Roland Gow
 Project Director

 cc:   Governor Richard D.  Lamm
      John Green, Regional Administrator,  EPA
      Harris  Sherman,  Chairman,  Clv'QCC
      Evan Dildine,  Technical Secretary, CWQCC
      Robert  Isaac,  Chairman, PPACG
      James Monaghan,  Governor's Staff
      Gary Broetzman,  State "208" Coordinator
      Mike Stiehl, Vice President, COSC

ka                         A_27

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\   \       J  V                                           July 29» 1976
  - > x-..	.xx   \-

COLORADO OPEN SPACE COUNCIL   1325 DELAWARE ST.   DENVER,COLO. 80204  303/573-9241

        Roland Gov;, Project Director
        Project Aquarius
        Pikes Peak Area Council of Governments
        27 East Vermijo
        Colorado Springs, CO  80903

        Dear Mr. Gow:

        We have received and carefully studied your letter of July 9 concerning our
        comments on the Draft Project Aquarius 208 plan.  We were of the hope that
        your reply to.our comments would have been more constructive and dealt more
        specifically with our questions.  We stand by our comments.

        In our view your draft document does not satisfy the requirements of a 208 Plan.
        The 208 planning process was intended to provide a mechanism for comprehensive
        water quality and water resources planning.  The Draft Plan falls short of
        identifying all the various opportunities available, for achievable water quality
        management.  Too much emphasis has been placed on gathering data.  This is only
        the first step in the planning process and more weight should have been placed
        on developing strategies for achieving water quality.

        We agree that Lower Fountain Creek may not in its present condition support
        active aquatic life.  We would go further to say that it has been badly polluted
        downstream by Colorado Springs municipal sewage.  This, however, does not mean
        that this condition has to continue in the future .  We believe a stream can be
        classified for aquatic life if it will be suitable in the future.  Aquatic life
        designation is a water quality parameter rather than a fish life indicator.
        For instance, aquatic life designation would protect downstream municipal water
        supplies.

        Wastewater management planning, when viewed as an opportunity rather than as a
        minimum federal requirement for grant money, can provide an opportunity for total
        water management systems.   Some examples would include ground water recharge,
        open space irrigation, low flow augmentation,  recreational use,  and others.
        Techniques are also available with minimum effort to improve stream bottom
        conditions and flow characteristics to support aquatic life and improve recre-
        ational opportunities.  Efforts currently under way in Denver,  Boulder, San
        Antonio, Muskegon and other areas are examples of the opportunities available.

        Stream flows in the Colorado Springs area are  improving because of the sub-
        stantial pure transmountain diversions used as water supplies.   This  increased
        resource availability needs to be maximized for the overall good of the community.
        The achievement of less than minimum water quality  standards and limited in-
        dustrial reuse does not take full advantage of these increased  supplies.
                           a state-wide environmental coordinating council
                                            Ar28

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Mr. Roland Gow
Page 2
July 29, 1976


The Draft Plan docs not demonstrate a serious consideration of the various
water resources planning opportunities which should be considered as a part
of the 208 planning process.  We will continue to request that the Draft Plan
not be accepted until such an effort has been undertaken.

In order to accommodate these concepts which we consider to be essential for a
successful 208 Plan, we would suggest that the overall status of the program
be reviewed.  The purpose of this review would be to determine actual deadlines
for the Plan, budgetary conditions and opportunities for Plan revision and
expansion.  It is our hope that in such a review of the Draft Plan, a Final
Plan can be developed and adopted which can be a model for the other 208 Plans
in the state.  We welcome the opportunity to participate in the review process.

Yours very truly,

 l/i       ft

Mary C. Taylor
President

cc:  Governor Richard D. Lamm
     John Green, Regional Administrator, EPA
     Harris Sherman, Chairman, CWQCC
     Evan Dildine, Technical Secretary, CWQCC
     Robert Isaac, Chairman, PPACG
     James Monaghan, Governor's Staff
     Gary Broetzman, State "208" Coordinator
     Mike Stiehl, Vice President, COSC
                                   A-29

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                                                         RECEIVED JUL
REPLY TO
ATTN OF:
         DEPARTMENT OF THE AIR FORCE
HEADQUARTERS UNITED STATES AIR FORCE ACADEMY
         USAF ACADEMY, COLORADO 80840

                                        1 JUL 1976
SUBJECT:  Comments on Draft Plan (Your Memo,  26 May 76)
       Pikes Peak Area Council of Governments
       .27 East Vermijo
       Colorado Springs, Colorado  80903

       Thank you for the opportunity to comment on the draft  of the  Areawide
       Water Quality Management Plan for El Paso and Teller Counties.   It  has
       been a'worth-while experience for us to participate in the  series of
       Aquarius Workshops.  The draft plan is excellent and the Air  Force
       Academy wishes you success in its implementation.   We  are looking for-
       ward to continued support and cooperation.
      ff. ROGERS CRAIG, L;
      Base Civil Engine,
      Colonel,  USAF
                                         A-30

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              CITY-COUNTY  HEALTH  DEPARTMENT

                     Colorado S/>n'»i».
-------
   TELLER  COUNTY  HEALTH SERVICES

    GEORGE M. HEMMING                    BOX no
       ENVIRONMENTAL^                WOODLAND PARK. COL'.HADO 80863


Roland Gow
Proiect Aquarius
PPACG
27 E. Vermiio Ave.

Dear Roland,
     Congratulations are  in order as you near '-he comp-
letion of Project Aquarius.  The study has coin;-iled much
useful information.   The  value of the plan will- be. real-
ized in the  future  if it  can be utilized in a /realistic
manner by those with access to it.
     The one related area which still concerns roe is
regulation requirements affecting small municipal sewage
treatment plants.   As you know from experience/ most
smaller operations  cannot or will not comply v/Jth re-
quirements of state and federal regulations.  A- case in
point is the NPDES  monitoring requirements.  The 1'aboratory
equipment required  for compliance with NPDES o'^sts^at
least $5,000 without consideration of housing.  This
coupled with the need for a trained technician is an
insurmountable burden to  most small municipal:! '-ies.
     Centralization of the testing program is '>£ course
one obvious  solution.  Another possible solut.i'>n is the
lowering of  testing procedure standards allows-''>le under
NPDES.  Efforts by  industry  (i.e. Hach ChemiC'' -:- Company)
to have simpler testing methods accepted by EJ'/- should
be supported.
     An awareness of the  funding and manpower r-roblems
found in rural areas is necessary for the real :.zation
of many of; the goals of Project Aquarius.
                                       Zx*
                                        GMH J'>'J£>
                       A-32

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Larry Kallenberger
                     TELLER  COUNTY COLORADO

                    PLANNING DEPARTMENT
                                   P. O. BOX 1886
                           Woodland Park, Colorado 80863

                                   July  27, 1976
LAND USE ADMINISTRATOR
PLANNER
       Mr.  Roland Gow
       P.P.A.C.G.
       27 E. Vermijo
       Colorado Springs,
       Colorado
       Dear  Roland:

            Teller County wishes to add  its congratulations on the
       completion of the first segment of Project Aquarius.

            Wastewater planning is  literally a dirty job which is
       needed  in the long range; yet often ignored when it takes
       place.

            You are aware of my apprehensions about the 208 Plann-
       ing Program in rural areas.   We have had a great fear that
       our citizens hopes will be encouraged; but that construction
       funds will not follow the massive planning efforts of recent
       years.  It is very difficult to convince rural citizens
       that  federal planning programs ever result in direct benefit
       in their areas.

            Of course, one way to break  free from this dilemma is
       through vigorous pursuit and delivery of construction funds
       assistance from that same federal government.  We do not expect
       that  every need outlined in  208 Planning be fulfilled
       immediately.  We do expect that our most urgent need be
       addressed in the very next step.
                              A-33

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                             -2-
     Many needs in Teller County are outlined in the Project
Aquarius report, however, we recognize the Village of Divide
as our most immediate and pressing project.  Septic failures
coupled with the absurdley high groundwater table make the
need for central sewage collection and treatment of utmost
importance.

     We look forward to working with you during the next phase
of Project Aquarius, and helping to bring the construction
moneys needed to fulfill planning dreams into this region.

                              Sincerely,
                              Xdrry-B.  Kallenberger
                              Land Use  Administrator
LK/bl
                          A-34

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                                  EL PASO COUNTY
                           9

                                   27 EAST VERMIJO
                            COLORADO SPRINGS, COLORADO 80903
                               August 16, 1976
Mr. Roland Gow
Assistant Director
Pikes Peak Area Council of Governments

27 E. Vermijo
Colorado Springs, Colorado

 Dear Roland:

     We have reviewed the draft of the Areawide Water Quality Management Plan
for Teller and El Paso Counties.  The report appears to be consistent with the
guidelines developed during the three Project Aquarius workshops.   As a reasoned
attempt to address both political realities and clean water standards, the plan
treads the thin and precarious1line between local  control  and federal require-
ments, environmental necessity and economic reality.  The  attempt  to do so is
the plans greatest strength and, conversely its most serious weakness.  Environ-
mentalists will undoubtedly see it as tenative in  its approach to  structural  im-
plementation (an approach that may be characterized as fragmented  regionalism)
and environmental degradation (proposals to suspend certain stream quality
standards).   Advocates of local  control and rapid  growth may view  the plan as a
potential usurpation of local initiative and private perogative.   The thing to be
remembered is that the goal of the plan is to clean up the water,  not to centralize
decision making or reflect a dominant political and economic philosophy.'  As  an at-
tempt to meet this modest goal;   water that people can swim in or  drink without
contracting disease or experiencing undue discomfort and within which other life
forms may survive, the plan outlines a mechanism which provides a  framework for
functional coordination.  The success of the region in effectively utilizing  this
framework will  not be as dependent upon the form of the administrative mechanism,
as it will be on the committment of the elected officials  and the  taxpayers to the
goal  of clean water.

Specific comments on portions of the plan follow:

1.   Administrative Structure

     The county plays a dual role in the administrative and planning structure
     outlined in the report.  As a member of the various sub-basin associations,
     the county will have a voice in the administrative decision making process.
     As a land  use regulatory agency, the county will  refer land use proposals
     to the management associations for review and comment.  The process seems a
     bit cumbersome, however, it is assumed that the working process, once esta-
     blished, will overcome potential areas of duplication.
                                    A-35

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Mr. Roland Gow
Page 2
August 16, 1976

2.   Planning Structure and Functions

     PPACG is identified as the water quality planning agency.  Included with this
     responsibility is an involvement with land use planning.  The degree and nature
     of this involvement should be more clearly defined.  The relationship between
     the comprehensive planning activities of the PPACG and the functional planning
     activities of the various entities comprising the management association should
     also be defined in greater detail.

3.   Ultimate objectives of the Plan

     The following statement should be clarified:

     "	a decentralized approach to areawide wastewater management would be
     preferred over a highly centralized approach	However, the existing barriers
     and conflicts do not preclude a change in the existing structure, if an appropriate
     plan and implementation strategy can be adopted.   A major effort should be given to
     improving and formalizing the relationships of the sanitation districts to the
     planning organization, the relation of wastewater management and planning organi-
     zation, the relation of wastewater management and planning to land use planning,
     and the degree of administrative centralization - by contract or other appropriate
     relationship."

     Is this an integral  part of the plan (i.e.  is administrative and planning central-
     ization an ultimate goal  of the plan?)?  Is the goal  of the planning mechanism
     to establish an increasing degree of centralization,  both in land use planning
     and administration?  Does the role of PPACG as the planning and coordinative
     agency imply that PPACG is seen as eventually fulfilling the regional responsi-
     bility outlined?  The county is unable to comment on  these possibilities without
     further clarification.   It appears that the statement should either be deleted
     or explained.

4.    Relationship to H.B.  1041

     The county has been given broad review and  approval authority with reference
     to both land use decision making and wastewater management under H.B. 1041.
     The strategy to be employed, in utilizing this authority has been to utilize  .
     existing regulatory mechanisms to deal  with the issues raised by H.B. 1041.
     Specific wastewater proposals and extensions will be  reviewed as part of the
     land use proposals necessitating the construction of  facilities.  For example,
     a land use proposal  (subdivision, industrial  park, etc) requiring additional
     wastewater treatment facilities or extension and  expansion of existing facilities
     will  be reviewed by both  the management associations  and the wastewater planning
     agency.   Approval  or denial  of the proposed land  use  will  be partially a function
     of the comments received  based on the referrals.   Thus a new facility will be
     reviewed by the planning  agnecy with reference to the adopted plan.   If the  fa-
     cility does not conform to the plan, the developer may be required to restructure his
     service arrangements  to conform to the  plan.   If  he is unwilling or unable to do so,
                                    A-36

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     it is assumed that the county could deny the land use change under the authority
     granted by 1041.  This approach avoids the creation of a further level of review and
     approval and coordinates the need for facilities with land use proposals.  The
     referral process is much the same as that now employed under S.B.  35.

5 .    Population Projections

     The Plan projects a population for the region of 550,000 by the year 2000.
     At present approved plats and Master Plans within the unicorporated area project
     a population of 496,000.  The uncertainties of economics, energy and regulation,
     render population forecasting marginal at best.  It appears logical to tie  the
     plan to population levels as  achieved.   What is important is that when the
     region reaches a population of 550,000 there are adequate wastewater treatment
     mechanisms, not that the legion attains  a population of 550,000 in the year 2000.

6.    Storm Drainage

     The development of a drainage manual has been a major achievement  of the 208
     process.  The administrative and planning mechanisms outlined are  viewed with
     somewhat less enthusiasm.  The initial plan, or the annual  update, should
     address the feasibility of forming an areawide drainage district or developing
     a working organization comprised of the  general purpose governments in the
     region to coordinate, review, and implement decisions relative to  both storm-
     water runoff and drainage problems.

The draft plan represents a major expenditure of time, effort, and money by the
PPACG staff, local governments, the general public, and the federal  government.
The data developed through the 208 process constitutes a valuable contribution to
the local planning effort.  Inclusion of the  designated groundwater basins  and
Soil Conservation Districts into the overall  wastewater planning and administrative
process is a valuable and necessary innovation in an area as dependant  upon ground-
water as El Paso County.  It is hoped that as the plan is revised and implemented,
the planning agency will continue and strengthen efforts to include not only local
government and technicians, but also the general public, developers, and the business
community, in the planning and implementation process.

Sincerely,
Bill Wildman
Asst. Land Use Admin.

krs
                                     A-37

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                     LEAGUE OF WOMEN VOTERS
                        OF THE PIKES PEAK REGION

                         COLORADO SPRINGS, COLORADO

                                                   August 17, 1976

Mr. iioland Gow
Director, Project Acuarius
PPA.CG
27 i3r Vermijo
Colo..Spgs., Colo. 80903

Bear Mr. C-ow:

     The Natural Resources Committee of the Pikes Peak League has
read and discussed the Draft 208 Plan for our area, and has been
informed of the criticisims directed to it by the Colorado Open
Space Council.  We do not agree  that this is an inadequate and
unacceptable plan, although we do not find it particularly innova-
tive or exciting.

     Our committee was naturally somewhat disappointed that this
plan failed to provide more social and fextfer technical solutions
to water quality problems in the area.  We also hoped that an
authority with some teeth in it might be adopted to replace the
current multitude of impotent districts.  However, we are well aware
of the political and economic conditions in the Pikes Peak region,
and vie feel that the plan you have devised correctly reflects the
desires of the people in this area.

     In fact, given the local political climate, we seriously
doubt that any other sort of plan could have been found acceptable
to those governmental entities involved.  We feel that you are to
be congratulated for devising any plan at all, and especially one
which appears to satisfy 208 goals insofar as they are attainable
in the peculiar waters of this region.
                                                  Sincerely,
                                                  Lee Ziegler
                                                  Chairman, N.R.
c c :  H ar r i s Sherman
     Gary Broetzman
     John Green
     Tess McNulty
     Mary 0.  Taylor
                              A-38

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                                                        3601 Azalea
                                                        Pueblo,  Colorado  81005
                                                        September 8,  1976
Mr. Rowland Gow, Assistant Director
Pikes Peak Area Council of Governments
27 E. Vermijo
Colorado Springs, Cplorado   80903

Dear Mr. Gow:

I am Chairman of a 15-member citizens committee known as the Fountain
Creek Commission.  The members of this Commission are appointed by
the Pueblo City Council.  The Commission has two basic objectives:

  1.  Study the Fountain Creek regarding flood control and make recom-
      mendations to the City Council.
  2.  Study the Fountain Creek for possible recreational usage and
      make recommendations to City Council.

Currently, one of the biggest issues in Pueblo is related to flooding and
flood prevention on the Fountain Creek.  I cannot over-emphasize the
amount of concern which this issue has generated in Pueblo.

As a result of that concern, the Fountain Creek Commission, the Pueblo City
Council, and the Pueblo Area Council of Governments has been actively pur-
suing some type of flood control assistance from the U. S. Army Corps of
Engineers and the U. S. Congress.  In 1974, we learned that the Congress
had. authorized construction of a dam on the Fountain Creek just north of
the Pueblo City Limits.  In February, 1976, funds were appropriated to the
Albuquerque District Office of the Corps of Engineers to initiate the
initial phase of the engineering design study for the dam.

We have had several meetings with representatives of the Corps of Engineers
to discuss the proposed Fountain Dam.  The District Engineer and several
members of his staff cane to Pueblo in November, 1974.   In March, 1976,  two
staff members came to Pueblo to meet with the Fountain Creek Commission.  In
May, 1976, the District Engineer came to Pueblo for a public hearing on the
proposed dam.

Throughout the discussion on the proposed Fountain Dam, we have been told
repeatedly that the Fountain Dam cannot be economically justified unless a
permanent recreation pool is maintained behind the dam.
                               A-39

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Mr. Rowland Gow
Page Two
September 8, 1976
This brings me to the point  -f  this  letter.   In order for a permanent
pool with recreational benefits  to become a reality, the quality of the
water must be maintained at  .=. level  which will accommodate body contact
sports. .We understand that  the  Pikes Peak Area Council of Governments
under the Section 208 Water  Duality  Study is  seeking a change in the classi-
fication of the Fountain River  from  B-2  to A-2.  We strongly support such
a change.

However, we also understand  that three variances are being sought on
oxygen, clorine residual and ammonia.  The Fountain Creek Commission of
the City of Pueblo strongly  objects  to these  three variances.  A higher
standard of water quality is absolutely necessary if the Fountain Dam is
to ever become a reality.  And, as I mentioned earlier, this is one of the
highest priority projects in the Pueblo Metropolitan Area.

We respectfully ask that this factor be taken into consideration in your
deliberations.
Thank you for your assistance.


                                   Sincerely,

                                   Dorothy Urban,
                                   Chairman
DU: Trail
cc: • Colonel R. E. Leonard, District Engineer
     Mr. Harris Sherman, Colorado Water Quality Control Commission
     Charles "Tommy" Thomson, Southeast Colorado Water Conservancy District
     Gene Fisher, Pueblo Regional Planning Commission
                               A-40

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      PIKES  PEAK AREA COUNCIL  OF  GOVERNMENTS

                         MICHAEL J. MEEHAN
                           Executive Director
27 EAST VERMIJO
COLORADO SPRINGS. COLORADO 80903
PHONE  (303)471-7080
September 27, 1976
Ms. Dorothy Urban
Fountain Creek Commission
3601 Azalea Street
Pueblo, Colorado 81005

Dear Ms. Urban:

Thank you for your recent letter regarding the Pikes Peak Region
208 Plan.  Your support for the A2 classification is appreciated,
but we would ask you to reconsider your opposition to the exceptions
requested.  It is very doubtful whether any of the exceptions would
affect the water quality of Fountain Creek as it crosses into
Pueblo County.

The exceptions we have requested include the following:

     1.  Dissolved Oxygen - requested to be 4 ing/1 for only 1000
         feet (the mixing zone) south of the Colorado Springs
         sewage treatment facilities.  Our observed minimum DO,
         about 4 miles south of the City of Fountain is  about
         7 mg/1 - which is well above the Al standard.

     2.  Ammonia is toxic to aquatic life (especially fish) in
         concentrations that depend on the acidity of the water
         and its temperature.  Since we do not believe Fountain
         Creek can be a fishery we have recommended an exception
         for ammonia.  This action was carefully considered in
         light of our genuine desire to improve the quality of
         Fountain Creek.  However, the economic burden would be
         considerable.  Our selected alternative suggests treat-
         ment costs of 15 cents per 1000 gallons for Colorado
         Springs.  With ammonia removal the costs would  rise to
         28 cents per 1000 gallons.  In other words the  difference
         in treatment costs for Colorado Springs alone would be
         $260,000 per day at a daily flow of 20 million  gallons.

         Should you persist in requiring no ammonia exception and
         should the State agree with you, then that extra cost
         would have to be added to the cost-benefit ratio of your
         suggested impoundment.
                            A-41

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     uoro'cny  ui'Daii
                                                          " ^7
          In  any  event,  ammonia will decay before it reaches the
          County  line  and  the.  impact on Pueblo County will not be
          severe  -  especially  given the frequent zero flow conditions
          which occur  in that  area.

      3.   Chlorine  is  toxic  to fish in certain concentrations but
          at  this time chloi'ine is the most cost-effective disin-
          fectant,  and its application is necessary for the reduction
          of  pathogenic  bacteria  in treated sewage.  A small residual
          of  chlorine  is left  in  the stream, but this normally dis-
          sipates quickly  after the introduction of discharge to the
          stream.  In  terms  of a  recreational pool in Pueblo County,
          I do not  think that  our excepted chlorine residual will
          affect  it chemically.   It could have a beneficial effect
          in  reducing  the  number  of bacteria entering the pool,
          thereby making the water much safer for body contact uses.

          You may be interested to know that the State, so far, has
          ignored the  Project  Aquarius recommendations regarding
          fecal coliform.  The plan recommends effluent limits of
          200/100 ml;  the  State is now issuing permits allowing up
          to  12,000 per  100  ml in the effluent of some treatment
          plants.

I will be happy  to discuss  these points at length with you and your
Commission,  but  certainly hope you will modify your stand on our
proposed  exceptions.
Sincerely,
4^ol
Roland Gow
Assistant Director
sw
cc:
     Evan Dildine, WQCC
     Terry Anderson, EPA
                          A-42

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                     RESOLUTION CONCERNING THE WATER QUALITY
                        OF THE FOUNTAIN CREEK UPON ENTRY
                     —	-  -INTO-PUEBLO COUNTY
          IvHiilU-AS, the Pueblo Regional Planning Commission (PRPC) has been assigned

responsibility by the Pueblo Area Council of Governments (PACOG) for the Section

208 Water Quality Management Planning Program; and

          WHEREAS, the Pikes Peak Area Council of Governments (PPACOG) has under-

way its Section 208 water quality study for its jurisdiction; and

          WHEREAS, the draft of the Areawide Water Quality Management Plan

for El Paso and Teller Counties has been submitted for PACOG review and comment

no later than July 6, 1976; and

          WHEREAS, the PRPC 208 staff have reviewed the draft document;

          NOW THEREFORE, BE IT RESOLVED that the Pueblo Regional Planning Commission

recommends to the Pueblo Area Council of Governments for referral of this recommen-

dation to the Pikes Peak Area Council of Governments and the Office of the Governor

that the Pikes Peak Area Council of Governments give every consideration to

establishing as a minimum the water quality standards prescribed for Fountain

Creek as are presently existing. •--• •	-	 -  	
INTRODUCED
                                             APPROVED:
                                                          v
                                                                             1976
                                             Marvan Stein,  Chairman
ATTEST:
        	
        Savage, Secretary
                                    A-43

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                                EXECUTIVE  CHAMBERS

R.CHAHi, D. ..AMM                 .             DlSNVKK
   Go vein or
                                            November 17, 1976

  Mr.  Robert Isaac, Chairman
  Pikes Peak Area Council of Governments
  27 East Vermijo
  Colorado Springs, Colorado  80903

  Dear Mr. Isaac:

      This is in response to the 208 Plan prepared by the Pikes Peak Area Council
  of Governments, a draft of which was submitted to the State in June and a more
  final, version in August.  Our letter of August 3, 1976 provided preliminary comments
  on the planning document and pointed out that we'were pursuing a coordinated response
  within State government, particularly with the Water Quality Control Commission.

      After considerable discussion by the Commission and other pertinent State agencies,
  the consensus is that the plan provides a sound base for improving water quality
  management within the two-county area.  The proposed management associations would
  provide an opportunity to considerably improve the fragmented approach for waste--
  water treatment that now exists in the area.

      Before the plan can be submitted to the Governor for certification or conditional
  certification, we believe that several points of concern need to be further addressed
  to the satisfaction of both the Commission and the 208 Executive Committee under
  the Planning Coordinating Council within the Executive Branch.  As you may know,
  we have adopted a review procedure in which the 208 Executive Committee relies upon
  the Commission for approval of the specific water quality issues in the plan..  The
  Committee expands upon the Commission position to reflect upon more generalized
  water management concerns and issues.  This we have done herein in accordance with
  the EPA program regulation.

      Attachment 1 contains comments from the 208 .Subcommittee of the Water Quality
  Control Commission emanating from a general discussion on the water quality features
  of the plan at the last Commission meeting.  These comments address the water-quality
  goals and objectives of the plan and associated wastewater treatment levels.  Beyond
  the comments of the Subcommittee of the Commission (not yet reviewed by the full
  Commission), the 208 Executive Committee has identified several matters pertaining
  to the growth and development projections, management system, and ongoing planning
  that need further attention, as shown, on attachment 2.

      All comments contained in the two attachments have been discussed in general
  with Roland Gow.  We are well aware of the program deadline for your area and the
  need to proceed expeditiously.  Our hope is to work with you and the COG staff in
  striving to resolve and clarify these matters to the extent possible at this time.
                                        A-44

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Mr. Isaac
November 16, 1976
Page Two


We are also aware, however, that this is the first stage of a continuing planning
process for water quality management in the two-county area and that some concerns
which cannot be reasonably resolved at this time might be properly deferred.  With
this in mind, we would like to suggest the following schedule:
        *  (see note below)
        *  Response on the comments contained in attachment 2 by December 10.

        *  A local public meeting during the week of December 12, 1976 to permit
           comments from local governmental officials and interested citizens.

        *  Any addendum to the plan should be submitted by December 31.  That
           addendum .would consolidate the previous responses made and address
           any new iss.ues or comments raised at the public meeting.  The addendum
           would need to be adopted and submitted by the Council.

        *  Formal action on the water quality provisions of the plan by the Commission
           at the January 4, 1977 meeting.

        *  Action on the plan and the management agencies by the 208 Executive
           Committee by January 14.                            .

        *  Action on the Plan by the Governor and transmittal to EPA by January 21.

    This is an ambitious schedule and will need the cooperative effort of all
parties involved.  Although the State needs to act promptly, it also needs to act
responsibly.  The need for a public meeting during mid-December reflects a concern
for the State to hear directly from your community leaders who will need to accept
the plan to help assure its success.  We trust that you share this concern and will
take the lead in arranging for the meeting and in helping in its organization.

    Thank you for your patience.  This is the first 208 Plan within the State and
we are all learning how to respond to the program need.  Please get in touch with
Gary Broetzman or me should you care to discuss the program further.

                                          Sincerely yours,
                                           Jim Monaghan
                                           \ssistant to Governor
                                             for Natural Resources
 Concur:   f

                                Co-sslon
 Cf-   Terrv Anderson   EPA                    features of the plan at its December 7
                                             meeting.   -(inadvertently omitted in the
                                             original letter, but subsequently discussed

      Frank Rozch                            with *' Isaac'>
      Phil  Schmuck
      208 Executive Committee
      Water Quality Control  Commission
      208 Policy Advisory Committee
                                      Ar45

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                                                                    At I iK:ilin«-'l'
                   COMMENTS FROM 208 SUBCOMMITTEE OF THE
                       WATER QUALITY CONTROL COMMISSION

           (Note:   This statement has not been officially adopted
            or approved by the Commission.   Any questions regarding
            this  document should be directed to Dr.  Robert Weiner
            of the Subcommittee)

1.  Proposed water classifications  in 208 plans should be directed
    towards the realization of the  1983 water quality goals as set
    forth in PL 92-500.

2.  Wherever attainable, proposed classifications must be equivalent
    to the present classifications or uses, whichever is more stringent.
    Attainability is to be judged by whether or not the classification
    quality paramaters can be achieved by any recognized technical
    method of treatment.  Unattainabi 1 i ty by this criteria is considered
    as permanent and would require  that the proposed classification be
    downgraded from the present classification or use.  Such an action
    will be evaluated by the criteria in the non-degradation statement
    of the adopted regulations.

3.  In some cases, the present classification or use is attainable but
    it is felt that the steps required to achieve the required water
    quality are not warranted by the benefits received.  Such a situa-
    tion might exist because of non-water-quality conditions such as
    are discussed in item **, below.  This situation is considered as
    temporary.  The proposed classification should be equivalent to the
   • present classification or use and an exception should be requested.
    With an exception, the classification is not lowered but temporary
    exceptions are made for certain quality parameters in spatially
    limited portions of water.  A proposed water quality exception must
    be accompanied by a compliance schedule for reaching the classifica-
    tion.  The compliance schedule should be realistic and may extend
    beyond 1983.   Where state and federal funding are needed, the com-
    pliance schedule may be indefinite in the timing of some of its
    steps.  In general, requests for temporary exceptions are preferred
    over the more permanent downgrading, wherever it appears that the
    conditions causing the current non-compl iance might be temporary
    within a 20 year time-frame.  Retaining a classification higher
    than the present usage will serve as a reminder that the degrading
    conditions are correctable and will increase the priority for
    funding to correct them.

J*.  The classification system is designed to set forth the water quality
    parameters necessary to qualify given portions of the state's waters
    for certain uses.  It is not concerned with non-water-quality conditions
    which also might be required for the intended use.  Thus, conditions
    such as public access, channeling, flow velocity, etc., which are not
    within the jurisdiction of the Water Quality Control Commission are
   ..not taken into consideration.  Although such conditions may limit the
    benefits received from, control measures and, therefore, might be
    the basis for requesting exceptions, they frequently are temporary in
    nature and are not relevant to the issue of water quality.  The
    attainability of a classification refers only to the appropriate
    water quality parameters in the adopted water standards.

5.  All proposed publicly-owned treatment works must provide secondary
    treatment as a minimum.  Industrial treatment must be best available
    technology.  If the water classification cannot be achieved by secondary
                               A-46

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                           -2-

treatment, then higher level treatment must be proposed or exceptions
or downgrading must be requested.  When planning a compliance program
to eliminate temporary exceptions, it is preferable and often more
cost-effective to plan for the best overall treatment right away, rather
than seek the most economical first step of treatment, which must be
followed by add-on treatments later.  This approach will, in general,
shorten the time period of the compliance schedule and because of
the higher water classification,  increase the priority for funding of
treatment works.

In the PPACG 208 plan every effort should be made to retain as high a
classification as possible on water segments such as Lower Fountain
Creek below the Colorado Springs treatment plant.   Since technical
attainability of aquatic life water quality standards is possible, the
issue is whether or not it is worthwhile.   Therefore, exceptions should
be requested and the accompanying compliance schedule should reflect the
uncertainties of state and federal funding and, also, non^-water-quality
parameters affecting these decisions.
                          A-47

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                       COMMENTS FROM THE 208 EXECUTIVE COMMITTEE
     The 208 Executive Committee has raised several matters pertaining to the PPACG
208 plan for El Paso and Teller Counties.  These matters need to be addressed further
before final action can be taken on the plan enroute to the Governor.   In general,
the following comments and issues fall within the broader categories of population  and
growth projections, mamagement systems, response from elected officials, and continuing
planning.
POPULATION AND GROWTH PROJECTIONS                        '
     The 208 plan is based upon a projected growth for the two counties of 550,000
by year 2000 as compared to the most recent State projections of 393,000 to 480,000
for that area.  Discrepancies between local and State projections are of concern,
particularly along the urban growth centers.  The State is reluctant to accept the
higher COG values as the basis for this plan and the associated grant supported
projects until a better relationship is known between those values and the State
growth and development policies being developed under the State 701 program and the
air quality management program underway for the Colorado Springs area.  At this time,
perhaps a better understanding can be gained regarding the discrepancies in the projections
in terms of the data and policy imput.  Specific comments that need response are:
     *  The population data for the regional projections should be put into the
     State model to determine if the basic computer models contribute to the discrepancies.
     *  The basic growth policies used in the COG model with respect to timing, intensity,
     and patterns of growth should be delineated.
     *  A comparison  of the growth policies between the regional 208 and 701 programs
     is needed.
     *  A comparison is also needed between the land use programs in the individual
     communities and the regional growth policies incorporated in the 208 plan.
MANAGEMENT SYSTEM
     The management system included in the plan would seem to be a significant improvement
over the currently frangmented  array of governmental entities involved in water quality
  :                                   A-48

-------
management within the two-county area.  The proposed system, however, appears to



lack a closely integrated system for the implementation of all features of the plan



responsive to Section 208 (c)(2) of PL 92-500.  Concern still exists over whether



the proposed management associations and agencies will  have sufficient authorities



and capabilities to implement the plan.  The relationships and coordinative procedures



among agencies with wastewater management responsibilities (the management association),



the growth and development responsibilities (local governments), and the non-point



source responsibiliites need clarification.  The following comments need to be.



addressed:



    *  A summary of legal authorities vested in each of the member governmental



    entities in the proposed management associations is needed with an explanation



    of the extent and method for transferring authorities to each of the management



    associations.



    *  An explanation is needed over the role of the proposed management associations



    in assuring that activities within member communities take place in conformance



    with the plan.



    *  A response toward the plan and the management associations is needed from all



    or most of the elected bodies of the affected local units of governments.



ONGOING PLANNING AGENCY



    The plan identifies the PPACG as the ongoing 208 planning agency.  Although this



may be a logical outgrowth of the plan, the current internal problems of the COG may



present some difficulties in support of that position.   Response is needed on the



following points:



    *  The status of the composition and future of the Council of Governments.



    *  The capability of the COG to provide representative planning over the two-



    county area.
                                     A-49

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      PIKES PEAK  AREA  COUNCIL OF GOVERNMENTS
                         MICHAEL J. MEEHAN            27 EAST VERMIJO
                           EK.CUUV. Dlr.ctor              COLORADO SPRINGS. COLORADO 80903
                                                    PHONE (303)471-7080
 November 30,  1976

                                                      DEC  S 19/6
 Mr. Jim Monaghan                                     ;., ..... -'.„.:..:!»
 Assistant  to  the Governor for  Natural  Resources/jr and V.'i.^ fic^cus
 State  Capitol,  Executive Chamber
 Denver, CO 80202

 Dear Mr. Monaghan:

 Thank  you  for your  letter of November 17,  1976, in response to the
 Pikes  Peak Region's  '208'  Plan.  We have responded to the Water
 Quality Control  Commission's subcommittee  comments in a separate
 document  (enclosed) ,  and I wish to address the further issues
 raised by  the '208'  Executive Committee.

 First,  let me address the proposed schedule.  Draft copies of the
 response to the  Commission's Subcommittee  have been mailed to the
 Commission and  its  staff.   Since PPACG  could not meet until
 November   30, 1976,  we had no choice but to issue a draft statement.
 Mr. Gow will  be  able to  discuss  the action taken by PPACG and get
 some firm  commitment from the Commission as arranged at its
 November 3 meeting,  on December  7.

 We do  not  feel a further public meeting on the plan is necessary.
 Our planning  process  fully included the public at key points, and
 we received comments  on  the plan from both public and private
 entities.   Further discussion with the public, at this juncture,
 would  seem to be  both duplicatory and unproductive.   Our inter-
 pretation  of  the  Colorado  Water Congress'  letter which appears to
 have prompted the public meeting request is not that the Commission
 seek more  public  input to  the '208' plans  but that the Commission
 strongly consider the public  participation that Occurred during the
 individual area's planning  processes.

Finally, as regards the  schedule, we hope  you will take no longer
than January  21,  1977, to obtain the Governor's certification.  We
have  already lost a  great  deal of momentum in getting the plan
implemented,  and our grant runs out on December 31, 1976.  Now to
the specific comments .

 (1)  Population and Growth  Projections

Please refer to Mr.  Gow's memo to the 208 Coordinating Council and
the Water Quality Control Commission, dated August 24,  1976.   At
pages 7 and 8 you will find a discussion of the population questions.

                            A-50

-------
 Jim Monaghan                    2                 November 26,  1976
 Further reference to the Plan,  pages  106  to 112,  will  provide  addi-
 tional  documentation.   Finally,  reference to the  enclosed volume
 Alternative Population and Employment Forecasts,  El Paso County
 1980-2000,  Detailed  Report will  answer any questions on methodology.
 Our staff has  been in  touch with the  State on the computer models
 and has provided  input to your  model.   The attached letter dated
 August  12,  1976,  is  indicative  of the material provided.

 Part 1,  of  Chapter III of the Plan, pages 99-105,  provides a good
 summary of  regional  growth policies.   Pages 106-112 illustrate the
 timing  and  intensity of growth  by area, by five year increments.
 The growth  policies  were adopted by PPACG on April 9,  1975, and
 reflect the local  areas'  desires.  We cannot conceive  of having
 different 208  and  701  growth projections  or policies,  hence consis-
 tency has always been  a feature  of our efforts.   What  you see in
 the plan is what we  have.

 PPACG revises  its  population data on  a continuing basis, and will
 continue to do so  in order to provide the best possible input to
 local plans and programs  in both the  public and private sectors.
 We  would welcome your  assistance in that  effort but, at this time,
 do  not  believe that  continued discussion  is any cause  for non-
 certification  of our plan.

 (2)   Management System

 Summaries of the legal  authorities (relative  to water  quality
 management)  may be found  in the  enclosed  document An Evaluation of
 Waste Treatment Regulatory Practices,  1976.  The mechanism for esta-
 blishing the management  association is a  joint exercise of powers
 agreement,  as  noted  on page 139  of the Plan.  Pages 124 to 139
 indicate the alternatives  examined and the  function of the manage-
 ment  association (more  specifically at pages  134 and 135).   Chapter
 VIII  discusses the powers  of the designated management agencies (the
 association, etc.),  as well  as the continuing planning process.
 Since the associations are  proposed as designated agencies,  this
 assures  that water quality management activities will conform with
 the Plan.   In addition, we  expect the general purpose governments
 to  request  review and comment on land development proposals  from
 the designated agencies.  However, land use control is the pre-
 rogative  of general purpose  government and that prerogative  will not
 be  relinquished in the Pikes Peak Area.

 Responses from local officials to the Plan are contained in  the plan
 document; you have already  received copies of correspondence from
a number of local governments.   We feel these comments are more
than adequate,  especially when backed by our planning process.

 (3)  Planning Agency

At the present time the PPACG membership is made up of Colorado
Springs,  Fountain, Manitou Springs, Palmer Lake,  Monument,  Green

                             A-51

-------
Jim Monaghan                     3                 November  26,  1976


Mountain Falls, Woodland  Park, Cripple  Creek  and Fairplay.  The
following governments are eligible  for  membership, but are  not  now
members:  El Paso, Teller and Park  Counties,  Ramah, Calhan, Victor,
and Alma.

In  January, 1977, we fully expect El  Paso County to re-enter the
PPACG.  We shall continue to work with  Teller and  Park Counties in
order to get them back into the  organization.

Given our organizational  structure  and  prospects we feel we can
continue to provide representative  professional planning services
to  the whole of the two-county area,  and beyond.  This capability
will be enhanced by a water quality advisory  committee composed of •
the designated management agencies  (including Teller County) once
that Committee is established early in  1977.

If  you have further questions on our  Plan please contact me.

Sincei
          *
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                             APPENDIX B



                        EPA MAILING LIST FOR

                        DISTRIBUTING THE EIS
NOTE:   Recipients of the Final  EIS are indicated by an  asterisk (*)
       The others on the list  received a  copy  of the  draft  EIS  but
       did not  submit comments.

-------
Mr. Teddy Adams
Northeast Garden Ranch Homeowners
  Association
Mr. Kenneth Baird
First National Bank
Mr. Sigurd Aga, Mayor
City of Fountain
 Mr. Alvln  E.  Born,  Mayor
 City  of Woodland  Park
Mr. Glenn Alexander
Donala Water & Sanitation District
 Mr.  Don  Bergen
 Colorado Springs,  Colorado
Mr. Oscar L. Anders
Fountain, Colorado
Mr.  Ed Baldwin, Director
Colorado Springs  Planning  Department
Mr. Andy Anderson
Homebullders Association of
  Metropolitan Colorado Springs
Mr. Huitt Barfoot
School  District #2
Mr. Arthur M. Anderson
Victor, Colorado
Mr. Edwin Bland
Monument, Colorado
Mr. Ray Anthony
West Side Action Group
Mr. J. W. Bradbury
Woodland Park, Colorado
Mr. & Mrs. Arthur Anderson
Bear Creek Canyon Association
Mr. Gary Bohrer, Mayor
Town of Ramah
Mr. Art Anderson
Victor Chamber of Commerce
Mr. Wayne Bricker, Superintendent
Harrison School District
Mr. Richard Anderson
Bureau of Land Management
Mr. Don Brinton
State Representative
Mr. Robert Andreason
Cascade Property Owners Association
Mr. Charles Bradley, Chairman
Teller County Board of Commissioners
Mr. John Asbury, Superintendent
A1r Academy School District, UAFAA
Dr. A. J. Bredall, Superintendent
Widefield School  District
Mr. Norton Bain
Colorado Springs, Colorado
Mr. D1ck Brown, City Administrator
City of Fountain
                                     B-l

-------
Mr. Don Brown, President
Monument Sanitation District
  Mr. John Cesario
  Ivywild Sanitation District
Mr. Gary Broetzman, 208 Coordinator
State of Colorado
  Mr. Stephen Chuck, Chairman
  City, County, PPACG Liaison Committee
Mr. Will Brown
Bass Realty
  Mr. Corky Cline
  Homeowners of Village Seven
Mr/ Kenneth Burkett, Teaching
  Administrator
Hanover School District
  Mr. Howard Cloud
  Tri-Lakes Businessman's Association
Mr. Joe M. Cantrell
Security, Colorado
  Ms. Evelyn Coats
  Peyton, Colorado
Dr. & Mrs. James Busey
Manitou Springs, Colorado
  Mr. Bob Cole
  Northeast Civic Association
Mr. Ralph K. Calabrese, Superintendent
Calhan School District
  Chairman
  Colorado Mountain Club
  Pikes Peak Group
Mr. William Callahan, Superintendent
Cheyenne Mountain School District
  Chairman
  Colorado Springs Park and Recreation
    Board
Mr. & Mrs. Ron Campbell
Crystal Hills Homeowners Association
  Colorado Wildlife Federation
  Boulder, Colorado
Mr. Tod Campbell
Colorado Springs, Colorado
  Mr. William Comer
  State Senator
Mr. Gene Childs, Superintendent
Skyway Park Water & Sanitation
  Mr. Frank Conlon
  Woodmoor Water & Sanitation District
Mr. Gene Clare
Florissant, Colorado
  Mr. Daniel J. Connor
  Colorado Springs, Colorado
Mr. Robert Case
Colorado Springs, Colorado
* Council on Environmental Quality
  Washington, D. C.
                                     B-2

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  W. Roger Craig, Lt. Colonel
  USAF Academy
Mr. Howard Emrich, President
Broadmoor Inprovement Society
  Mr. Thomas R. Cross, Town Attorney
  Town of Palmer Lake
Environmental Defense Fund
Denver, Colorado
  Mr. William Curtis
  Falcon  Estates Association
Mr. Robert Ermel
District #10 Water Commissioner
»i Mr.  Robert Daniel
  Colorado Springs, Colorado
Mr. Tom Evans
Colorado Springs, Colorado
  Mr. Gary  L. Danks
  Town of Green Mountain Falls
Mr. Harold Evetts, Teaching
  Administrator
Miami-Yoder School District
  Mr.  L.  B. Delabar
  Ent/Golf Acres Area
Mr. Waldo Ewing, Superintendent
Peyton School District
  Mr.  Evan  Dildine
  Colorado  Water Quality Control
     Commission
Federal Highway Administration
Denver, Colorado
  Mr.  Thomas  Doherty, Superintendent
  C.  S.  School  District  #11
Mr. Gene Fisher, 208 Project Director
Pueblo Area Council of Governments
   Dr.  Charles  H.  Dowding, Jr., Admin.
   City/County  Health  Department
Mr. William Flanery
State Representative
   Mr.  George  Dragosh
   Colorado  Springs, Colorado
Dr. Dean Fleischauer, Superintendent
Fountain School District
   Mr.  Steven  Durham
   Colorado  Springs, Colordao
Mrs. Mary Fluegel, Superintendent
Edison School District
   Mr.  Howard  Ehlers,  Secretary
   Rainbow  Valley  Water  District
Mr. W. E. Fluhr
Colorado Springs, Colorado
   Chairman
   El  Paso County  Park  and  Recreation
    Board
Ms. Alice Foote, Secretary
Palmer Lake Sanitation District
                                       B-3

-------
 Mr.  Norman C.  Foote,  Administrative
   Assistant
 Lewis Palmer School  District
 Mr.  Francis  Guthrie
 Calhan,  Colorado
 Mr.  G.  N.  Free, Jr.
 Chapel  Hills, Cheyenne Canyon and
   Cherokee Water and Sanitation Districts
 Mr.  Charles  Haase
 Colorado  Springs,  Colorado
 Friends of the Earth
 Denver, Colorado  80206
 Mr.  Alfred  A.  Hagedorn
 Colorado  Springs,  Colorado
 Ms. Kala Fuller
 San Miguel Street Association
 Mr.  George Hemming
 Teller  County  Health  Department
 Mr. Paul Gerdes
 Colorado Springs, Colorado
Mr.  Dick Henninger
Colorado Springs, Colorado
 Mr. Kimball E. Goddard
 U. S. Geological Survey
Mr. Don Henry
Old Garden Ranch Homeowners
  Association
 Mr. Fred Goldsby, Chairman
 Academy Water & Sanitation District
Dr. Arthur C. Herzberger
State Representative
 Mr. Ted Goodlng
 Yorkshire Estates Association
Mr. William Hinkley, Chairman
Public Services Commission
*Mr. Roland Gow, Executive Director
 Pikes Peak Council of Governments
Mr. William J. Hughes
State Senator
 Chairman
 Green Mountain Falls Planning
   Commission
Mr. Barry Huebert
Colorado Springs, Colorado
 Mr. Steve Guass
 El Paso County Highway Department
Mr. Robert Hunt
Pleasant View Estates
 Mr. Russell A. Gugeler
 Westwood Lakes Water Board
Mr. Robert M. Isaac, Chairman
Pikes Peak Area Council of Governments
 Mr. Bill GulUkson, President
 Izzak Walton League
Mr. Richard Janltell
Garden Valley Water & Sanitation
  District
                                        B-4

-------
  Mrs.  Winnifred  Jenson
  Colorado Springs,  Colorado
Mr. Warren Langer, Mayor
Town of Monument
  Col.  Samuel  Jordan
  Mesa  Northwest  Homeowners  Association
Col. Richard A. Leonard, District Engineer
Albuquerque District Corps of Engineers
  Mr.  Larry Kallenberger
  Teller County Planning Department
Mr. J. W. Lucas, Regional Forester
U. S. Forest Service
  Mr.  J.  D.  Keenon
  Fountain,  Colorado
Mr. Mel Lucero
Vista Grande Area
  Dr.  Ray Kilmer,  Superintendent
  Lewis  Palmer  School  District
Mr. James G. Lunghofer
Pleasant Valley Association
  Mr.  Larry  King,  Mayor
  Town of Calhan
Mr. Jim Mayes
Fountain Chamber of Commerce
  Mr.  Frank  Klotz,  Chairman
  Republican Committee
Mr. James E. McClelland, President
Black Squirrel Soil Conservation
  District
  Mr.  Bob Kochera
  Manager for Wastewater  Division
Mr. James McCurdy
Bonnyville Homeowners Association
  Mr.  John  Kolisek
  Colorado  Springs,  Colorado
Chairman
Manitou Springs Planning Commission
  Mr.  Ken  Kramer
  Colorado Springs,  Colorado
Mr. Rudy Melena
Conejos Street Area
  Mr.  Bob Knudson
  Southeastern  Colorado Springs
    Protection  Association
Ms. Helen McMillan
Holland Park Community Association
  Ms.  Mary Kyer
  Colorado Springs,  Colorado
Mr. Gary Miller, Superintendent
Manitou Springs School District
* Honorable Richard  D.  Lamm
  Governor of Colorado
Mr. George N. Miller, Mayor
City of Manitou Springs
                                         B-5

-------
Mr. Tom Mllligan
Teller County Land Use Administrator
Mr. Jack Owen, President
Westwood Lakes Water Board
Mr. Kingston G. Minster
State Senator
Mr. R. L. Palmer, Mayor
Green Mountain Falls
Chairman
Monument Planning Commission
Chairman
Palmer Lake Planning Commission
Mr. John Moseley, Executive Director
Colorado Springs Board of Realtors
Mr. Frank J. Parisi
Pulpit Rock Land Company
Mr. Robert F. Mott, Director of
  Administration
El Paso County Community Development
Mr. Charles B. Parker, Vice President
Cherokee Water District
Mrs. James Munson
State Representative
Mr. Evert Paulson
Calhan Sanitation District
National Wildlife Federation
Denver, Colorado
Mr. Bud Pelffer
Two Mile High Club of Cripple
  Creek
Mr. Don Nielson, District Conservationist  Mr. Jim Perry
Colorado Springs Work Unit                 Widefield Homes Water &
                                             Sanitation District
Capt. David A. Nuss
Peterson A1r Force Base
Mr. Harold Peto
Teller County Water & Sanitation
  District #1
Mr. Lawrence D. Ochs, Mayor
City of Colorado Springs
Mr. Jim Phillips, Director
Colorado Springs Department of
  Public Utilities
Mrs. Patti F. O'Rourke
Water Quality Control Commission
Mr. & Mrs. John Pieper
Calhan, Colorado
Mr. Tom Osterman
Colorado State Forest Service
Mr. Donald C. Pol ley
Fountain, Colorado
Mr. Frank Otoupalik
City/County Health Department
Mr. Jack Power
Cascade, Colorado
                                     B-6

-------
Mr. John Price
Woodmoor Water & Sanitation District
 Mr. James R. Ross, Executive Director
 ENPAC
Mr. El son Pritz
Colorado Springs, Colorado
 Mr. Max Rothschild, Director
 El Paso County Department of
   Public Works
Mr. Daniel E. Quigley
Colorado Springs, Colorado
 Mr. Frank Rozich, Director
 Water Quality Control Division
 Colorado Department of Health
Ms. Charlotte Quist
Colorado Springs, Colorado
 Mr.  Stephen Sampson
 Colorado Springs,  Colorado
Mr. Chuck Reese, Secretary
Forest View Acres Water District
 Ms.  Ann Sandmore
 Eastborough Area
Mr. Bev Reinitz
Northend Homeowners Association
 Mr.  Arthur Sapp
 Colorado Springs,  Colorado
Mr. Charles E. Reser, Supervisor
School District # 11 Representative
 Mr.  Vern  Schmitt
 Pike National  Forest
Mr. Dave Roberts
Building Inspector
City of Cripple Creek
 Mr.  Ernest  Schwarzer
 Chelton  - LaSalle Streets
  Neighborhood Association
Mr. Bruno Rancis
Manitou Springs Southside
  Homeowners Association
Mr. Frank Reichardt, President
Jimmy Camp Sportsman Group
Mr. Tom Remple, Manager
Security Sanitation Water District
Mr. Ted Schubert
High Plains Land Use Commission


Chairman
Security Parks and Recreation Board
Mrs. Lynn Seese
Council of Neighborhood
  Organizations
Mr. Ron Robenson
Colorado Springs, Colorado
Mr. James Severson
Colorado Springs, Colorado
Mr. B. G. Robinson, Mayor
City of Cripple Creek
Mr. John Sherak
Woodmen Water & Sanitation District
                                    B-7

-------
  Mr. Harris Sherman, Executive Director
  Colorado Dept. of Natural Reources
* State Clearinghouse
  Office of State Planning
  Mr. John Shoemaker
  Cascade Public Service Company
* State Historical Society
  State Archaeologist
  Mr. Golden Simmons
  Cragmor Neighborhood Association
  Mr. Marvin Stein, Chairman
  Pueblo Regional Planning Council
  Mr. Luther Slabaugh
  Mdhument, Colorado
  Col. Albert Stoll, Chairman
  Committee for Preservation of
    Black Forest
  Mr. Bruce Somners, Chairman
  Ecology & Environment
  Colorado Springs Chamber of Commerce
  Ms. Mary C. Taylor, President
  Colorado Open Space Council
  Mr. Eric W. Sonderman
  Colorado Springs, Colorado
  Mr. Ralph Taylor, Superintendent
  Cheyenne Canyon Sanitation District
  Ms. Ann Sorton
  Northeast Garden Ranch Homeowners
    Association
  Ms. Ruth Taylor
  Rustic Hills Homeowners Association
  Mr. Thomas Speer
  Colorado Springs, Colorado
  Chairman
  Teller County Planning Commission
  Mr. Ted Spiewak
  Red Rock Valley Estates Water District
  Mr. John Thels
  Golden Hills Association
  E. J. Sprague
  Colorado Springs, Colorado
  Mr. David Thomas
  Aiken Audubon Souciety
  Mr. Lowell R. Stanley
  Ampex
  Ms.  Ellen Thomas
  Uintah & Union Area Homeowners
    Association
  Mr. John Stansfleld
  Colorado Springs, Colorado
  Mr.  Lloyd Tharp
  Colorado Springs, Colorado
* State Conservationist
  U. S. Soil Conservation Service
  Mr.  William T1edt
  Teller County Attorney
                                        B-8

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  Dr.  Donald  Tolbert,  Superintendent
  Falcon  School  District  #49
 Mr.  Carl  Wiese
 Fountain, Colorado
  Mr.  Vern  Totten,  Superintendent
  Ellicott  School  District
 Ms.  Clark  Wilder
 SPABA
* Regional  Director
  U.  S.  Bureau  of Sports,  Fisheries
    and  Wildlife, Region VI
 The Wilderness  Society
 Denver,  Colorado
* Regional  Director
  U.  S.  Department of Health
    Education and Welfare
Mr.  Bill Wildman
El Paso County  Land  Use  Department
* Regional  Administrator
  U.S.  Department of Housing and
    Urban Development
Rev. Douglas M. Williams
LOGOS
* Di rector
  U.  S.  Department of Interior
Mr. Ken Wilson, Chairman
Rock Creek Mesa Water District
  Mr.  Randall  Warthen,  Mayor
  Town of Palmer Lake
Mr. Craig Withee
DFAE, Ft. Carson
  Mr.  Jules Watson
  J.  H.  W.  Investment Company
Mr. & Mrs. Lester Wiley
Taxpayers of El Paso County, Inc.
  Mr.  Cecil  Wayman,  Chairman
  Skyway Park Water  &
    Sanitation District
Chai rman
Woodland Park Planning Commission
  Mr.  Ken Webb
  Colorado Department of Health
Mr. Bob Wunderle
Villa Loma Civic Association
  Ms.  Wynn Weidner
  AAUW
Mr. James Young
Colorado Springs, Colorado
  Mr. Andrew H. Wei gel
  Colorado Springs, Colorado
Mrs. Charles Zeigler, President
League of Women Voters
  Mr. Fred Weisbrod, Executive
    Director
  Pueblo Area Council of Governments
Mrs. Ann Zwinger
Colorado Springs, Colorado
                                       B-9

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* EPA Headquarters and Regional
    EIS Coordinators

* Mr. Jasper H. Coombes
  Chief, Engineering Division
  U.S. Army Corps of Engineers

* Mr. Mark Rey
  National Forest Products Association
                                        B-10

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                             APPENDIX C
                   COMMENT LETTERS RECEIVED BY EPA
1.  Council on Environmental Quality
2.  Pikes Peak Area Council of Governments
3.  The State Historical Society of Colorado
4.  Corps of Engineers, Albuquerque District
5.  Soil Conservation Service
6.  Fish and Wildlife Service, Colorado-Utah Area Office
7.  U.S. Department of Health, Education, and Welfare
8.  U.S. Department of Housing and Urban Development
9.  State of Colorado

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              EXECUTIVE OFFICE OF THE PRESIDENT

                 COUNCIL ON ENVIRONMENTAL QUALITY
                        722 JACKSON PLACE, N. W.
                        WASHINGTON, 0. C. 20006
                               APR 1 3 1977
Dear Mr. Green:

     This is in response to your March  22,  1977  letter to
Chairman Warren requesting the Council's  concurrence in a
shortening of the review period for  the environmental impact
statement (EIS) prepared on the 208  Water Quality Management
Plan for El Paso and Teller Counties, Colorado,  pursuant to
Section 1500.11(e) of the CEQ Guidelines.

     We have reviewed your request,  which involves maintaining
the 45 day review and comment period for  the  draft EIS, but
shortening the review period for the final  EIS from 30 to 20
days.

     Your request is based on the need  to comply with the
requirements of P.L. 92-500 that EPA approve, disapprove or
conditionally approve a 208 plan within 120 days from the
date the plan was certified by the Governor,  which in this
instance means that EPA must make a  decision  by  June 7,
1977.  Because of this exceptional circumstance, and because
the proposed plan was apparently developed  with  substantial
participation on the part of government agencies and the
general public, we concur in your request to  shorten the
review period on the final EIS to 20 days.  However, we
believe that it is important that the final EIS  adequately
address any comments received on the draft  EIS.

                                   Sincerely,



                                      -  ^ t-i
                                   Nicholas
                                   Acting General Counsel
Mr. John A. Green
Regional Administrator
Environmental Protection Agency
Region VII
1860 Lincoln Street
Denver, Colorado   80203
                                                                          \'

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      PIKES  PEAK AREA COUNCIL  OF GOVERNMENTS
                                                    27 EAST VERMIJO
                                                    COLORADO SPRINGS, COLORADO  80903
                                                    PHONE (303)471-7080
                                                        - ?'•'•
April 20, 1977
                                                        APR 2 5 197?
Mr. Terry Anderson                                f
U. S. Environmental Protection Agency Region VIII
1860 Lincoln Street
Denver, Colorado 80203

Dear Mr. Anderson:

At its regular meeting on April 13,  1977,  the Pikes  Peak Area
Council of Governments reviewed the  draft  EIS on Project Aquarius.
The PPACG has asked me to pass on the comments noted below for
your consideration in developing the final EIS.

- Page 6 -- The Draft states that the recommendations in Table 2
  are "separated into high and low priority categories based on
  PPACG 's determination of their significance."

  COMMENT:  This statement is not correct, in that PPACG has not
  listed high priority and low priority concerns as  noted in the
  draft EIS.  The. Draft is close to  correct in what  would be high
  priorities and low priorities but  has neither staff nor elected
  official sanction.  It is felt that Item 10, for example,  on the
  lower priority recommendation list is of fairly high concern to
  the Pikes Peak Region.  This relates to  the U. S.  Forest Service's
  increase in funding for the maintenance  of recreational forests.

- Page 11 — The statement is made "the State's position on the
  stream segment (i.e., Fountain Creek from its confluence with
  Monument Creek down to the Colorado Springs wastewater treatment
  plant) is that it should remain classified for fisheries and that
  the present water quality criteria should remain in effect."
  This paragraph on stream classification  also states that "the
  State did not accept all of the "208" Plan's recommendation re-
  garding stream classifications and exceptions for  water quality
  criteria for the Lower Fountain Creek segment."

  COMMENT:  The "208" Plan recommended that Fountain Creek from
  its confluence with Monument Creek be classified as A-2-C  with
  exception for chlorine residual and ammonia and for a short
  segment of stream below the Colorado Springs treatment facility
  dissolved oxygen of 4.0 instead of 5.0 mg per liter.   The
  recommended classification in the  Addendum to the  Plan which was
  accepted by the Colorado Water Quality Control Commission  was

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Terry Anderson                 2                   April 20,  1977
  that the stream be classified in this same segment as secondary
  recreation and ground water recharge.  At the present time the
  stream is classified as B-2.  Item 6 in the State's Letter of
  Certification to PPACG and to EPA indicates that the State will
  consider the recommendations made by the "208" Plan for stream
  classifications for interim decision-making,  until it reclassifies
  the streams according to a newly revised stream classification
  system currently under consideration.  The only bone of contention
  with the State was the segment of Lower Fountain Creek and, in
  fact, the intent of the State appears very clearly to be to accept
  the exceptions of chlorine residual, ammonia, and dissolved
  oxygen, for most of the Monument and Lower Fountain stream system.
  This is reinforced by the State's extension of the dissolved .,
  oxygen limitation to a point below the City of Fountain which
  was not recommended in the "208" Plan.  When the State accepted
  the Plan with its Addendum, the recommended classifications
  clearly indicated, and the State clearly recognized, that the
  aquatic life standards were not appropriate on the Fountain-
  Monument system except in the headwaters of Monument Creek, from
  its source to Monument Lake, and in the headwaters of Fountain
  Creek from Crystola Creek to its confluence with Monument Creek.
  The EIS should reflect this point of view.

  Page 11 — It is stated that "recognizing that the discharge of
  sludge into Fountain Creek by the Colorado Springs waste treatment
  plant is one of the most serious and immediate point source
  problems. ..."

  COMMENT:  The Plan did not recognize that the discharge of sludge
  into Fountain Creek was in fact a problem.  No mention was made in
  the Plan of the discharge of sludge directly to the Creek.  It is
  important to note that recent events with regard to the Colorado
  Springs sewage treatment system should not cloud the thinking of
  the writers of current reports when they reflect upon the Plan
  that was written during the early part of 1976.  PPACG and its
  staff has no knowledge of direct discharges of sludge into
  Fountain Creek.

  At the present time the City of Colorado Springs is in dire need
  of an expanded sludge handling capability.  It is diligently at
  work on this process in order to protect Fountain Creek's aquatic
  biota, its water quality, and the water quality of the Widefield
  aquifer and other water supply sources.

  Page 13 -- The report states "the State did not specifically
  designate management agencies for land use review and non point
  sources."

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Terry Anderson                 3               .    April 20, 1977
  COMMENT:  It should be borne in mind that land use controls are
  the prerogative of general purpose government and that storm
  drainage systems and individual sewage disposal permits are also
  normally operated or controlled by general purpose government.
  Special purpose governments such as water and sanitation districts
  also have the authority to control storm runoff.  These authorities
  exist in Colorado Statutes.  As a result, the State has already,
  in fact, designated management agencies for the critical activities
  of land use control and non point source pollution control.  This
  same statement would apply to Point 9 which is also raised on
  page 13 with regard to the rejection of the recommendation for
  the Upper Fountain Creek's sub-basin management agency.  In fact,
  by not designating a specific management agency the State has
  allowed the current situation of Municipal and County control to
  continue to exist until such time as the two entities in that area
  can get together on a cooperative basis.  It is fully expected
  that this will be done within the one-year period of the condition.

  Page 18 — EPA reports that the violations of the hydrocarbon and
  suspended particulate standards will occur using the population
  growth projections mentioned in the Plan.  It further goes on to
  state that the issue is one of growth, and suggests that this
  growth would result directly from the provision of expanded sewage
  services.  The recommended action here is that EPA will not parti-
  cipate in the construction funding of any wastewater treatment
  plant expansions especially in the Fountain and Security areas
  until air quality studies are completed.

  COMMENT:  Penalizing water quality because of an air quality factor
  is hardly the way to get clean water.  Emerging Congressional
  philosophy appears to be that once air quality maintenance plans
  and transportation control strategies are developed,  then if im-
  plementation is slow, instead of withholding sewage treatment
  funds, transportation development funds will be withheld.  This
  makes more sense than holding up needed sewage construction funds.
  Since the Pikes Peak Area Council of Governments, in cooperation
  with the State, EPA and with the County Health Department, is in
  the process of developing an air quality maintenance plan, and
  has been in the forefront of trying to examine the impacts of
  growth on air quality, penalizing local entities because these
  studies are incomplete is not equitable.  The stated posture will
  contribute nothing to either cleaning up air pollution or water
  pollution.

  It should also be noted that the Pikes Peak Air Quality M&intenance
  Area is not consistent with the "208" planning area as the AQUA
  consists only of El Paso County.

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Terry Anderson                 4                   April 20,  1977
  PPACG views the provision of sanitation services as a means by
  which growth is accommodated and guided,  not a means to control-
  ling how much growth occurs in the Region.   It is strongly felt by
  the elected officials of this area that the provision of services
  to meet demands is as important as guiding  where those demands
  take place.  Since it is not possible to  control the number of
  people who actually come here by any local  effort,  we see no reason
  for EPA to be in the position of controlling the kind of growth
  that occurs in the Pikes Peak Region.  As a point of information,
  and this is related to the statement on page 20 regarding the
  rationale under Item C - the allocations  of growth to various
  segments of the area was done with the protection of a flood
  plain and unique ecological and scenic resources and the cost of
  public services in mind.

  Page 21 -- The statement is made "the Colorado Springs Department
  of Public Works has accepted the Urban Drainage Criteria Manual."

  COMMENT:  This is not wholly correct; both  the El Paso County
  Department of Transportation and the Colorado Springs Department
  of Public Works have administratively accepted the Urban Drainage
  Manual for use in review of drainage design and subdivisions.

  Pages 23 and 26 -- with regards to comments under Item F and Item
  M regarding the development of a summary plan implementation
  document.

  COMMENT:  PPACG feels that the planning process is a continuous
  operation leading towards implementation of plans.   In this regard
  its philosophy does not differ from that  of EPA.  However, we do
  feel that the development of any further documentation on Project
  Aquarius ought to be done with continuing funding and that docu-
  mentation should be in the products developed from a Work Program
  that results from continued funding.  It  is worthwhile noting that
  it took about two years to complete the Plan; the review process
  will have taken close to one year.  We strongly urge that annual
  Work Programs be used as statements of policy and priorities for
  the implementation of the whole Project Aquarius.  Implementation
  of the whole plan will take a long period of time before it can
  be fully accomplished, indeed the planning  horizon is the year
  2000, and we should not expect implementation of the current plan
  to occur without revisions.

  Given the State's conditions, which PPACG accepts,  further docu-
  mentation can and should be covered under the continuing process.

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Terry Anderson                 5                   April 20, 1977
  PPACG agrees with other EPA recommended actions in Table III, and
  not specifically addressed here, and will do everything within
  its power to assure that the plans and processes are carried out
  as expeditiously as possible.
Sincerely,
Roland Gow
Executive Director

sw

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      THE STATE HISTORICAL SOCIETY OF COLORADO
                   State Archaeologist (Interim address) Pioneer Hall,
                   University of Denver, Denver 80210

                                           May 3, 1977


Mr. John A. Green
Region VIII Environmental
   Protection Agency
1860 Lincoln Street
Denver, CO  80203

Dear Mr. Green:

     The Office of the State Archaeologist of Colorado has re-
ceived and reviewed EPA's summary Draft Environmental Impact
Statement, Water Quality Management Plan, El Paso and Teller
Counties  (March 1977).

     The Statement does not apparently discuss archaeological
resources.  Archaeological resources should be considered under
the National Environmental Policy Act of 1969, the Council on
Environmental Quality's "Guidelines for the Preparation of En-
vironmental Impact Statements"  (36 CFR 20550), Executive Order
11593 of 1971, and the Council on Historic Preservation's
"Procedures for the Protection of Historic and Cultural Properties"
(36 CFR 800; see 16 USC 470f, as amended 90 stat. 1320) which
implements the National Historic Preservation Act of 1966.

     This required consideration of archaeological resources should
be implemented in the earliest possible stage of planning.  By
delaying  (until the later planning stages when project flexibility
has diminished and specific sites have been selected), an unevalu-
ated commitment of non-renewable archaeological resources is made.
Site avoidance and many other mitigative options are often untenable
at such later stages.

     Based upon the provided information, the Environmental Pro-
tection Agency has not adequately addressed archaeological
resources in this Draft Statement.

     The State Historical Society's Department of Historic Preser-
vation independently comments regarding historic/architectural
resources.                              *~

      If we can be of assistance in converging upon a mutually

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Mr. John A. Green
Page 2
May 3, 1977
beneficial solution to the water-quality and cultural-resource
obligations, please contact Staff Archaeologist David R. Stuart
at (303) 744-1713 (after June:  839-3391).
                                 For the State Historic
                                  Preseuwllux Officer
                                 Bruce E.
                                 State Archa!
BER(DRS):ng
cc:  Meehan, Pikes Peak COG
     Monaghan, Colorado Executive Chambers
     Schmuck, Division of Planning
     Klein, Council on Environmental Quality
     Wall, Council on Historic Preservation
     Hart, SHPO
teau, Ph.D.
ogist Colorado

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                     DEPARTMENT OF THE  ARMY
                  ALBUQUERQUE DISTRICT. CORPS OF ENGINEERS
                               P. O. BOX 1580
                       ALBUQUERQUE. NEW MEXICO 871O3


SWAED-EP                                               21 April 1977
                                              ^Hck CONTROL
Mr. John A. Green, Regional Administrator
United States Environmental Protection
 Agency, Region VIII
1860 Lincoln Street
Denver, Colorado  80203
Dear Mr. Green:

In response to your notice of March 25, 1977, we have reviewed the draft
environmental impact statement on the 208 Water Quality Management Plan
for El Paso and Teller Counties, Colorado.  The plan evaluated in the
statement could have an adverse effect on the potential Fountain Lake
project, especially if a multiple-purpose reservoir with flood control
and recreation is the selected alternative.  However, as stated in our
letter to you of 18 March 1977, we have not progressed far enough in our
formulation studies to give you a definitive answer regarding water qual-
ity at this time.

As you know, our preliminary water quality studies, to which you refer on
page 17 of your draft environmental statement, indicate that existing dis-
charges in Fountain Creek would adversely impact on a recreation pool at
Fountain Lake.  Even with the existing poor quality of water in Fountain
Creek, a warm water fishery could be sustained in a Fountain Lake perma-
nent pool.  However, increased discharges of un-ionized ammonia and chlor-
ine residual, as well as lowering of instrearn dissolved oxygen standards
from 5 rag/1 to 4 mg/1 could further degrade the water quality of Fountain
Creek and possibly have an adverse effect on establishment of a warm water
fishery in Fountain Lake.

We appreciate the opportunity to comment on your draft environmental impact
statement.

                                   Sincerely yours,
                                   JASPER H. COOMBES, P.E.
                                   Chief, Engineering Division

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UNITED STATES DEPARTMENT OF AGRICULTURE

SOIL CONSERVATION SERVICE	

  P.  0.  Box  17107,  Denver,  Colorado 80217



                                                       April 26, 1977
  Mr.  John  A.  Green
  Regional  Administrator
  U.  S.  Environmental  Protection Agency
  1860 Lincoln Street
  Denver, Colorado 80295
  Dear  Mr.  Green:
  Thank you  for  sending us a copy of the draft Environmental Impact Statement
  for  the Water  Quality Management Plan for El Paso and Teller Counties.  We
  have reviewed  the  summary and associated documents and submit the following
  comments.

  Since the  draft  Environmental Impact Statement does not present specific
  information concerning the sites upon which the wastewater treatment facil-
  ities will be  constructed, we suggest the final EIS discuss the following
  items as they  relate to construction activities.

      a.  Discuss  the soil suitability and limitations for the proposed
         action.

      b.  Discuss  the provisions for controlling soil erosion during and
         after  construction.

      c.  Discuss  the provisions for stockpiling topsoil during construction
         for later  use in revegetation work.

  In addition, we  suggest the final EIS describe the impacts, favorable or
  adverse, on the  following:

      prime  and  unique farmlands, rare or endangered plants or animals,
      archeological  sites, floodplains, and wetlands.

  We believe further documentation is needed to support the conclusions reached
  concerning non-point sources of pollution.  Statements on page 22 of the
  draft EIS  and  page 75 of the Water Quality Management Plan conclude that
  "agriculture, mining, and silviculture activities are not now a significant
  source of  pollution".  We feel the draft EIS fails to recognize the effects
  of sheet and gully erosion, erosion from deteriorated cropland and rangeland
  and  erosion from streambank scouring.  These non-point sources constitute a
  significant impact on water quality in the form of sediments to downstream
  areas.  All eight Soil Conservation Districts, mentioned on page 230 of the

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Water Quality Management Plan, identify erosion problems and have on-going
programs to help individual landowners solve them.

We suggest the final EIS address the problem of non-point sources of pollu-
tion only as it relates to construction activities for wastewater treatment
facilities.  The agricultural related non-point sources are beyond the
scope and magnitude of this EIS.

Thank you for 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)
     Ken Kirkpatrick, State Soil Conservation Board
     Roger Hansen, AC, LaJunta
     Dennis Davidson, DC, Cripple Creek
     Don Nielsen, DC, Colorado Springs

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In Reply Refer To
         United  States Department  of the Interior

                   FISH AND  WILDLIFE SERVICE
                    AREA OFFICE COLORADO—UTAH
                       1426 FEDERAL BUILDING
                       125 SOUTH STATE STREET
                     SALT LAKE CITY, UTAH  84138

     (ES)                  AptXe  S,  1977
Memorandum

To:



Etom:



Subject:
We nave
the
                       Env,6tonmenta£ Piot:ectton Agency
                       Re.gional 0^i.ce.
                       Penu&t,  Colorado

                       Atea Manager
                       U.  S.  F,ah and WiZdLLfie. SeA.vi.ce.
                       SaJtt Lake. City, Utah
                             env/6tonmento£ impact statement on the. 208 WoteA Quality
                       Management P£an f$o
                  at  but,  and we woa£d tkeJie.^oie. recommend a cto^e co-o^dcnatcon
              mth the. Cotonado ViviA-ian o& Wi2dti^e. *hou£d the. plan be /implemented.

                 Comment
       We  do  not be^ceue that exceptxona (JoA. unionized ammonia (M^) and
       chUonine. £e.veJti>  ate juAtL&i.e.d &imp£y because £oweA fountain C doesn't
       cuwientty Aappo-tt a u^ab£e fiiAheAy.   We do not: agiee wictn PPACG'4 con-
       c£u6't.on tnat the 06 e ojj &u.ch a ^iAheJuj iA unattainable..  We ate fiu/itheA con
       ce/med,  tftat theie exception* to e^£aent ammonia and chlorine, concen-
       tAation6 have the po-tent£a£ to caaie toxsicity problem* in down&tA.e.am wateti
       06  w>e££.   It.   AuggeAte-d that thue. and a&Aociatejd problem* be. Looked at
       veA.y cJlo&eJty be^o-te a ^na£ de.ciAi.on /C6 made.
       Thank  you jjo-t avoiding  OA  ^he opportunity to tuwLow and comment on thu
       matter.

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              DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE

                                 REGION VIII

                            FFUI-.RAL OFFICE BUILDING

                            19 III AND STOUT STREETS

                           DENVER. COLORADO  fcfcty't

                                          80294
                                 6) \3II
                                                      OFFICE OF THE REGIONAL DIRECTOR
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 208 Water Quality Management  Plan  for El  Paso  and
Teller Counties, Colorado.

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

                                     Sincerely  yours,
                                     Edwin'R.  LaPedis
                                     Acting  Regional  Director

cc:
Office of Environmental Affairs
HEW, Washington, D.C.

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

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               DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
                                  REGIONAL OFFICE
                          EXECUTIVE TOWER - 1405 CURTIS STREET
                              DENVER, COLORADO 80202

                                                                 6
                                 May 10, 1977
REGION VIM                                              \  I I        IN REPLY REFER TO:
                                                                    8DE
   Mr. John A. Green
   Regional Administrator
   Environmental  Protection  Agency
   1860 Lincoln Street
   Denver, Colorado  80203

   Dear Mr. Green:

   We have reviewed your Draft  Environmental  Impact Statement (EIS) on the
   208 Water Quality Management Plan for El  Paso and Teller Counties, Colorado
   transmitted to us on March 25,  1977.

   As you know, under the Guidelines of  the  Council on Environmental Quality,
   this Department has been  assigned responsibility for comments on EIS's
   pertaining to  comprehensive  planning  and  impacts on residential areas.
   Our principal  concern with this statement is your inference that there will
   be growth-related impacts which may occur if the recommendations made in
   the 208 Water  Quality Management Plan are implemented.

   Though your Summary Sheet lists many  of these growth-related impacts,
   there has been little attempt in the  Draft EIS to show how a water quality
   management plan will effect  growth.   There is no discussion on what could
   be done to mitigate any adverse effects of this projected growth and many
   of the identified impacts were  not thoroughly discussed.

   Enclosed are two HUD documents  which  may  help you to address some of these
   areas.  The Noise Assessment Guidelines provides an outline of how to
   assess noise emanating from  railroads, airports and roadways for both
   present and future conditions,  while  the  Guide for Social Environmental
   Assessment lists various  social  areas which need assessment.

   Thank you for  this opportunity  to comment on this Draft EIS.

   Sincerely,

               >  K.
Robert J. Matuschek
Assistant Regional Administrator
Community Planning and Development

Enclosures
                                                MAY i2 i')77
                                    Insuring Offices
  Casper, Wyoming • Denver, Colorado • Fargo, North Dakota • Helena, Montana * Salt Lake City, Utah* Sioux Falls, South Dakota

-------
RIPHARO 0. LAMM
   Governor
                          EXECUTIVE  CHAMBERS
                                   UKNVRR
                                       May 16, 1977
   Mr.  John Brink
   Environmental  Evaluation Branch
   Environmental  Protection 'Agency
   1860 Lincoln
   Denver,  CO  80203

   Dear John:

        As  a follow-up to our discussion on the telephone this morning, here
   are  copies of  three letters received on the abbreviated draft EIS being
   prepared for the PPACG 208 plan.

        Each of these three letters  pose some concerns and questions that
   deserve  the attention of both EPA and -the State possibly now or in the near
   future.

                                       Sincerely,
                                       Gary 6. Broetzman
                                       State 208 Coordinator
   Attachments

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COLORADO  DEPARTMENT OF HEALTH
     E. 11TH A/ENUE     DENVER 8O2SO    PHONE 388-6111 EXT. 329
                 ANTHONY ROBBINS.M.D..M.P.A. EXECUTIVE DIRECTOR
                               May 2,  1977
  Mr.  Phil  Schmuck
  Division  of  Planning
  Department of  Local  Affairs
  520  Centennial  Building
  INTERDEPARTMENTAL

  RE:   208  Plan  for  El  Paso and  Teller Counties
  Dear  Phil:

     The  Department  of Health's  comments on the El  Paso-Teller
  208 Plan  have  been  submitted  to your office.   Subsequent
  review of  the  check-off  form  letter (SOC-3)  and the attached
  commentary  dictates that  a  modification is appropriate in
  this  particular  instance.   Instead  of an affirmative check-off
  in  the first box  (see attached),  the Department is now
  qualifying  that  statement  by  referring to the paragraph indi-
  cated with  an  asterisk in  the body  of the comments.  In this
  instance we did  not feel  a  strict "yes" or "no" could suffice,
  hence the  change.
                               S i ncereIy
                               Ron  Simsick,  Prb-gram Administrator
                               Colorado Department of Health
 ggb

 Enclosu re

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                                    -<• J
GOLOKIAQO
                                           OF MSAILTH
4210 E. TVTH AVENUE     DENVER 80220     PHONE 3BS-6111 EXT. 329
                ANTHONY RODSINS.M.D..M.P.A. EXECUTIVE DIRECTOR
DATE:   April 26,  1 977

SUBJECT:    NON-STATE ASSISTANCE

                       REVIEW AND COMMENTS

TO:.  Phil Schmuck
     Oept of Local Affairs
TO:
     MA
PROJECT TITLE: 208 Plan for El Paso and Teller Counties

STATE IDENTIFIER: ESR #77-107

COMMENTS DUE BY:

            No Q
Yes
   KJ


YesU
Yes

Yes
            No
            No
            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.
Comments: Air PollutIon Control Division:  The Division's primary
  concerns with aTlfb~S Plans are: that oOr quality  Is adequately
  considered during the planning process, and that the Plan will
  not allow areas  in the State to degrade current air quality.
  The 208 Plan for El Paso and Teller Counties did,  In the Divi-
  sion ' s op 1 n Ion ,  fulfill the first criteria.  Air quality was
  addressed in the February 27, 1975 document entitled "Options
  for the Future, What Do They Mean?", and the April 12, 1976
  report entitled, "Year 2000 Air Quality In the Pikes Peak
  Region".  While we may not concur with the conclusions of
  either document, we do feel that PPACG made the effort to
                           Name, Ti tle .& Phone
SOC-3, Feb 77
                     ATTACHMENT B

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  Phil  Schmuck
  SOC-3 (208 Plan  for El  Paso and Teller Counties)
  April 26,  1977
  page  2


  Include  air quality considerations.                   '    -     •
•fc   The second criteria  relating  to the  20$ Plan's  Impact on  current
  air quality Is a complicated matter^  and  one not  easily solved^;:"
  The report, "Year 2000  A'r  Quality In  the Pikes Peak Regjon",  ~
  states,  on page  13, that  "a general deterioration In air "" •>«  ..>:-:
  quality  over 'the region as  a whole appears likely."  Violations
  of standards for certain  pollutants are projected by the
  year  2000.   In addition,  two recent draft reports by the
  EPA consultant,  PEOCo  Environmental,  Indicate that In the
  short term (1980 and  1985)  both the partlculate and carbon
  monoxide standards will bo  violated.   Based  on EPA's stated
  unwillingness  to fund  sewage treatment plants until air      ;
  quality  studies  are completed (presumably EPA Is  referrtvig
  to the Air Quality Maintenance  Planning effort) the Colorado
  Springs  area should, as rapidly as possible,  develop Imple-
  mentable air pollution  reduction and maintenance  strategies.
    The Division's final  comment  relates to the draft EIS.
  They  are unable,  at this  time,  to judge the  accuracy of the
  statement  on page 19 that "on ground  location of  growth is
  not the  critical  factor In  air  quality degradation".  They  would
  not like to see  a 2C3 Plan  that completely locks  out an alter-
  native population distribution  as a potential aj r pollution
  reduction  strategy.
                              Ron  Simsick,  Program  Administrator

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          STATE  DEPARTMENT  OF  HIGHWAYS
                 JACK KINSTLINGER
DIVISION OF HIGHWAYS
E. N. HAASE
CHIEF ENGINEER
                                                 EXECUTIVE DIRECTOR
      COLORADO STATE PATROL
      COL. C. WAYNE KEITH.
      CHIEF
             42OI EAST ARKANSAS AVENUE • DENVER. COLORADO 80222 •  <3O3> 757-9O1I
                                April 26, 1977
   Mr. Philip H. Schmuck
   Director
   Colorado Division of Planning
   520 Centennial Building
   1313 Sherman Street
   Denver, Colorado  80203
                                                     PEOnv-E
                                                     I > i_ w ;__ i •; t_
PUKNiNG
                                RE:  Teller and El Paso Counties 208 Plan
   Dear Mr. Schmuck:
   The Colorado Department of Highways has completed its review of the Draft
   Environmental Impact Statement for the Areawide Water Quality Management
   Plan for Teller and El Paso Counties and its supporting documents.   As a
   result of our review we would like to offer the following comments.

   The format used in the subject DEIS departed significantly from standard
   DEIS format.  The DEIS as presently structured presents the State's and
   EPA's reaction to the proposed 208 plan with little explanation of  what the
   plan for Teller and El Paso counties looks like or accomplishes.  In order
   to ensure that the DEIS is a full disclosure document,  the  actual  plan
   prepared in response to Section 208 of the Federal Water Pollution  Control
   Act Amendments (P.L. 92-500) should have been summarized in the DEIS.  Many
   individuals will read the DEIS expecting to be briefed  on the*plan  and its
   current status.  However, without a brief summary describing the water
   quality planning and management process developed during the initial two
   year planning period, the document's value as an educational tool is
   severely diminished.

   The Colorado Department of Highways endorses the recommendations made by
   EPA regarding further refinement and approval of the plan,  EPA's recom-
   mendations appear to be consistent with the State's position on these matters.
   In the development of the work program for the next round of water  quality
   management planning by PPACG the Highway Department would like to see the
   following concerns addressed.

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Mr, Philip H.  Schmuck
April  26, 1977
Page Two
 1)  Have  the Colorado Springs Transportation Improvement Program and
    the PPACG  input  to the CDH Five-Year Highway Construction Program
    been  formulated  incorporating Project Aquarius objectives?

 2)  How does the current Five-Year Construction Program contribute to
    changes in land  use, thereby affecting plans for control of storm-
    water run-off and for wastewater treatment facilities?

 3)  Have  the growth-stimulus effects of transportation projects been
    considered with  plans for regionalized or consolidated wastewater
    treatment?

 4)  Who will continuously coordinate planning for transportation and
    water quality management?

 5)  Will  the responsibilities of PPACG Transportation Advisory Committee
    change to  reflect the concerns for water quality?  If so, what will
    these new  responsibilities include?

 6)  Will  the Environmental Protection Agency through the PPACG promulgate
    criteria to be applied during highway project impact assessment
    studies to ensure consistency between transportation and water
    quality goals, policies, programs and plans?

 7)  What  additional  erosion controls and standards for highway project
    construction, if any, are anticipated by the Environmental Protection
    Agency, and will potential chemical pollutants such as de-icers,
    pesticides and herbicides be restricted?
Thank you for providing the Colorado Department
to review and comment on the subject
                                    •
                                 Very'
                                                   Highways the .opportunity
                               //Executive Director
AP/jc

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      THE STATE HISTORICAL SOCIETY OF COLORADO
                   State Archaeologist (Interim address) Pioneer Hall,
                   University of Denver, Denver S0210

                                           May 3, 1977
Mr. John A. Green                             • s   .
Region VIII Environmental
   Protection Agency
1860 Lincoln Street
Denver, CO  80203

Dear Mr. Green:

     The Office of the State Archaeologist of Colorado has re-
ceived and reviewed EPA's summary Draft Environmental Impact
Statement, Water Quality Management Plan, El Paso and Teller
Counties  (March 1977}.

     The Statement does not apparently discuss archaeological
resources.  Archaeological resources should be considered under
the National Environmental Policy Act of 1969, the Council on
Environmental Quality's "Guidelines for the Preparation of En-
vironmental Impact Statements"  f36 CFR 20550), Executive Order
11593 of 1971, and the Council on Historic Preservation's
"Procedures for the Protection of Historic and Cultural Properties"
(36 CFR 800; see 16 USC 470f, as amended 90 stat. 1320) which
implements the National Historic Preservation Act of 1966.

     This required consideration of archaeological resources should
be implemented in the earliest possible stage of planning.  By
delaying  (until the later planning stages when project flexibility
has diminished and specific sites have been selected), an unevalu-
ated commitment of non-renewable archaeological resources is made.
Site avoidance and many other mitigative options are often untenable
at such later stages.

     Based upon the provided information, the Environmental Pro-
tection Agency has not adequately addressed archaeological
resources in this Draft Statement.

     The State Historical Society's Department of Historic Preser-
vation independently comments regarding historic/architectural
resources.                              "
     If we can be of assistance in converging upon  a mutually

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Mr. John A. Green
Page 2
May 3, 1977
beneficial solution to the water-quality and cultural—resource
obligations, please contact Staff Archaeologist David R. Stuart
at (303) 744-17733 (after June:  839-3391).
                                 For the State Historic
                                  Preserver Lion Officer
                                 Bruce E. R
                                 State Archa!
BER(DRS) :ng
cc:  Meehan, Pikes Peak COG
     Monaghan, Colorado Executive Chambers
     Schmuck, Division of Planning
     Klein, Council on Environmental Quality
     Wall, Council on Historic Preservation
     Hart, SHPO
teau, Ph.D.
ogist Colorado

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