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
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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).
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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.
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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.
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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.
-------
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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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
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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
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PIKES PEAK AREA COUNCIL OF GOVERNMENTS
f^^'^
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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~
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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
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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
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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
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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
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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
-------
\ \ 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
-------
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
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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
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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
*
-------
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
-------
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
-------
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
-------
* 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
-------
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
-------
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
\'
-------
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
-------
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."
-------
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.
-------
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.
-------
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
-------
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
-------
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
-------
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
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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.
-------
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
-------
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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