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FINAL
ENVIRONMENTAL IMPACT STATEMENT
WASTEWATER TREATMENT FACILITIES
THREE LAKES, COLORADO
Prepared by
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION VIII, DENVER
March, 1978
Approved by: Alan Merson
Regional Administrator
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Anyone who has had a bull by the tail knows
five or six things more than someone who hasn't.
Mark Twain
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Summary
Draft Environmental Impact Statement
Wastewater Treatment Facilities for
Three Lakes, Colorado
1. Environmental Protection Agency; Draft ( ) Final (X)
2. Type of Action; Administrative (X) Legislative ( )
3. Description of Action; The objective of this project 1s to protect
the water quality of Grand Lake, Shadow Mountain Lake, Lake Granby,
and their tributaries by the provision of wastewater collection and
treatment facilities and the control of nonpolnt (erosion, sedimenta-
tion, septic tank wastes, etc.) type pollution. The objective 1s
also to provide these water quality controls while, at the same
time, avoiding undesirable secondary Impacts on area growth patterns,
the Shadow Mountain National Recreation Area, water rights, and other
aspects of the local environment. The treatment facilities and non-
point controls have been proposed so that water quality 1n the Three
Lakes area will meet goals established by the 1972 Amendments to the
Federal Water Pollution Control Act, the State of Colorado water
quality classifications, and so that the lakes and streams will con-
tinue to be a quality environmental resource.
The Three Lakes Water and Sanitation District proposed to con-
struct a large regional sewerage system (described as Regional System
in the facility plan) to serve the west shores of Lake Granby and
Shadow Mountain Lake and the Grand Lake area. EPA refused to fund
this system because it believed the system would lead to development
which, in turn, would lead to serious nonpolnt type pollution. EPA
also objected to this regional system for technological, water rights,
and Shadow Mountain National Recreation Area reasons.
Following EPA's rejection of this earlier proposal EPA, the
Three Lakes Water and Sanitation District, Grand County, State of
Colorado, Park Service, U.S. Bureau of Reclamation, and others have
worked to resolve issues and to develop a satisfactory water quality
control plan for the area. Six alternative wastewater treatment
systems have been analyzed with one, the Willow Creek Lagoon alter-
nate, having been selected by EPA.
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This final environmental impact statement thus grants EPA approval
for funding of Step II (preparation of plans and specifications) for
the Willow Creek Lagoon alternative as described 1n this document.
This approval includes the following grant conditions which must be met
by the Three Lakes Water and Sanitation District and others Involved:
(A) Enactment by Grand County of non-point pollution controls as
previously discussed between EPA and the County.
(B) Resolution of water rights issues between the Three Lakes
Water and Sanitation District and the U.S. Bureau of Reclama-
tion.
(C) Further testing of a known archaeological site and use of a
qualified archaeologist during the initial construction phase
of the sewage lagoons.
(D) No EPA approval of an Interceptor sewer line to Area "L"
until resolution of the National Recreation Area Issue.
(E) Demonstration of financial ability by the Three Lakes Water
and Sanitation District.
4. Environmental Impacts (of the proposed Willow Creek Lagoon):
An extensive list of the various impacts that could be expected
from implementation of the Willow Creek Lagoon sewerage system is
found in Chapter VII of the facility plan. The major impacts, as
analyzed 1n this EIS, are as follows:
(1) Construction will cause some short-term erosion and
resultant sedimentation. EPA grant conditions, however, will
require stringent erosion control, especially for the sensitive
lake shore areas.
(2) There will be a loss of approximately 33 acres of land
area to lagoon construction. This land 1s part of a general deer
winter range area.
(3) Local residents will have to pay monthly service charges
and will be taxed to pay for the system. This cost, however, should
be viewed in relation to present septic tank costs and to increased
property values that will probably result.
(4) The Three Lakes will be protected from septic tank and
sewage treatment plant discharges with resulting higher water
quality.
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(5) Nonpoint pollution (erosion, sedimentation, septic wastes)
will be controlled to a much greater extent than at present with
resulting water quality benefits.
(6) Presently undeveloped subdivision lots will be easier
to develop with provision of sewer service, and some accelerated
development may occur as a result. Grand County land use regula-
tions, however, should mitigate the Impacts of this development.
At the same time, the sewage collection system will serve to channel
growth to preferred areas.
(7) The Shadow Mountain National Recreation Area should benefit
from Improved water quality. The sewage collection system should
not conflict with Park Service and Grand County plans for the area.
(8) Effluent will be given proper treatment and discharged out
of the lakes' basin. An added advantage will be land treatment
(crop Irrigation) of the peak summer sewage loads.
(9) The lagoons have the added benefit of being easier and
cheaper to operate than more "mechanical" systems. Also, the
lagoon site 1s away from areas of heavy human use and from the
aesthetically sensitive lake shore areas.
(10) Two small "neighborhood" treatment plants will continue
to discharge to the lakes. The impact of this discharge should be
minimal.
5. Alternatives Considered;
(1) 'Do Nothing (capitol cost = 0)
(2) "Upgrade Existing FaciTitles"(capftol'cost = $940)000)
(3) Regional System (capitol cost = $6,113,000)
(4) Willow Creek Lagoon (capitol cost = $5,719,000)
(5) North Shore Plant (capitol cost = $6,336,000)
(6) Stlllwater Creek Lagoon (capitol cost • $5,756,000)
6. Distribution;
Only those agencies and Individuals commenting on the draft
EIS will be mailed copies of this final. These agencies and Individuals
are those as found 1n Section X of this EIS.
7. Draft Statement Sent to Council on environmental Quality; fJ/A
8. Final Statement Sent to Council on Environmental Quality:
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Contents
Section Paqe
I. Introduction and Summary 1
II. The Issues 5
Point Source Pollution 6
Nonpoint Pollution 7
Shadow Mountain National Recreation Area 9
Water Rights 10
Land Development 11
Cost of Sewerage Service 12
Technological Aspects 13
Phasing 14
Septic Tanks 15
III. Background 19
Three Lakes Water and Sanitation District 19
1972 Sewerage Plan and EPA Objections 24
Interagency Aspects 27
National Park Service 27
Grand County 30
Bureau of Reclamation 32
State of Colorado 33
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Section Page
Forest Service 34
Colorado Open Space Council 35
Other Comments 35
Recent History of the Project 36
EPA's Selection of a Preferred Alternative 46
IV. The Setting 47
Land Use Patterns 48
The Lakes 55
The Tributaries 56
Social and Economic Setting 58
Water Quality 60
Sedimentation and EPA's 1974 Survey 72
Water Quality of Tributaries and Willow Creek 78
V. Environmental Impact Evaluation of the Alternatives 81
Point Source Pollution 84
Nonpoint Pollution 90
Shadow Mountain National Recreation Area 95
Water Rights 96
Land Development 96
Cost of Sewerage Service 99
Technological Aspects 100
Phasing 102
ii
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Section
Page
Septic Tanks 104
Other Environmental Considerations 106
VI. The "Preferred" Alternative 107
VII. Irreversible and Irretrievable Commitment 109
of Resources
VIII. Relationship Between Short-tarm Uses of the 113
Environment and the Maintenance and Enhancement
of Long-term Productivity
IX. References 115
X. Comments on Draft EIS 116
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SECTION I
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I. Introduction and Summary
The National Environmental Policy Act (NEPA) requires that EPA and
other federal agencies prepare an environmental Impact statement (EIS)
on proposed projects that may significantly affect the quality of the
human environment. The EIS serves as documentation of the agency's
decision-making process on the project and Includes consideration of
environmental, social, and economic Impacts and of ways to avoid or
minimize potential adverse effects.
The project on which EPA has written this EIS 1s a proposed waste-
water treatment and collection facility for the Three Lakes area 1n Colorado.
The sponsor and proponent of the sewerage project 1s the Three Lakes Water
and Sanitation District (District). Under terms of the Federal Water
Pollution Control Act EPA, 1n conjunction with the State of Colorado, pro-
vides 75% of the costs of such projects, providing they meet environmental,
cost effectiveness, and other standards.
As required by federal law, the District and Its consultants have
prepared a plan (facility plan) analyzing several alternative ways to
meet Three Lakes area sewage treatment needs. This planning process has
compared and ranked these alternatives on the basis of their relative Im-
pacts on the environment, on their costs, on their compatibility with
local land use plans, etc.
The facility plan for the Three Lakes project 1s attached to this
draft EIS and 1s considered part of 1t. The facility plan contains the
details of the project, and the EIS describes EPA's decision-making process
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and the analysis of the major environmental and other Issues that were
involved. The reader must use both documents (the EIS makes numerous
references to specific pages in the facility plan) to gain a full under-
standing of the project and its potential impacts.
Deliberations between all those involved 1n this project, including
EPA, the District, State of Colorado, National Park Service, U.S. Bureau
of Reclamation, Grand County, Northwest Colorado Areawide Water Quality
Planning Project, and others, have been going on for a number of years.
There have been differences of opinion among these parties as to the
best way to preserve the water quality of the lakes. The Issues Involved
have included what level and type of sewage treatment are needed, the
actual status of the lakes' water quality, developmental impacts, costs,
land use regulation, water rights, and others.
Early in 1977 the EPA Regional Administrator was able to select a
"preferred" alternative sewage treatment and collection system. Though
a final decision will not be made until this EIS receives full public
review, this selection of a "preferred" system was made because the
major points of contention between the various parties had been resolved.
The "preferred" alternative is the Willow Creek Lagoon system
(described in Chapter VII and shown as Figure VI-8 in the facility plan).
This alternative has the advantages of (1) offering a reliable and manageable
type of treatment, (2) serving the major areas of concentrated develop-
ment in the Three Lakes area, (3) discharging sewage effluent out of
the lakes' drainage basin, (4) offering land treatment of effluent in
the peak summer season, (5) avoiding conflict with the Shadow Mountain
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National Recreation, (6) placing the treatment plant 1n an area
that results 1n few aesthetic or other Impacys, and (7) being somewhat
conducive to phasing (building the system 1n Increments) 1f the District
1s unable to obtain Its full 25% share of system costs. At the same
time, Grand County has agreed to control erosion that may result from
development associated with provision of sewage service. Also, water
rights Issues, which have been a stumbling block, are being resolved.
Under the preferred plan two small neighborhood treatment units
will provide service to two clusters of development outside the larger
area to be served by sewer lines. These areas are at Sunset Point (plant
would discharge to Lake Granby) and at Sun Valley Ranch (plant would discharge
to North Fork, Colorado.
EPA believes that the "preferred" Willow Creek Lagoon alternative
is a project that, along with the other mitigative measures Involved,
is capable of providing positive benefits. The project has been com-
plicated and not an easy one to resolve, but the result—a plan to protect
the waters of this beautiful mountain valley—offers the promise of
helping assure the environmental quality of the Three Lakes area.
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SECTUON II
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II. The Issues
The Three Lakes sewerage project has been the subject of lengthy
negotiations and often has been controversial. This controversy and the
lengthy period of time 1t has taken to resolve 1t probably can be attributed
to the fact that the Three Lakes area 1s the scene of a major water
resource development project, 1s a highly scenic and popular vacation area,
and Is subject to differing management policies of numerous agencies and
levels of government Involved. Also, the controversy and length of time
1t has taken to resolve 1t can be attributed to honest differences of
opinion about the nature, the extent, and thus the appropriate solution to
water quality problems in the area.
Certain Issues have dominated the deliberations and differences of
opinion between the District, EPA, Grand County, Park Service, State of
Colorado, Bureau of Reclamation, the public, and others Involved.
Though there are many Issues Involved (the facility plan presents an
evaluation of alternative sewerage systems on some twenty-four different
criteria), this EIS will Identify the major Issues that have had to be
resolved before the project could proceed and will concentrate on them.
These same Issues will be used in the evaluation of alternatives in that
section of this EIS. These central Issues, and a brief summary of each,
follow.
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!• Point source pollution - Point sources of water pollution
are those which reach a water body via a specific conveyance structure
(pipe, canal, etc.). Point sources are usually the discharges from
something like a factory or, as with Three Lakes, the discharge from a
sewage treatment facility. In the Three Lakes case, these point sources
are comprised of the discharge from the Town of Grand Lake's sewage
treatment plant and possibly some unknown discharges from private structures
in the area. The National Park Service also has a facility on Shadow Mountain
Reservoir consisting of two lined lagoons with discharge into a third unlined
holding lagoon; the holding lagoon seldom has a discharge to the lake
and is not considered polluting.
The issues concerning point sources at Three Lakes are
(1) actual contribution of point sources to lake pollution; (2) type
of sewage treatment needed in the area; (3) extent of area that should be
included 1n a centralized collection system; and (4) whether or not
point source discharge, even though treated, should continue to enter
the lakes. These questions surrounding point sources have been one
of the focal points for all deliberations on this project.
Concerning each of the above four questions, the District
has maintained that point sources are a major source of pollution, the
type of treatment system proposed should eliminate any discharge to the
lakes, and nearly everyone 1n the district should be hooked Into a cen-
tralized sewage collection system.
On the other hand, EPA has not been as adamant about not
allowing properly treated effluent enter the lakes. However, EPA
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would prefer a treatment system that does not discharge to the lakes
if it can be justified. EPA has determined that there is no need to
serve nearly everyone in the district with a centralized collection
system, especially those outlying developments where expense and environ-
mental considerations argue against it.
2. Nonpoint pollution - Nonpoint type water pollution is
that reaching a body of water via some nondiscrete conveyance. Nonpoint
pollutants are sediments and associated nutrients from soil erosion,
residues from chemical fertilizer or animal wastes that have been spread
over a large area, underground seepage of poorly operating septic tanks,
etc. These wastes are not generally receptive to treatment but instead
must be controlled by prevention, i.e., not allowing erosion to take
place, not over-fertilizing, not allowing use of septic tanks in un-
suitable areas. It can also be seen that prevention of nonpoint pollution
implies land use regulation of some sort such as performance regulations
for construction activity, use of building permits, or lakeshore setback
requirements.
Many people and governmental agencies involved have recognized
the seriousness of the nonpoint problem in the Three Lakes area. The
National Park Service, U.S. Bureau of Reclamation, and marina owners and
their customers have been well aware that Shadow Mountain Reservoir, in
particular, was growing shallower due to sediment accumulation at the mouths
of its westside tributary streams. Areas where motor boats had once
traveled have now become too shallow to allow for boat operation due to
the sediment deposition.
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More recently, the contribution of sediment to the nutrient
enrichment and consequent lowering of water quality has become of great
concern for the three lakes. Specifics of this concern are covered in
the section of this EIS on water quality, but it should be pointed out
here that EPA has found, through surveys of the water of the lakes,
that nonpoint type pollution is the major water quality problem of these
waters. How to control this problem has been a major issue of the Three
Lakes project. It should be emphasized that all parties concerned have
basically agreed that nonpoint pollution is a serious problem and must
be controlled if the lakes are to be protected.
EPA has been involved in the nonpoint issue at Three Lakes
for two reasons. First, the Federal Water Pollution Control Act, requires
consideration of, and various planning programs for, control of nonpoint
pollutants. Second, and more direct, EPA reasoned that any regional sewage
collection system proposed by the District would sewer large undeveloped
areas and thus probably lead to a large amount of construction and road
building activity. This road building and construction activity would
lead to increased erosion and thus to further water quality degradation.
EPA was especially concerned about this possibility because of what it
believed was inadequate County control of the land uses that could lead to
acceleration of nonpoint pollution.
One of the major legal difficulties with controlling nonpoint pol-
lution that could be caused by construction activities related to provision
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of sewerage service 1s that the Water and Sanitation District 1s not the
governmental entity with the necessary land use control authority. The
governmental unit with this authority is Grand County, governed by the
three-member Board of County Commissioners. It must be made clear,
however, that land use control is a relatively new undertaking by Grand
County and many other counties and, most important, until EPA actually
quantified the nonpoint problem at Three Lakes in 1977, little concrete
evidence existed showing the need for more stringent control.
The issues with nonpoint control are (1) what type of controls
are needed and (2) whether or not the County will implement these controls.
Both these issues have now been answered. In terms of the first Issue, EPA
and the County have jointly developed a definition of the type of controls
needed. In terms of the second issue, the County has agreed to enact and
implement some nonpoint control measures.
3. The Shadow Mountain National Recreation Area - The
Shadow Mountain National Recreation Area (NRA) is administered by the National
Park Service under rules and regulations of that agency. However, this
NRA, unlike others in the National Park system, exists on the basis of a
memorandum of agreement between the Park Service, U.S. Bureau of Reclamation,
and the U.S. Bureau of Land Management. Though 1t 1s discussed in more
detail in this EIS and in the facility plan, it should be pointed out here
that the Park Service has attempted to gain Congressional legislation to
more formally and more specifically back the NRA and to spell out its
management direction.
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The Park Service developed a plan for the NRA, which 1t made
available, for public review 1n May, 1975, in the form of a draft environ-
mental impact statement. This Park Service activity came at the same
time as EPA was analyzing and deliberating the potential Impacts of
the Sanitation District's original regional wastewater collection and
treatment facility. A review and comparison of both the sewerage plan and
the NRA plan revealed certain conflicts which have been an Issue with this
project.
The major conflict between these two plans was that the Park
Service proposed open space-type management and, 1n some cases, purchase
of areas along the west side of Shadow Mountain Reservoir and Lake Granby
which the Sanitation District was planning to sewer. Obviously, it made
little sense to use federal funds to sewer developments that might be
purchased by another federal agency. Also, and most Important, EPA did
not want to Interfere with a Park Service plan that was aimed at environ-
mental preservation by funding a project that could foster developments
at odds with this plan.
Another issue associated with the NRA 1s nonpoint pollution.
With the lakes and their water quality a central focus of the NRA, the Park
Service has been most concerned about proper sewage treatment and the
control of nonpoint pollutants.
4. Water rights - The Board of Directors of the Three Lakes
Water and Sanitation District developed a policy that sewage effluent
should be collected from nearly all the developed areas around the lakes
and delivered for treatment and final discharge below Lake Granby, thus
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eliminating any discharge to the lakes themselves. This policy was
reflected in the District's originally proposed regional sewage col-
lection and treatment system which EPA rejected.
A major Issue with the District's original proposal concerned
a conflict with water rights vested 1n the U.S. Government and the Colorado-
Big Thompson Project. Sewage effluent entering the lakes via the Grand
Lake and Park Service treatment plants would have been discharged below
the lakes and thus lost to the Colorado-Big Thompson storage system.
EPA's position on this Issue was that the water rights problem had to be
worked out between the Sanitation District and the U.S. Bureau of Reclama-
tion before a sewerage project could proceed. As will be seen under the
discussion of the selected alternative, these water rights problems have
been solved.
5. Land development - The relationship of a regional sewage
collection system to Increased nonpolnt pollution has already been listed
as an Issue under the "Nonpolnt Pollution" heading of this part of the EIS.
Another related Issue Involving the District's plan to sewer most of
the existing development 1n the Three Lakes area 1s that of th** relation-
ship of a sewerage system to land speculation and land development 1n general.
The problem with the District's originally proposed regional
wastewater collection and treatment system and, to a lesser extent,
the alternative shown as "preferred" 1n this EIS (Willow Creek lagoon)
1s that there are several thousand platted but unbullt-upon subdivision
lots (many are old plats and very small lots) 1n the area that would
be served by the collection system. There 1s no way 1n which to quantify
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the number, 1f any, of these lots that would be developed 1f a sewer line
becomes available, but with the County's present policy of requiring a
two-acre minimum lot size for septic tank use, it becomes readily apparent
that the potential exists for development. It should be pointed out that
these are lots and subdivisions already accepted in their present configura-
tion by the County and that their owners have been granted certain rights
to develop based on this acceptance. Undoubtedly, a number of these lots
were laid out with no environmental impact considerations.
The issues thus become (1) whether the need for the sewage
system justifies the provision of an extensive collection system to
serve many of the existing developments and (2) whether mitlgative measures
are available to control potential impacts from possible development of
these lots. A note in relationship to this later Issue is that a strong
case can be made that provision of a centralized sewage collection system
can channel and concentrate growth into areas deemed acceptable and suitable
for it. This is a most important consideration for the Three Lakes project.
6. Cost of Sewerage System - The expenditure of public monies
for construction of wastewater collection and treatment systems requires
that the funds be used in a "cost-effective" manner. EPA does not believe
that sewage-related water quality problems should be corrected by unneces-
sarily elaborate and expensive systems. In the case of the Three Lakes
project, the Issues in this regard have been related to the type of
treatment plant needed, to the extent of the collection system, and to
whether any treatment plant of any kind is needed.
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It should be pointed out here that the State of Colorado, acting
through the Colorado Water Pollution Control Commission, actually makes the
decision on which sewerage projects 1n this state will receive EPA funds.
The Commission has a funding priority system, approved by EPA, which as-
signs priority to various proposed projects based on severity of water
quality problems, on population Involved, on quality of receiving streams,
and on other factors. It has been the policy of the Commission to fund
interceptor sewers and treatment plants but not to fund sewage collection
lines. Sewage collection lines represent the major part of the expense
of the Three Lakes Water and Sanitation District's preferred system.
Since the District does not have sufficient funds to pay for the full
collection system, it must find funds elsewhere or gain special fund-
ing approval from the Commission before the system proposed in this EIS
could actually be built.
7. Technological Aspects - Certain aspects of the District's
proposed sewerage system have been an issue because of the nature of
the technology proposed for use. The major issue has revolved around
the District's original proposal to use underwater vacuum lines to col-
lect sewage from homes around parts of Grand Lake and along tha west
shore of Shadow Mountain Lake. Less of an Issue but still Important to
deliberations on the Three Lakes project has been concern over the type
of treatment plant to be used. These latter concerns have centered around
whether treatment would be best provided by some "mechanical" type of
plant (rotating b1o-d1scs have been considered, for example) or whether
treatment would best, and possibly more economically, be provided by
aerated sewage lagoons.
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Another Important factor that has had to be taken Into account on
treatment type has been the level of treatment that might be required
in the future. Because of the high quality water presently 1n the Three
Lakes area and because of a desire and policy by all concerned to protect
this quality, it 1s entirely possible that any treatment plant discharging
to the lakes might be required to add an advanced waste treatment (AWT)
process in order to maintain this quality due to Increased sewage loads or
because of more precise and refined water quality trend data becoming available.
Because of the above factors, EPA, the District, and the State
believe that aerated lagoons plus another treatment level ("advanced")
offered by land irrigation of the lagoon effluent represent a sound
technological approach to Three Lakes sewage treatment needs. This ap-
proach is that described in the recommended Willow Creek lagoon alternative.
8. Phasing of the Sewage Collection and Treatment System -
The Willow Creek lagoon system preferred by the District is comprised of
extensive collection systems. The Willow Creek lagoon alternative also
has additional components—two or three small "neighborhood" treatment
plants for clusters of development beyond the main system.
Because the Three Lakes Water and Sanitation District does not
have enough money for the local share of the system (they are approximately
$2 million short of sufficient funds) and because other funding sources for
this money may or may not be available, EPA has urged the Board of Directors
of the District to be flexible and, if the entire amount of money needed
for the construction of the complete system is not available, to phase the
completion of the system. This phasing could be accomplished by not
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immediately building all the collection system or by not initially building
the outlying neighborhood treatment units. EPA has, as explained under
the "NRA Issue" heading, already decided that certain areas of the southwest
shore of Lake Granby should not be served until the NRA issue can be
resolved. This decision is a "phasing" of that part of the system.
The Board of Directors of the Water and Sanitation District
have adopted a policy that they Intend to serve nearly all the homes in
the District. EPA, because it believes that sewage treatment plant im-
provements must be made in the area whether all areas receive service
or not, has asked the Board to be as flexible on this issue as Its mem-
bers feel possible. EPA must point out that this is the Board's deci-
sion to make, not EPA's, and that the whole sewerage system as described
as preferred in this EIS is being considered for approval.
9. Septic Tanks - The use of septic tanks in the Three Lakes
area has been an issue comprised of two opposing viewpoints. First, the
District and the County have stated that they do not believe the Three
Lakes area to be suitable for widespread septic tank use. Both entities
have expressed the opinion that septic tank use has been a major problem
and that the use of these systems is probably causing water quality problems.
On the other hand, the Rocky Mountain Center on the Environment (ROMCOE),
which performed an environmental analysis on this project, has stated that
septic tank management in conjunction with some type of centralized treat-
ment and collection, operated by the Sanitation District and the County,
might be a better and less costly system for management of sewage in the
Three Lakes area than the centralized collection and treatment system
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proposed. The difference between the two sides of the septic tank Issue
has been one of degree—that 1s, one side arguing that access to a sewer
connection be provided nearly "all" homes and establishments 1n the District
and the other side arguing that many of these units would better be served
by Individual septic systems managed by the District or County.
The water quality data on the three lakes and their tributaries
is not conclusive as to whether septic tanks are a major water quality
problem. The sampling programs to date have not been refined to the
level where the contribution of septic tanks, especially in the west-
side tributaries, has been specifically identified as a certain quantity
of the whole pollutant load entering the lakes. However, the fact that
\
people in the area have continuing problems with malfunctioning septic
systems, though not quantified, has also been brought to EPA's attention
by the County and District on numerous occasions.
Data developed by the County under current land use planning
efforts indicates that most of the Three Lakes area 1s unsuitable for
septic tank use. EPA water quality analysts are also leary of wide-
spread and concentrated septic tank use in mountain areas such as at
Three Lakes. It should also be stated that the District is adamantly
opposed to becoming involved 1n a septic tank management system.
As stated in the beginning of this section of the EIS, the
facility plan contains much additional discussion on these Issues and
on others that have not figured as prominently 1n the deliberations con-
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cernlng the Three Lakes project. The reader should refer to this dis-
cussion 1n the facility plan for a more complete review of the Issues
considered. The Issues described 1n this EIS document will be the ones
on which the alternatives are further evaluated 1n this EIS, with the
discussion 1n the facility plan serving to cover the remaining ones.
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SECTI1ON 111
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III. Background
The Three Lakes Water and Sanitation District
The Three Lakes Water and Sanitation District, a special service
unit of local government, is the proponent of, and the legal entity
responsible for, the sewage collection and treatment system proposal
analyzed in this EIS. The service area designated for wastewater
management planning purposes 1s the District boundaries comprising
some 56 square miles. These boundaries, shown in Figure II-2 of the
facility plan, include Grand Lake, Shadow Mountain Lake, and Lake
Granby, as well as the North Fork of the Colorado River and other
smaller tributaries to the lakes.
Unlike other special service water and sanitation districts in
Colorado, the Three Lakes District was created by the Colorado General
Assembly. This action by the Legislature was in recognition of the
valuable environmental resource represented by the three lakes and in
the belief that action needed to be taken to preserve the quality of
the waters of the lakes. The Act creating the District was passed by
the General Assembly in 1971. In stating its purpose for passing the
Three Lakes Sanitation District Act (CRS 1973, 532-10-101 through 179),
the Legislature stated, among other things, the following:
(a) Certain areas in the state possess natural char-
acteristics which make them attractive for the building
of seasonal homes and tourist facilities. There is an
increasing need to build public facilities in such areas
in order to accommodate the needs of the seasonal popula-
tion. . . The increasing public use of such areas is
leading to serious water quality problems, a factor of
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concern to all the citizens of the state ... the Gen-
eral Assembly thus declares that the creation of this
District promotes the health, comfort, convenience,
safety and welfare of all the people of the state and
visitors to the state, and will be of special benefit
to the inhabitants of the District and the property
therein.
(f) The necessity for this Article results from the popu-
lation, growth, and development 1n the area Included by
this Article and from the resultant population of Grand
Lake, Shadow Mountain Lake and Lake Granby; . . .
(Ref. No. 7.)
Like other water and sanitation districts, the Three Lakes District
was given the power to levy taxes, build and operate wastewater treat-
ment facilities, own property, etc. Most Important to the history of
this project, the District was also empowered to provide:
(1) Not later than December 31, 1972 the Board shall
submit to the Board of County Commissioners of Grand
County a comprehensive Master Plan for the development,
maintenance, operation, and financing of a proposed
sanitary sewer transmission and disposal system. The
master plan shall contain provisions for the acquisition
or utilization by purchase, lease, or other agreement,
of existing facilities planned, constructed, or operated
by existing municipalities and special districts having
area within the boundaries of the District. The Board
of County Commissioners shall proceed to hold public
hearings on the Master Plan. . . (Section 32-10-179 of
the Act).
In response to this charge, the District hired the planning/en-
gineering firm of Nelson, Haley, Patterson, and Quirk (NHPQ) which, in turn,
analyzed the Three Lakes situation and developed a plan for the regional
wastewater collection and treatment system. This sewerage system was
approved by the Board of Directors of the District but has been met
by objections from EPA and others.
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A complete chronology of events subsequent to the creation of the
Three Lakes Water and Sanitation District and the appointment of Us
Board of Directors 1s found on pages II-2 through 11-12 of the facility
plan. To avoid repetition, this section of the EIS will only discuss
those particular events 1n that chronology that need to be elaborated
on or emphasized 1n order to clarify the environmental Issues and the
background leading to the decision to write this EIS.
As mentioned, the Three Lakes Master Plan was completed and approved
by the District and submitted to Grand County 1n November, 1972. The
plan recommended a sewer system that would serve most of the existing
dwellings 1n the District by means of an extensive collection network
and an Interceptor line from the existing Grand Lake treatment plant to
a new treatment facility Just south of Lake Granby. This treatment
plant site would be below the Three Lakes drainage basin and thus would
eliminate any effluent discharge to the lakes. This system proposed 1n
the 1972 Master Plan 1s the same as Alternate 3, Regional System, as
discussed 1n greater detail 1n Chapter IV of the facility plan.
There are two Important aspects of this original plan that should
be pointed out. The first concerns the District Board of Directors'
desire to eliminate any discharge of treated effluent to the lakes.
As stated, this was a feature of the original plan and 1s one the Board
and others believe should be part of any water quality management plan for
the area. This position stems from the belief that Inadequately treated
sewage treatment plant effluent and poorly operating Individual septic
tanks are presently a major Impact on water quality of the lakes.
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The second aspect is that the Board has maintained the position that
sewage treatment service, I.e., provision of access to a centralized
system if possible, should be made available to the majority of the
existing homes and other structures within the District's boundaries.
This latter position probably stems from the Board's belief that these
homes and businesses, the ones on septic tanks, constitute a water quality
problem. This position is also a result of the Board's concern that
property owners who have been paying taxes to the Water and Sanitation
District should receive some type of sewerage service in return. Both
of these positions taken by the Board have been important because they
partly underlie the rationale for the regional sewerage system proposed
in 1972 and because they have played an important role in deliberations
since that time.
EPA, on the other hand, while respecting the Board's position, has
considered federal requirements calling for cost-effective sewerage systems
and on the National Environmental Policy Act requirement that other environ-
mental values and secondary impacts must be considered 1n the evaluation of
these systems. EPA's position on these issues has tended to favor a smaller
system, one not attempting to service the whole District, and also to a
more detailed analysis and concern for secondary impacts associated with
the regional sewerage system such as generation of development, nonpoint
(erosion) pollution generation, and effects on the Shadow Mountain National
Recreation Area.
The importance of discharging Three Lakes area sewage effluent out
of the basin will be discussed in more detail under the Alternatives
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section of this EIS. It 1s sufficient at this point to Indicate that
nearly all those Involved 1n this project, Including EPA, recognize the
merit and the positive water quality benefits to be derived from such
a system. Obviously, the quality of the lakes' water would be higher
if no effluent, treated or not, were discharged to them.
The second point, whether all people in the District should be
served, has been analyzed by EPA in some detail. Two studies con-
tracted for by EPA on the three lakes (White and Burke legal analysis,
Ref. No. 8; Rocky Mountain Center on Environment environmental analysis,
Ref. No. 7) concluded that the Board did not have to provide sewerage
service to all existing homes and businesses. There 1s obviously a question
as to the definition of what constitutes "service." EPA maintains that
service can consist of the provision of a connection to a centralized
sewerage system, it could consist of septic tank Improvements on an Indi-
vidual basis, or 1t could merely consist of an Inspection of whether or
not individual systems are functioning properly. The water quality control
plan alternative described as the "preferred" system 1n this EIS 1s based
on the above "flexible" definition of "service" and the Board, though still
maintaining Its position on this Issue, has probably become much more
receptive to the above definition than 1t had been in the past (see
Resolutions of March 14, 1977, passed by the Board of Directors as found
in Appendix A of the facility plan). The Importance of a more flexible
definition of "service" is that 1t allows for a more complete consider-
ation of sewerage system alternatives—ones avoiding certain impacts
associated with the original regional system-- and has allowed the Board,
EPA, and others to work toward a resolution of differences.
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The 1972 Master Plan/Regional Sewerage System and EPA Objections
The sewerage system developed under the 1972 Master Plan was
described in the preceeding section, and reference was made to a more
complete description of this system in the facility plan. (This system
is shown as Alternate 3 in the facility plan.) Following completion
of the master plan and its adoption by the Grand County Commissioners
and the Governor of Colorado, EPA was asked to approve the system pro-
posed and thus allow the granting of federal funds (75% federal funding
is allowed under the Federal Water Pollution Control Act) for its actual
construction.
Because of concern about the possible growth, resultant nonpoint
pollution, and certain technical matters, EPA asked the Board and its
consultants, NHPQ, for more information and analysis on these subjects.
A complete coverage of these requests and their chronology is found on
pages II-4 through II-6 of the facility plan. Most important to the
history of this project, EPA in 1974 conducted an additional water quality
survey on the lakes. This survey led EPA to the conclusion that (1) non-
point pollution was the major water quality impact on the lakes and
(2) that the growth inducement potential of the regional system could
lead to a worsening of the nonpoint problem by fostering construction
activity along the sewer lines.
The District and NHPQ responded to EPA's request for more information
by the submittal of a revised environmental assessment and a supplementary
report in February, 1975. EPA, being aware of other governmental agencies'
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Interest and Involvement 1n this area and of public Interest 1n the project,
sent this report out for public and federal, state, and local agency
review. A number of those who received these reports responded, and their
Ideas and positions on the project served as an Important element 1n EPA's
deliberations.
After reviewing the revised environmental assessment, the results
of the 1974 water quality survey, and the comments of other agencies and
Individuals, EPA developed Its position on the District's proposed
regional wastewater treatment project. This position was transmitted
to the Board of Directors of the District 1n a letter dated August 4,
1975 (ref. No. 9).
The position taken by EPA 1n the August 4th letter can be summarized
as follows:
1. The regional sewerage system as proposed by the District
would not be 1n the best Interests of the environment of the Three Lakes
area;
2. EPA's position 1s based on the findings that:
a. nonpolnt pollution was the major water quality problem
of the lakes, and this problem was not being addressed by the District;
b. the extensive sewer line collection system would
probably Induce "uncontrolled" growth along the west side of the lakes
and was speculative and growth-Inducing 1n nature (required eighty new
taps a year 1n order to be financially feasible);
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c. the Induced growth and attendant construction activity
would worsen the nonpoint pollution problem; this was especially true
in view of a lack of local land use regulation addressed to this problem;
d. certain technological aspects of the proposed system,
in particular the underwater vacuum lines in Grand and Shadow Mountain
Lakes, are of concern;
e. the discharge of effluent below the lakes would probably
violate the water rights associated with the Colorado-Big Thompson project;
f. the sewering, and resulting development, of the west
shore areas would conflict with National Park Service plans for the
Shadow Mountain National Recreation Area;
3. instead of the sewerage system as proposed, EPA recommends
a "scaled-down" system that would eliminate these objections as a better
alternative. At the time the letter was written, it was thought that an
upgraded Grand Lake sewage plant and a new one between Lake Granby and
Shadow Mountain Lake would be a possible alternative that would eliminate
most of these objections;
4. EPA does not recommend a "do nothing" approach but believes
that a water quality management plan comprised of point and nonpoint
controls is needed to assure the long-term protection of the lakes.
Following the development and transmittal of this position statement
to the Board by EPA, all parties concerned—EPA, District, Grand County,
State Health Department, National Park Service, Bureau of Reclamation,
and others—have been working to resolve differences, to reevaluate the
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situation, and to develop a water quality plan more responsive to the
environment of the Three Lakes area.
Interagency Aspects
As mentioned 1n the previous section, the views and Involvement
of other agencies Involved 1n the Three Lakes area have played an Im-
portant role 1n EPA's deliberations on the sewerage system project.
Numerous meetings have been held with these agencies with the express
purpose of making an attempt to resolve differences and to gain assis-
tance 1n devising a plan that meets water quality and other environ-
mental protection goals. The agencies with major Involvement 1n the
Three Lakes sewerage project, their type of Involvement, and their con-
cerns as expressed to EPA are discussed Individually as follows.
National Park Service. With direct responsibilities for environ-
mental management and protection of the Shadow Mountain National Recreation
Area and the adjacent Rocky Mountain National Park, the Park Service has
probably had the longest and most direct Involvement with water quality
and environmental Issues 1n the Three Lakes area of any federal agency. As
an agency with a basic mission to protect environmental values, the Park
Service has recognized the need for Improvements in environmental manage-
ment of the Three Lakes region, particularly stressing the need for more
adequate land use and erosion controls.
Unlike other national recreation areas, the Shadow Mountain National
Recreation Area (NRA) was not created by a specific act of Congress
but Instead exists solely on the basis of a memorandum of understanding
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between the Park Service, the Bureau of Reclamation, and the Bureau of Land
Management, which are all agencies in the U.S. Department of Interior (see
pages IV-11 and IV-12 in the facility plan for further discussion on
the NRA). Funds to manage the area are actually taken from operating
monies appropriated for management of Rocky Mountain National Park.
Shadow Mountain National Recreation Area presents the Park Service
with various management problems which they, and others, would like to
correct. First, the very lack of a Congressional act in setting up the
area, giving it management direction, and authorizing funds for its
management does not lend itself to the quality of management and of operation
usually associated with units of the National Park system. Second, the
land ownership pattern of the recreation area—a significant amount of
shoreline and adjoining lands are in private ownership and have been
developed with trailer courts, marinas, resorts, etc., some of which are
not compatible with Park Service standards—has led to a basic conflict
between publicly owned water and privately owned shore!ands. Last, the
Park Service has become increasingly aware that land development and other
activities, particularly that causing accelerated erosion to enter Shadow
Mountain Reservoir, are serious environmental problems.
In May, 1975, the Park Service issued a document for public review
entitled, Draft Master Plan - Shadow Mountain National Recreation Area.
The proposal described in this draft plan and accompanying EIS had a direct
relationship to EPA's deliberations on the regional sewerage system, which
the Sanitation District had previously submitted for approval. The most
direct relationship was due to the fact that the Park Service was proposing
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purchase of some areas of private ownership that were to be sewered under
the District's plan. Obviously, 1t would make little sense to place ex-
pensive and permanent capital Improvement structures such as sewers Into
an area slated for eventual removal of structures and reversion to open
space. Such an action would make little economic sense and would, 1n all
probability, make 1t much more difficult for the Park Service to carry out
its plans. Second, but perhaps less obvious, a regional sewerage system,
with its growth and development Implications overlaid on a lack of land use
regulation on private lands, could lead to further accelerating of an
already serious nonpolnt type water quality problem.
With possible conflicts between the proposed National Recreation
Area master plan and the Three Lakes Sanitation District's sewerage
system master plan, EPA has tried to reach a compromise between the
two. The section of this EIS on alternatives further discusses this
issue, and the alternative preferred by EPA 1s based partially on the fact
that this system permits a large measure of this compromise.
It should be pointed out that, although the Park Service has not been
able to develop a consensus on the master plan, this work is onqoing and
will possibly be submitted to Congress before too long. The preferred
alternative takes these factors into full consideration. The County and
Park Service are considering provisions for federal purchase of some lands
essential to preservation of the aesthetic values of the NRA. One such
area lies south of the Willow Creek lagoon site on the west shore of Lake
Granby. EPA has chosen not to participate 1n the funding of sewerage
service to this area until the NRA plan is finalized.
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Grand County. In the State of Colorado, county government, admin-
istered by a board of county commissioners, is the unit of government
with basic authority to regulate and control the use of private lands
not part of an incorporated community. Because most of the land area
that would have been served by the District's proposed regional waste-
water collection and treatment system and, in fact, all the other
alternatives also considered fall under county jurisdiction, Grand
County land use regulation has been a most important aspect of this
project. Because of the potential relationship between the sewerage
system, land development, and nonpolnt water pollution, the need for Grand
County action to control this problem has been most evident.
Grand County, like most counties outside the populous east slope
area, has only been involved in land use planning for a relatively short
period of time. Grand County's first master plan, the one currently in
force, was adopted in 1971. Like all plans, this one has features that
many, including the County, have found to need revision.
EPA's concern with Grand County land use regulations is mainly related
to how these regulations may or may not control water quality degradation.
Since EPA concluded that the District's regional sewerage plan would
probably lead to land development that would, in turn, lead to worsening
of the nonpoint pollution, EPA has taken the position that Grand County
must be part of any water quality plan for the Three Lakes area and that
the County should be prepared to control these pollutants through land use
regulation.
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It has been obvious to many Involved 1n the Three Lakes situation
that the Three Lakes Water and Sanitation District does not have the authority
to control these Impacts via land use regulation. This authority rests
with Grand County and Its zoning, subdivision approval, septic tank regu-
lations. EPA's main goal 1n light of this discrepancy has been to work
with the County 1n making plans to take positive water quality protection
action that will be 1n conjunction with District sewerage plans.
The most encouraging element of the development of the revised sewerage
system described 1n this document has been Grand County's willingness to
take positive action to revamp and Improve Its land use planning and
controls. Obviously, the County has undertaken this effort because 1t 1s
well aware of Us own land use problems and 1s motivated to prevent their
recurrence. Without this commitment, little progress would probably have
been made 1n resolving the difficult Issues associated with this project.
EPA will not, however, make final approval of construction monies for the
project until the County has enacted the regulations necessary to control
nonpolnt pollution.
Grand County has expressed a number of concerns to EPA on +he
Three Lakes project, Including: (1) a desire to reach a compromise
equitable to the Water and Sanitation District; (2) a desire and need
for EPA to furnish the County with specifics on how County regulations
do or do not protect water quality; and (3) a recognition of environmental
problems, Including nonpolnt water pollution, that need to be controlled.
It should be pointed out that EPA has always been fully aware that the
County 1s the proper authority for these type of local land use regulations
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and respects County rights in this area. It must also be reemphaslzed that
EPA involvement with the County on these issues 1s related to water
quality protection and not to the more general police powers associated
with county land use controls.
U.S. Bureau of Reclamation. The Bureau of Reclamation, as builders
and operators of the Colorado-Big Thompson Project, has had a direct
involvement with the three lakes since this project was constructed
in the late 1940's. The Bureau of Reclamation's interests 1n the water
quality management of the lakes include: (1) protection of this quality
(for example, approximately 16% of the 230,000 A-F diverted to the
eastern slope each year goes for municipal uses); (2) maintenance of
storage volume in the lakes - thus, an Interest 1n prevention of sedimenta-
tion; and (3) the protection of water rights associated with the Colorado-
Big Thompson Project.
The water rights associated with the District's proposed regional
sewerage system have been of concern to the Bureau of Reclamation. Under
that proposal, water that is currently being discharged to the lakes through
the treatment plants and through septic tanks would be discharqed below
the lakes. This water would thus be lost to the Colorado-Big Thompson
system. As will be explained in the section on the "Preferred Alternative"
and in "Mitigative Measures," efforts to solve this water rights issue
have been an important element 1n working out a compromise wastewater
treatment system (ref. No. 10).
It should also be pointed out that the major recipient and user of
Colorado-Big Thompson water, the Northern Colorado Water Conservancy
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District, has expressed the same general concerns about the original
District sewerage system as did the Bureau of Reclamation. The Con-
servancy District especially was interested in the effects of the system
on water rights, water quality, and interference with National Recreation
Area plans (ref. No. 10). As with the Bureau of Reclamation, the Con-
servancy District has been a participant in the resolution of issues
involving the Three Lakes project.
State of Colorado. Though the Federal Water Pollution Control Act
is federal legislation, it provides for a major state role in implementation
of the law. The Water Quality Division in the State Health Department,
with the duty of administering various provisions in the law (water quality
planning, review and monitoring of treatment facility grants, discharge
permits, etc.) in conjunction with the Water Pollution Control Commission
(sets stream standards, approves treatment plant sites, and disburses
federal treatment facility construction funds via a priority system), has
been involved with the Three Lakes project from Its inception. Other
state agencies, because of their various functions—State Division of
Planning, State Fish and Game, etc.—are involved with the management and
Impacts occurring at places like Three Lakes and thus have been part of
the deliberations on this project.
State Interests expressed to EPA on the Three Lakes project Include
(1) concern over the present poor quality discharge from the existing
Grand Lake treatment plant; (2) desire to establish a point and nonpoint
source control plan as soon as possible and end the debate over this
project; (3) concern over the water rights Impacts of the original
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district sewerage system proposal; (4) desire to see better land use
planning for the area; and (5) desire to construct a sewage treatment
system capable of protecting the lakes' water quality.
The State Water Pollution Control Commission will review and either
accept, deny, or ask for modifications on the alternative system shown as
"preferred" in this EIS. The State Health Department has indicated ac-
ceptance of the "preferred" system. Again, State concerns have played a
major role in the deliberations that have led to this stage of the project
(ref. No. 10 for State letters on the originally proposed sewerage system).
U.S. Forest Service. The U.S. Forest Service, though not directly
involved in the management of the lakes themselves, plays an important
role in water quality and environmental protection affairs in the Three
Lakes area. First, national forest lands comprise large amounts of the
watershed of the lakes' tributaries. Obviously, Forest Service activities
on these watershed lands that may contribute to production of sediment—road
building, timber harvest, etc.—can directly add to what has been identified
as the number one water quality problem in the lakes. Second, Forest Service
decisions on allowing ski area development on public lands under their
management (an area has long been proposed by local people at Bowen Gulch, a
site up the North Fork Colorado River valley) are directly related to
population growth and to the subsequent need for, and sizing of, wastewater
treatment facilities.
Concerning the first issue, i.e., maintenance of water quality,
it should be pointed out that the Forest Service, like all federal agencies,
must not violate water quality standards by their activities. EPA has
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had numerous discussions with Forest Service people on this Issue, specifically
as related to Three Lakes. The Forest Service 1s an active participant 1n
local land use planning that has water quality protection as a major goal.
Concerning the ski area Issue, the fact that the Bowen Gulch
development 1s speculative at this point makes evaluation of Its possible
relationship to a sewerage system equally speculative. Before any
such area becomes reality, 1t must first have a proponent with the
financial capability to develop 1t. Secondly, the area must be evaluated
via the Forest Service's own environmental evaluation and EIS process.
Colorado Open Space Council. The Colorado Open Space Council (COSC),
representative of a statewide coalition of environmental groups, has shown
Interest and has been Involved 1n deliberations on the Three Lakes project
for some time. COSC, specifically Its Mater Quality Workshop, has reviewed
and provided comments on the earlier regional sewerage system proposal on
a number of occasions. The COSC concerns with this system have centered
on Its possible growth Inducement aspects, on the acceleration of non-
point pollution from this growth generation, on the use of public funds
that might be better spent elsewhere, and on the technology associated
with the system's underwater vacuum lines and other features (ref. No.
10).
The concerns expressed by COSC have been fully considered 1n EPA's
efforts to devise an acceptable water quality management plan for the Three
Lakes area.
Other Comments. Though not as directly Involved as those agencies
and groups discussed 1n proceeding sections, 1t should be pointed out
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that the U.S. Bureau of Land Management, Mr. James P. Fitzgerald of
Northern Colorado State University, and numerous Three Lakes area resi-
dents and homeowners have expressed opinions via formal letters of
comment, verbal presentations at various public meetings, and Informal
correspondence on water quality management needs for the area. These
comments have varied but basically are the same as those attributed to
the agencies discussed in this part of the EIS. Nearly all who have
spoken out on the project have emphasized the need to resolve differences
and to proceed with a plan to protect area water quality.
Recent History .of the Project
Following EPA's decision not to fund the Sanitation District's
regional wastewater collection and treatment system on August 4, 1975
(ref. No. 8), a series of meetings and studies has been conducted which
was aimed at developing a sewerage system and water quality plan acceptable
to all parties concerned. The major developments and studies will be
described in this section of the EIS with the reader also referred to pages
11-6 to 11-13 of the facility plan for further discussion and a chronology
on the same subject. It should be pointed out that these more recent
developments, aimed at reaching a solution to the Three Lakes situation
and culminating in this EIS, do not comprise a final decision by EPA on
the project. A final decision will be made after completion of the EIS
process.
The studies and deliberations that have occurred up to the present
time have served to define the issues, to clarify some misconceptions, and
to devise solutions to them. The many meetings that have been held,
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ranging from the major policy decision-making occasions on the part of
agency heads and elected officials to staff member work sessions, have
been based on a desire to fully explore all Issues and to better under-
stand viewpoints held by opposite parties. These meetings have been open,
candid, and have resulted in development of a "compromise" plan with
commitments from the County, Sanitation District, and others to correct
problems with the earlier proposal. These meetings and work sessions have
involved all the agencies with direct Involvement with Three Lakes including
EPA; Grand County Board of Commissioners and County staff; NHPQ; Three
Lakes Water and Sanitation District Board of Directors and their legal
counsel; National Park Service representatives; Rocky Mountain Center on
Environment (hired by EPA to assist with an environmental assessment on
the project); State Health Department; Northwest Colorado Areawlde Water
Quality Planning Organization; Bureau of Reclamation representatives; and
Northern Colorado Water Conservancy District representatives. The Colorado
Open Space Council has also been in attendance at times.
The major thrust of these meetings was to analyze the problem areas
associated with the earlier sewerage plan and to develop information
needed to better assess the Three Lakes situation. Another hoped-for
outcome running concurrently with these efforts was the development of an
alternative sewerage system that would, 1n conjunction with nonpoint
controls, satisfy recognized point source treatment deficiencies.
These meetings resulted in agreement that (1) nonpoint source
control regulations needed to be strengthened by the county and (2) that
the actual trend of water quality 1n the lakes was very difficult to
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pinpoint. It was decided, in view of this situation, that an approach
emphasizing a high level of treatment would be the safe course of action
to follow. Also, because of the long history of the project and the ex-
tensive work that had already gone into alternatives evaluation, it was
decided that the six alternatives shown in the facility plan adequately
represented the possible array of alternative sewerage systems that should
be considered.
As has been mentioned several times in this EIS, nonpoint type
pollution arising from man-caused erosion and resultant sedimentation
and nutrient loading of the lakes had been identified as a major problem
critical to the preservation of the lakes. Nonpoint controls are, by
their nature, land use controls. The control of nonpoint pollution involves
such things as not allowing construction on steep and unstable slopes,
keeping road grades to a low degree, requiring revegetation of disturbed
areas, requiring setbacks from lake shores, etc. These controls are com-
monly expressed in a local government's land use map and related zoning
and subdivision ordinances.
Because there was some disagreement between Grand County and EPA
over the adequacy of County land use regulations as related to nonpoint
control, the decision was made to hire an outside analyst to review the
County laws. The Denver law firm of White and Burke was chosen to do
this analysis. White and Burke submitted a final report to EPA and the
County in January, 1977, (ref. No. 7) entitled, Review and Analysis of
Grand County, Colorado. Land Use Laws Related to Water quality Protection.
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The White and Burke study basically pointed out that the County had
a number of means available to 1t to control water quality Impacts. These
means Included use of existing zoning regulations, special use permits,
subdivision regulations, planned unit development regulations, building
codes, and other features of the various authorities available to county
government. Use of these various authorities would result 1n prohibition
or control of developmental activity on shorelines, hazardous and unstable
areas, floodplalns, areas unsuitable for septic tanks, etc.
One of the most difficult aspects of land use control as related to
water quality protection 1n the Three Lakes area 1s that related to already
platted subdivision lots. As explained 1n the later section of this EIS
entitled "Land Use," there are some 4,000 already platted lots 1n this area.
These lots, many of which are quite small, have been on the County books
for years, and their owners have certain legal rights. Unlike the situation
where a developer wants to gain county approval for subdivision of presently
unplatted land by going through whatever review process exists and meeting
whatever requirements are current, these lots have already been approved
and there 1s no authority requiring the lot owner to go throu^) the sub-
division approval process again.
Because availability of a sewage collection system could possibly
make many of these small lots "developable" (the County now requires a
two-acre minimum lot size when no centralized collection system 1s
available and a septic tank must be used) and because many of these lots
and their associated roads were laid out without any water quality Impacts
1n mind, they have been of great concern to EPA and the County as related
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to the Three Lakes project. White and Burke were asked to examine the
possibilities for control of potential water quality problems from develop-
ment of these lots.
White and Burke expressed an opinion that certain control over such
sources could be obtained through the use of such techniques as building
permit regulations, regulation of nonconforming uses, nuisance regulations,
adoption of certain H.B. 1041 regulations, and adoption of H.B. 1034
regulations. White and Burke did, however, advise a word of caution by
stating that:
The regulation of water quality Impacts created
by existing development or development approved under
prior versions of subdivision regulations or County
platting regulations is largely untested in Colorado.
While the consultant has offered as suggested techniques
only those which it has concluded are lawful under
existing Colorado statutes and case law, the novelty
of the suggested techniques mandates that any specific
proposed regulation based on these suggestions be care-
fully reviewed to assure that 1t 1s in fact valid. To
assure that a particular regulation is valid the County
must devise regulations which:
(1) Have as their purpose the regulation of an
identifiable water quality hazard to the public health,
safety, or welfare, and which
(2) Serve as a reasonable means of regulating
a land use in order to aid in controlling that problem.
(Ref. No. 7, pages 119 and 120.)
Obviously, there is no simple solution to the control of land
uses that may degrade water quality 1n the Three Lakes area. White
and Burke suggested a number of possible regulatory schemes that could
be used to accomplish this goal, and, most important to Three Lakes
water quality protection, Grand County is 1n the process of formulating
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and enacting certain of these. This development 1s probably the single
most Important element of the whole process of deliberation on the Three
Lakes sewerage project and 1s, 1n EPA's opinion, the basic reason why
planning for such a system has been able to proceed to the EIS stage.
The type of controls that Grand County will Institute are as described
1n the letters between Grand County and EPA 1n Appendix A of the facility
plan. Enactment of these measures will be required by EPA before any
federal funds are approved for actual construction of a Three Lakes
sewerage project.
It should be pointed out that Grand County has recognized the need to
Improve Its whole planning/regulatory function 1n the Theee Lakes area 1n
order to protect not only water quality but also to protect general
aesthetics, to promote a more favorable tourist Industry climate for the
area, and to provide for a more orderly and efficient public service and
public utility situation. In order to develop a better Three Lakes area
plan, one that 1s legally defensible and on which new regulations can be
based, the County has taken two steps.
First, the County Commissioners created a subgroup to the County
Planning Commission called the Three Lakes Planning Commission. This
commission, Involving a citizen advisory board and members of the
County planning staff, has been at work for over a year and has con-
ducted a number of public meetings aimed at generating local land use
goals.
Though a final plan has not been officially adopted by the County
Commissioners at this time, the Three Lakes Planning Commission has fully
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recognized the importance of water quality protection for the area,
has developed a goal of maintaining water quality, and is recommending
steps to reach this goal (ref. No. 11). Though it defers to the Three
Lakes Water and Sanitation District for decisions on the exact type
and configuration of a sewerage system, the planning commission has listed
as priority items the need to control both point and nonpoint type
pollutants for the three lakes.
As part of its Three Lakes planning effort, Grand County has funded
and is using the planning and environmental analysis of Dr. Dennis Lynch
at Colorado State University and that of COMARC Design Systems, a private
environmental planning firm. Dr. Lynch, building on previous land carrying
capacity analysis that he and Colorado State associates developed for
eastern Grand County, made a detailed land capability study for the Three
Lakes area. This effort resulted in land suitability maps (specific areas
of land were rated per suitability for construction, septic tanks, etc.)
and a number of policy proposals designed to keep land uses compatible
with these suitabilities.
The second effort, that being conducted for the County by COMARC
(the Northwest Colorado Areawide Water Quality Management Project is
also sponsoring this work along with a financial grant from EPA), is
refining and adding to Dr. Lynch's work by the production of computer
drawn land capability maps developed on 400' x 400' cells. The COMARC
system, using twelve categories of resource and land uses (soils, wildlife,
ownership, etc.) has developed a number of interpretive and constraint
maps (erosion hazards, environmental limitations, etc.). The purpose of
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the Comare system Is to build data-based land use capability maps that
will serve as the basis for allowing, denying, or modifying proposed uses
of specific land areas. This type of analysis, based on specific data,
Is needed to give a factual and legally defensible basis to County land
use regulations. Water quality Impact analysis and related maps showing
which areas should not be developed or developed only with certain pre-
cautions taken 1n order to protect water quality have been a major element
of COMARC's work.
Because of the long history of the Three Lakes project and due to
the fact that the Sanitation District and EPA had developed somewhat
polarized positions, EPA also decided to hire a separate outside con-
sultant to analyze and report on the potential environmental Impacts
associated with the alternative sewerage systems possible for the Three
Lakes area. It was hoped that such an analysis by a group not Involved
1n the long series of deliberations on the project would help to define
and to refine the Issues and to move all the parties concerned toward
a resolution of differences. After gaining agreement from the Board of
Directors of the Sanitation District to hire this Independent consultant,
EPA hired the Rocky Mountain Center on the Environment (ROMCOF) to fill
that role.
ROMCOE assembled a team consisting of a planner, attorney, engineer,
economist, and writer and began an analysis of the Three Lakes situation
and also began to participate 1n various meetings and discussions on the
project. Though dealing with a complex and controversial situation and
with a rather limited budget, ROMCOE submitted Its environmental assessment
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to EPA in June, 1977. This assessment, listed as reference No. 6, has
been used as a supporting document 1n preparation of this EIS.
ROMCOE believed that there were certain problem areas related to
provision of sewerage service in the Three Lakes area. These included:
1. lack of definitive data describing the degree, extent,
or trend of water quality of the three lakes;
2. the fact that the various sewerage system alternatives do
not directly confront the nonpoint pollution problem;
3. that all alternatives, especially an alternative emphasizing
extensive septic tank management, were not considered;
4. that the system proposed by the Sanitation District (Willow
Creek lagoon alternative) may not be the best expenditure of federal
monies and might, in fact, be better spent elsewhere on other projects;
5. that wildlife, water supply, relationships to other sani-
tation districts within the Three Lakes Sanitation District boundaries,
and the debt burden and its effects have not been adequately analyzed.
In addition to pointing out what they considered the above problem
areas, ROMCOE also evaluated the impacts of the alternative sewerage
systems as presented in the facility plan. These alternatives were
evaluated on twenty-eight different criteria and then ranked 1n terms of
negative impact on these various criteria (aesthetics, secondary growth
factors, water rights, etc.). It should be pointed out that ROMCOE con-
cluded that they had insufficient data for the areas of water quality,
fish and wildlife, air quality, protection of lakes, water supply, and
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groundwater quality to enable the use of these criteria 1n this ranking
process.
Based on the results of this ranking process, ROMCOE concluded that
"Alternatives 1, 2, 4 and 6 (see Chapter VI of facility plan for discussion
of alternatives) do not exhibit a very wide spread in relative negative
impacts." ROMCOE also concluded that "due to the District's desire not to
be involved in an alternative with a very large non-sewered component,
consideration of the 1mplementab1l1ty of the alternatives would narrow
this spread." (Page 18, ref. No. 6.)
Another conclusion drawn by ROMCOE in their final report includes
the finding that the sewerage facility plan favored by the Sanitation
District, in conjunction with nonpoint controls, could improve water quality
in the area. Also, ROMCOE found the cooperative accomplishments of EPA,
Grand County, and the District for land use controls to be commendable.
Last, ROMCOE stated that "the validity of the centralized system, as
represented in the recommended alternative, is not supported in a broad
view of the Three Lakes situation. Unfortunately, no other remedy is
obvious either. Whether or not a mix of approaches, including a cen-
tralized system, land use controls and septic management plan, can have
a predictable Impact on water quality in the area simply isn't certain."
(Page 40, ref. No. 6.)
EPA has recognized the questions identified by ROMCOE on this project
and has attempted to answer them in this EIS. Though data gaps will exist
with any project, 1t is EPA's opinion that the amount of data supporting
decisions at Three Lakes is considerable and probably much more extensive
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and concrete than that used 1n most projects of similar magnitude. Given
the above difficulties, EPA believes a decision on a centralized sewerage
system, bolstered by strong mitlgative measures, can be made and supported
at Three Lakes.
EPA's Selection of a "Preferred" Alternative
Following EPA's rejection of the District's original proposal for
a regional wastewater collection and treatment system, efforts have con-
tinued between all those involved to resolve points of contention and
to develop a water quality plan acceptable to all. The previously
described studies—White and Burke; ROMCOE—and further efforts by NHPQ,
EPA, the Park Service, and Grand County on alternatives and land use
plans were involved. A chronology of these activities 1s found on pages
II-6 through 11-12 of the facility plan.
Through the more complete development of alternatives, a more ex-
tensive consideration of impacts, and commitments and Involvement of
the Grand County Commissioners, the Bureau of Reclamation, the Board of
Directors of the District, and the Park Service, the Regional Administrator
of EPA was able to select a "preferred" alternative sewage collpction and
treatment system. This selection, based on a full consideration and
comparison of environmental, economic, and policy factors, was made on
March 21, 1977. It must be emphasized that this was not a final decision.
A final decision by EPA on this project must await completion of the EIS
process and the public review provided by it.
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•l I
SECTION ID
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IV. The Setting
The Three Lakes region is located in the northeastern portion of
Grand County, Colorado, just to the north of Middle Park and immediately
west of the front range of the Rocky Mountains. The area is within a
three-hour drive from Denver and other metropolitan areas along the
northern front range. Federal Highway 34 serves as the major road through
the Three Lakes area and through Rocky Mountain National Park. Locational
maps are found as Figure II-l (page 11-15) and Figure 11-2 (page 11-17)
of the attached plan.
The Three Lakes (Grand, Shadow Mountain, and Granby), the National
Park Service-administered Shadow Mountain National Recreation Area, the
adjacent Rocky Mountain National Park, the Arapahoe National Forest,
numerous private tourist and resort facilities, and the associated moun-
tain scenery are major attractions that yearly draw thousands of
visitors to the area. Grand Lake is a natural lake formed by glaciation,
while the other two lakes are man-made reservoirs built as part of the U.S.
Bureau of Reclamation's Colorado-Big Thompson Project in the late 1940's.
Overall, the Three Lakes drainage basin, encompassing approximately
396 square miles, can be characterized as a high mountain valley ringed
by mountain peaks, forested except for the valley floors and open parks,
and drained by the headwaters and tributary headwater streams of the
Colorado River.
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It is an area of outstanding natural beauty, which has been im-
pacted to varying degrees by the creation of two large reservoirs, the
construction of numerous roads, and the urbanization of major parts
of the valley floor. Further discussion of the setting of the Three
Lakes area is provided in Chapter IV of the facility plan.
Land Use Patterns
Land use patterns, both existing and as may develop in relationship
to a centralized sewer system, have been a major consideration in the
long history of deliberations on the Three Lakes project. EPA's main
involvement with the land use issue has been related to how land develop-
ment (provision of sewer service will lift a present restraint to develop-
ment of land parcels too small or unsuitable for septic tanks) could
generate nonpoint pollution (erosion and sedimentation). EPA and others
have also been concerned over the possible impact of this possible develop-
ment on the NRA and other environmental values such as aesthetics. For
these reasons, a careful look at the land use issue is necessary and, as
presented later in this EIS, the mitigation of these possible impacts by
Grand County via land use planning and regulation is essential to an environ-
mentally acceptable sewerage project.
The total Three Lakes drainage basin area encompasses some 396
square miles, much of which is in a relatively natural state. In terms
of the total 396 square mile drainage basin, some 35 square miles, or
9 percent, is in private ownership. Though the percentage of private land
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is relatively small in comparison to the total land area in the basin,
it should be noted that 35 square miles are sufficient to accommodate a
very large level of development and also that much of this private land
is located in the aesthetically and environmentally sensitive stream
valleys and along the western side of the lakes.
Rocky Mountain National Park east and north of the lakes, though 1t
contains some development along Highway 34, is basically managed as
wilderness area. Arapahoe National Forest lands located west and south-
east of the lakes are managed for multiple use purposes and, as such,
contain some roads, timber harvest areas, and other existing or potential
development. However, several unroaded areas, Indian Peaks to the east
and some areas forming the western boundary of the Kawanechee Valley, are
currently undergoing evaluation for possible wilderness classification.
Shadow Mountain National Recreation Area, encompassing the lakes and the
immediate area around them, is managed by the Park Service. The NRA in-
cludes, or 1s adjacent to, extensive developed lands along the west sides
of Shadow Mountain Lake and Lake Granby with the eastern shores of these
two reservoirs being lightly developed or undeveloped.
The bulk of the developed lands in the area He along the. Highway 34
corridor along the western shores of Shadow Mountain Reservoir and Lake
Granby, in a core area centered at the Town of Grand Lake and around
Grand Lake Itself, and 1n a subdivided and developed area northeast of
Grand Lake and extending for some distance up the Kawanechee Valley.
The majority of this developed land Hes within the boundaries of
the Three Lakes Water and Sanitation District. A land ownership map
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of the immediate Three Lakes area (that land area within the boundaries
of the Three Lakes Water and Sanitation District) is shown as Figure IV-15
in the facility plan. This map offers a visual presentation of develop-
ment which, as previously stated, is mainly on private lands concentrated
along the western side of the lakes and northward along the North Fork
Colorado River. Also, in addition to the previously mentioned Rocky
Mountain National Park lands to the east and north of the lakes and U.S.
Forest Service lands on the west and south, there are some U.S. Bureau of
Land Management and U.S. Bureau of Reclamation tracts scattered among
other ownerships.
Historically, most of the privately owned land 1n the region was
devoted to ranching. Large ranches still exist in the southern portion
of the Three Lakes region but farther north, in the area under considera-
tion in this EIS, ranching has been lost to the reservoir inundation
or has become more of a "guest ranch" type operation. Much land has
been subdivided and offered for sale as residential or recreational
housing property.
The Three Lakes Water and Sanitation District includes many platted
subdivisions in addition to the Town of Grand Lake. These subdivisions
contain numerous lots ranging in size from one-tenth of an acre to more
than four acres per lot. Some of these subdivisions were platted many
years ago, while others are more recent. In the five-year period after
the two reservoirs were built, there were 25 filings. After that, the
rate of subdivision filing dropped off for ten years, then started to
increase again in the 1950's (reference No. 1). Again, reference to the
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land ownership map in the facility plan shows that the majority of these
subdivisions are located along the western side of the lakes.
These subdivisions, and their existing and potential environmental
impacts, are a major concern of EPA and others as they relate to the
proposed sewerage project. This subject is treated in more detail else-
where in this EIS, but basically the issue is that provision of sewer
lines may make these lots, many of which were laid out with no considera-
tion for environmental impact, much more "developable" than if no sewer
were available. Also, for further discussion on this subject see page
IV-10 in the facility plan.
Currently, there are approximately 1,500 existing residential units
in the Three Lakes region (ref. No. 2). The Three Lakes Water and Sani-
tation District has proposed providing sewerage service to some 1,900
units in the area. ( A "unit" is an existing single development that
would be a source of sewage. The 1,900 figure includes National Park
Service campgrounds and commercial units such as motels.) The
majority of these residential units would be served by the Sanitation
District's proposed sewerage plan (see page VI-7 of the faclHt^ plan
and Figures VI-1 and VI-8).
Commercial developments, basically tourist-oriented facilities such
as motels, lodges, marinas, restaurants, shops, gas stations, etc., are
located along the Highway 34 corridor and at the Town of Grand Lake. The
Town of Grand Lake developed as a resort and tourist-oriented community
long before the Colorado-Big Thompson reservoirs were constructed and
remains as the major concentration of this type of activity 1n the Three
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Lakes area. Overall, there are some 55 motels and lodging establishments
in the region supplying an estimated 660 rental units (1973 data from
ref. No. 1).
A summary of land uses in the Three Lakes area has been recently
developed by COMARC Design Systems, a land planning and analysis firm
that is under contract to Grand County and the Northwest Colorado Water
Quality Planning Project to do detailed land and resource mapping
and evaluation for that area. Though the planning area chosen by Grand
County for use in the COMARC effort is not contiguous with the boundaries
of the Three Lakes Water and Sanitation District, they do cover almost
the same land area. The COMARC analysis summarizes Three Lakes land
uses as:
Type Use Area in Acres Percent of Area
Lakes 8011.021 17.43
Urban 58.77 .13
Vacant Urban 14.69 .03
Residential 999.08 2.17
Trailer 116.19 .24
Power Generation 146.92 .32
Water Treatment 14.69 .03
Recreation 176.31 .38
Campground 18.37 .04
Golf Course 154.27 .34
Special Recreation 14.69 .03
Irrigated Hay 1928.37 4.'20
Range 5417.81 11.79
Misc. Range 1355.37 2.95
Wetlands 2953.17 6 43
Water 187.33 .41
Con. Forest 23698.80 51 57
Dec. Forest 697.89 1 52
1 Small areas of Grand Lake and Lake Granby
are not within the COMARC study boundary.
(Ref. No. 3)
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Land ownership of the Grand County study area 1s summarized by
COMARC as:
Owner Are~. in Acres Percent of Area
Bureau of Reclamation 547.29 1.19
Bureau of Land Management 275.48 .60
National Recreation Area
(Park Service) 822.77 1.79
Grand Lake Metro
Recreation District 5663.31 12.32
U.S. Forest Service 9046.83 19.69
Park Service 5046.83 10.98
Private 16543.61 36.00
(Ref. No. 3)
Grand County has compiled subdivision data on the Three Lakes area
as part of Its land use planning. This data lists the following Informa-
tion on subdivisions (Grand County Planning Area C encompasses the
Three Lakes area and covers nearly the same private land area as 1s
contained 1n the Three Lakes Water and Sanitation District boundary.):
Total number of subdivisions: 81
Total land area of the 81 subdivisions: 3,459.31 acres
Number of developed units (residential): 1,478
Number of undeveloped lots: 3,283
Building Permits Issued: 1974 - 38
1975 = 25
1976 = 31
1977 (as of 6/1) = 19
(Ref. No. 2)
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Figures compiled in 1973 under a study entitled Three Lakes Regional
Planning Study reveal the following about subdivision trends in the Three
Lakes area:
Amount of Subdivided Land,
By Filing Date of Plat
Before 1945 499.4 acres
1946-1949 275.5 acres
1950-1954 438.7 acres
1955-1959 172.6 acres
1960-1964 239.7 acres
1965-1969 499.1 acres
1970-1972 523.7 acres
This study also concluded that the trend was toward subdivisions
containing larger lot sizes. This trend was probably partly attributable
to the need for larger lot sizes to accommodate adequate septic tank
leach fields. It should be noted here that Grand County now requires
a two-acre lot size if a public sewage collection system is not available
(subdivision regulations revised August 31, 1972).
Note - The Three Lakes Regional Planning Study listed 84 sub-
divisions in the area totaling 2,737.67 acres and containing
4,168 lots. These are different figures than those supplied
by Grand County under ref. No. 2. This difference is probably
attributable to the use of slightly different study area
boundaries.
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The Lakes
As stated, Grand Lake 1s the only natural body of water of the
three lakes, and Lake Granby and Shadow Mountain Reservoir are man-
made reservoirs built as part of the Colorado-Big Thompson Project by
the U.S. Bureau of Reclamation. As a result of this project, all three
lakes are linked 1n a somewhat complex hydrologlc manner.
Basically, Lake Granby acts as the major storage facility of the
system, collecting and holding spring runoff. This water is then pumped
back during irrigation season into Shadow Mountain Reservoir, from where
1t flows into Grand Lake and then out the Adams tunnel, which runs under
the Continental Divide. The water is delivered for Irrigation and muni-
cipal uses on Colorado's eastern slope area between Ft. Collins and Boulder.
(Further discussion on this system 1s found on page III-4 and IV-7 of the
facility plan.) Also, though 1t will be discussed further 1n this EIS
under Water Quality, it should be noted that the complex hydrologlc arrange-
ment of the three lakes—flows go 1n either direction, depending on the
season and operational demands with water detention times varying consider-
ably—makes an equally complex task out of water quality analysis and Impact
evaluation.
The three lakes collectively cover more than 8,800 acres of water.
Lake Granby, by far the largest of the three, has a maximum pool of 7,256
surface acres. Lake Granby's water level, however, may fluctuate from
15 to 75 feet annually, depending on runoff and on demands made on the
system by the eastern slope users. Shadow Mountain Lake, with only 1,356
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surface acres, maintains a constant water level, as does Grand Lake
with which 1t 1s connected by a navigable channel (ref. No. 4).
Grand Lake is almost completely ringed by private ownerships,
which have been developed into residential units and some commercial
establishments. The eastern shorelines of Lake Granby and Shadow Moun-
tain, the highly scenic backdrops for views from the Highway 34 corridor,
are under federal ownership and are basically undisturbed. The western
shores of these two lakes, the shores most accessible to people, are,
for the most part, privately owned. These private tracts have mostly
been developed in some manner Including resorts, marinas, campgrounds,
homes, and trailers. Some public land does exist on these western shore-
lines (again, refer to the land ownership map, Figure IV-15, in the facility
plan), but these lands consist of a relatively small portion of the area.
Overall, the three lakes form the focal point for much of the
recreational activity in the area. The maintenance of the water quality
of the lakes, the problems with some of the lakeside development, and the
nature of the future management of the lands surrounding the lakes make
up the major environmental protection conflicts associated wit^. the region.
The Tributaries
The maintenance of the water quality of any lake is obviously
dependent to a large extent on the quality of water flowing into the lakes
from its tributary streams. In the case of the three lakes, the pollutant
load reaching the lakes from their tributaries has been the basis of part
of the environmental controversy involving the area. Because human
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activity (land disturbance, etc.) can degrade the quality of streams
and thereby the lakes, any environmental Impact evaluation of Three
Lakes must Include these streams and the land uses Involving them.
Drainages on the east side of the lakes are comprised almost en-
tirely of public lands. These tributaries include the North Inlet, East
Inlet, Arapahoe Creek, and a number of smaller tributaries. Only some
2% of the drainage area is in private ownership, with the public lands
1n these drainages (Arapahoe National Forest and Rocky Mountain National
Park) managed as "undeveloped" type areas. These drainages are the least
Influenced by man's activity of any in the study area.
Drainages to the north and west of the lakes contain a larger per-
centage of private ownership, but the predominant ownership is public.
This Includes the North Fork of the Colorado River, Willow Creek, Soda
Creek, Stillwater Creek, and Little Columbine Creek drainages. Land
uses in these drainages are much less homogenous, but, in general, the
headwaters and upper reaches of the streams are in public ownership with
the private lands occurring in the lower segments nearer their confluence
with the lakes.
Stillwater and Soda Creeks are approximately 20% in private owner-
ship with land uses in these areas including subdivisions, irrigated
hay meadows, livestock grazing, timberland, and roads. Little Columbine
Creek drainage, 1n contrast, is comprised entirely of private land with
a high intensity subdivision area completely encompassing Columbine Lake.
The North Fork of the Colorado River arises in Rocky Mountain National
Park but flows through private lands in its last ten miles before reaching
Shadow Mountain Reservoir. Land uses are similar in the private sections
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to those found in the Stillwater and Soda Creek drainages. The area
of the drainage in the Park, though lightly developed, does carry High-
way 34 and has several Park Service developed areas (campground, housing,
visitor center). It should also be noted that the North Fork Colorado
drainage contains the site for a proposed developed winter sports site
and also, according to the Three Lakes Regional Planning Study, has high
potential and is suitable for further subdivision development (ref. No. 4).
Social and Economic Setting
The economy of the Three Lakes project area is geared primarily
to the tourist and recreation business. Though there are several ranches
and some irrigated grazing lands within the Sanitation District boundaries,
employment other than tourism is slight and consists mainly of construction
people, government maintenance workers, professional people, and laborers.
Because of its tourism basis, the income of the residents of the
Three Lakes area is highly dependent upon retail sales and services.
A predominant characteristic of this income is its "seasonality" with the
summer months predominating and the winter months accounting for only a
small percentage of the total year's economic activity. The following
sales tax information (figures are for amount of taxes returned to the
community by the State) for the Town of Grand Lake show this "seasonality"
very wel1:
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January, 1976 - $ 3,767.08
February, 1976 - $ 2,075.60
March, 1976 - $ 3,330.72
April, 1976 - $ 1,885.01
May, 1976 - $ 1,616.43
June, 1976 - $ 4,021.56
July, 1976 - $13,276.58
August, 1976 - $20,272.27
September, 1976 - $18,058.75
October, 1976 - $11,821.17
November, 1976 - $ 3,854.58
December, 1976 - $ 2,101.67
(Information provided by Town of Grand Lake, June 10, 1977)
One of the major goals expressed by the residents of the Three Lakes
area in such past planning efforts as the Three Lakes Regional Planning
Study and current efforts to develop a new Three Lakes comprehensive plan
has been for the improvement of the area's year round economy. Numerous
ideas have been expressed on how to accomplish this goal, some of which
are being pursued by local residents. Though wintertime activities have
increased in recent years—basically due to the weekend and holiday in-
flux of snowmobilers--a ski area (probably located at a site in the
Kawanechee Valley) is held out as the major potential solution to the
problem. To date, though, actual plans for such an area do not exist and
such a development remains highly conjectural.
The Three Lakes seasonal economy and the population fluctuations
that are associated with it have an important bearing on the type
and financing of a sewerage system and water quality management
system for the area. Significant factors to be considered because of this
situation include (1) sewage loads reach a peak in the few summer months;
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(2) the tax base needed to pay for costly utility services such as
sewage systems 1s much less than 1n areas with more stable and populous
economies; and (3) pressures exist for the creation of Income generators
such as ski areas, which in turn require that there be made available
such services as sewage collection and treatment. Each of these issues
1s discussed further in later sections of this EIS.
Water Quality
One of the major difficulties with the Three Lakes project has been
attempting to reach an understanding of the actual status of the quality
of the lakes' water. Because of these difficulties it has been hard for
all those concerned—Sanitation District, EPA, State, Park Service, and
others—to reach agreement on how best to meet the water quality maintenance
needs of the area.
The following is a summary of past water quality studies of the Three
Lakes taken from the Three Lakes Sanitation District's 1975 Revised
Environmental Assessment (ref. No. 5). This summary, and the observations
that are included, points out the difficulties involved in analysis of the
status of the quality of the lakes' water. The reader is also referred
to pages III-3 through 111-10 of the facility plan for further discussion
of the water quality of the lakes. (The facility plan and the former
reference are somewhat duplicative 1n their discussion on this subject,
but the two together offer a more complete accounting than if read alone.)
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Information on water quality and possible pollution problems in
the Three Lakes area has been collected by numerous agencies since the
early 1950's. Studies include those by the Joint-Algae Committee (1954);
State Health Department (Smades and May, 1969, and others); Colorado
Game, Fish and Parks Division (Nelson, 1971); Environmental Protection
Agency (Timrn and Seeley, 1970); and Colorado State University (Kugrens
and Paulsen, 1972). Some data has also been collected in the area by the
U.S. Geological Survey, U.S. Bureau of Reclamation, and the National Park
Service. The most recent work has been done by EPA (1974 and 1975) and
by the proponents of the Windy Gap Project.
Because of the numbers of different agencies involved and variations
in research techniques and methods, conclusions from evaluating the past
and present conditions of the lakes or projecting future conditions have
been difficult. However, discussion of these studies and the general
effects of pollution or eutrophlcation problems will be beneficial in
understanding water quality situations in the lakes.
The present three lakes were created in the 1940's with construction
by the Bureau of Reclamation of Lakes Granby and Shadow Mountain and their
connection with the existing natural Grand Lake. The project serves to
divert water to the eastern slope of Colorado via the lake systems and a
diversion tunnel (Adams Tunnel) to the east slope. Morphometric and physical
data concerning the lakes are as follows:
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Mean Approximate Average
Depth Surface Area Average Volume Total Water-
Lake. Feet in Acres In Acre Feet Exchange Time**
Grand 135 507 68,500 96 days
Shadow
Mountain 10 1,700 17,700 19-23 days
Granby 74 7,000 324,300 570-730 days
** Based on calculations by Nelson (1971)
By means of pumps and diversion structures, water flow patterns
through the lakes are as follows:
1. During spring runoff periods from May through June, water
from Grand Lake and Shadow Mountain Reservoir flows into and fills Lake
Granby.
2. From August through April, depending on seasonal water
needs on the east slope, water is pumped from Lake Granby to Shadow
Mountain Reservoir to Grand Lake, where it exits through the Adams Tunnel.
These flow patterns allow for the free mixing of water in the lakes
and exchange of pollutant or nutrient materials between the lakes, depending
on the direction of water flow at a given time. The shallowness of Shadow
Mountain Reservoir, its role in receiving basin runoff from the North Fork
of the Colorado River, sewage effluent from the Grand Lake sewage treatment
plant, and its location between the other lakes make it the primary source
of pollutant or nutrient materials to the lakes' systems.
Two different yet related conditions must be considered in the lakes:
pollution and eutrophication. Pollution will be considered to mean too
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much of a given material or substance present over a given time period
to Interfere with or prevent man's use of the lakes for domestic, fisheries,
aesthetic, or recreational purposes. Pollutants may Include organic
matter such as sewage effluent, bacteria, algae, aquatic plants, dead fish,
fish Innards, and related material, or Inorganic substances such as mineral
and metallic compounds, silt, sand, suspended materials, or oil or gas-
oline films from outboard motors. Nitrogen, phosphorus, sulfates, and
related compounds may be contributed by either runoff or natural biological
processes, or from organic materials associated with domestic sewage
effluent.
Eutroph1cat1on literally means "good eating." A eutrophic lake 1s one
that 1s rich 1n nutrients (nitrogen, phosphorus, sulfates, etc.) and
generally supports large populations of plant and animal life. An oil go-
trophic lake generally has low quantities of available nutrients and a
low productivity with respect to animal and plant life. The natural
process of aging in most high mountain lakes, such as the Three Lakes,
proceeds from conditions of oligotrophy to those of eutrophy. As sediments
and nutrient materials are washed Into new, relatively nonproductive lakes
and form deposits on the lake beds or become Incorporated into the lakes'
biological and chemical systems, the biological productivity of the lakes
Increases. The end result of such trophic changes under long-term natural
conditions 1s a successions! change from a relatively deep unproductive
lake to a shallow productive lake to a f1lled-1n lake basin on which ter-
restrial plants and animals become established (Welch, 1952).
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Man, with his technology and apparent inherent ability to pollute
or change his environment, can speed up the rate of eutrophication in
lake systems. This ability has been called "cultural eutrophication"
to distinguish the process from natural eutrophication. Cultural eutro-
phication can and does create serious pollution problems in lake systems,
since overloading of lake systems with nutrients and organic materials can
cause loss of oxygen in such lakes and a decline in bioproductivity.
In general, the process of cultural eutrophication can be reversed if
pollutant or nutrient materials come from a specific identifiable source
such as an improperly functioning sewage treatment plant or septic systems.
Other forms of cultural eutrophication are much harder to control with
present technology, such as increased nutrients being washed into waters
from fertilized lawns, gardens, or agricultural lands surrounding lakes,
or increased sediment loads and suspended materials washing into the lakes
as a result of human development and land use impacts on surrounding areas
within the watershed. In the Three Lakes area some cultural eutrophication
is occurring in the lakes. Although some of this is controllable through
the construction of a proper sewage system, other less obvious cultural
eutrophic conditions will continue without improved land use and management
controls in the area to prevent these detrimental effects.
Biologists who have investigated the three lakes in the past have
different views on whether the three lakes are eutrophic or not. However,
their contentions and interpretations at given points in time on trophic
situations in the lakes may all be relatively correct. Pennak (1955) con-
sidered the three lakes to be eutrophic. Timm and Seeley (1970), Nelson (1971),
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and Kugrens and Paul sen (1972) did not consider Lake Granby or Grand Lake
to be eutropMc. Kugrens and Paul sen (1972) considered Shadow Mountain
Lake to be an eutrophic lake, while Nelson and T1mm and Seeley considered
1t to be ollgo- or mesotrophic. However, the latter two studies agreed
that cultural conditions could lead to eutrophic conditions in all of
the lakes. It 1s quite likely that, when Pennak (1955) and the Algae
Committee (1954) examined the lakes 1n the early 1950's, they were showing
definite eutrophic signs and that conditions have changed 1n the following
years. New constructed reservoirs, such as Granby and Shadow Mountain
1n the late 1940's, frequently are very productive 1n their first few
years as a result of high nutrient levels and organic materials present
1n the lake bed as 1t 1s filled. These nutrient loads are gradually
reduced so that, in a sense, the three lakes may have gone from a brief
period of eutrophy to the more expected high mountain condition of ollgo-
trophy and are now cycling towards Increasing eutrophic conditions;
Shadow Mountain Reservoir 1s certainly heading towards eutrophy.
Over the years the following general conditions in the lakes were
noted:
1. In the early 1950's, an increase was noted 1n Grand Lake
and attributed to the Colorado-Big Thompson project and the construction
of Shadow Mountain Reservoir. The Algae Committee report (1955) noted
that the extensive and complex changes in the environmental conditions of
Grand Lake as a result of the project preclude restoring it to original
conditions and biological changes in populations must be accepted. At
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that time the Fish and Wildlife Service, in concurrence with the Colorado
Game and Fish Commission, stated "that the problem of excessive algae
growth in the lakes will naturally tend to correct itself when the project
is in full operation and as the initial fertility of the lakes decreases
during the next few years."
2. A lack of agency pollution studies, and no complaints,
during the period 1954 to 1966 indicate that algae did not present sub-
stantial problems during that time span. Nelson's (1971) report covered
the period 1962 to 1966; during this time he estimated primary productivity
to be only moderate in the three lakes with almost all productivity being
in the upper six (6) meters. Blue green algae, green algae, and diatoms
including Aphanizomenon and Melosira were the most common. Nelson con-
cluded that inflow from Shadow Mountain with its two sewage treatment
facilities and individual septic tank units at Grand Lake may contribute
to so-called "nuisance algae blooms" but not to the point that they are
causing the lakes to become eutrophic.
3. Nelson indicated that Lake Granby functions as a "sink" in
late June and July with inflow from Shadow Mountain Reservoir and Grand
Lake contributing to the deposition of sediment and organic materials.
Conversely, Grand Lake acts as a "sink" in the summer and fall months.
A decrease in dissolved oxygen was already noticeable in the hypolimnion,
and Nelson noted that a continued loss of oxygen at deeper levels could
result in depleted 02 levels in over 80 percent of the lake's volume,
resulting in serious effects on productivity in the lake.
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4. In 1967 a public health consultant for the National Park
Service conducted a survey of Shadow Mountain Reservoir following com-
plaints of persistent foam deposits, algae formation, turbidity, and
floating solids and sludge deposits in the lakes. Although observed
conditions were not as serious as the situation presented by the residents,
the conclusion was that there was apparent evidence of the presence of
domestic pollution of sufficient strength to create public health hazards.
5. A more thorough investigation by the Federal Water Pollution
Control Administration was completed in 1969 and published in 1970 by the
Environmental Protection Agency. At that time, domestic wastewater sources
were the Grand Lake sewage treatment plant, Shadow Mountain government
camp, and individual subsurface disposal systems. The study revealed that
all of the lakes were generally nitrogen deficient, existing water quality
was equal to or better than standards, and that most organic material was
either from photosynthesis or natural runoff and correction of the depleted
dissolved oxygen situation in Grand Lake was not readily correctable.
Evidence suggested Lake Granby was becoming a "sink" for orthophosphates
with concentrations two to thirteen times the levels 1n the other lakes
or in its upper levels. Lake Granby also had the highest organic content
and lowest dissolved oxygen and pH measurements 1n their study.
6. EPA recommendations were that natural Inflows be monitored
to detect nutriflcation loads, and that a plan be formulated to control
future development in the area to protect the water quality of the lakes.
Domestic wastewater was considered the major cause of orthophosphate and
thus the major contributor to nutriflcation pollution and the increase 1n
certain algae species.
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7. Studies by the State Health Department (May, 1969-1970)
indicated generally low dissolved oxygen levels at the surface in all
three lakes and high coliform counts by the sewage treatment plant.
No definite evidence of septic tank or direct pollution from domestic
sites was found, although 68 were less than 50 feet from the lake
shore.
8. Data from the State in 1971 generally indicated dissolved
oxygen levels above 6.5 and low coliform counts in all of the lakes.
This data was collected after upgrading of existing sewage treatment
plants and individual home units.
9. In 1972 Kugrens and Paul sen indicated that the lakes were
in reasonably good condition based on surface water quality and algae
counts. They concluded that:
a. All three lakes have relatively pure water.
b. The main vegetative problem in Shadow Mountain Lake
is a vascular plant, El odea. Its nutritional requirements are not known,
but it grows in relatively pure water habitats, not in ones that have
experienced heavy organic pollution.
c. Elodea is generally beyond the control of any chemicals
currently on the market that are not also toxic to fish. Harvesting under
conditions when the crop is exposed during lake water level reduction is
recommended.
d. Algae are not a nuisance in any of the lakes. The annual
"bloom" of algae is minor and may be essentially a natural phenomenon
caused by nutrient levels increasing temporarily during an overturn of the
lakes.
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e. The major area that can be considered polluted 1s 1n
the vicinity of the sewage plant effluent 1n Shadow Mountain Lake, ex-
tending some sixty yards Into the lake.
f. Temperature may be Instrumental 1n keying the Inter-
mittent excessive algae "blooms" that have been reported.
g. Generally, pH, DO, BOD, alkalinity, calcium, mag-
nesium, phosphate, nitrate, sulfate, and chloride levels are below those
levels at which pollution results.
h. Silica contributions, especially from the North Fork
of the Colorado River, are within the optimal range for diatom growth
and may contribute significantly to the high levels of FragilHrla and
Asterionella noted 1n several of the past studies.
1. There presently exists no need for the application
of algae eradication methods to any of the lakes.
Based on this available background data, 1t appears that the following
results may be expected with construction of a treatment system to remove
effluent from the basin:
1. The system will alleviate any contributing cultural eutro-
phication effects caused by effluent discharge, especially tlvit associated
with phosphates which may be a contributing factor to the growth of certain
common algae species such as Anabaena 1n the lakes.
2. The removal of contributed BOD material will very slightly
lessen some oxygen demand in the lakes, although much of this problem 1s
apparently of a natural origin.
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Any proposed system to remove effluent discharge from the lakes
will not solve problems associated with:
1. natural or cultural eutrophication processes, including
enrichment of the lakes from material washed into the lakes from natural
waterways or from developed properties along the lake shores;
2. the present Elodea situation and the growth of other plants,
especially in the shallow areas of Shadow Mountain Reservoir, and the col-
lection of noxious material in such rjlant growths;
3. lake pollution or degradation arising from oil or gas leaks
from motor boats. It has also been suggested that the use of such craft
in shallow areas of the lakes may serve to stir up sediments and reintroduce
settled nutrients into the lakes' systems;
4. growth and production of diatomaceous algae such as
Fragill aria and Asterionella which are dependent on the high content of
silica washed into the lakes from natural sources;
5. pollution and aesthetic problems caused by cleaning fish or
discarding unwanted fish into the lakes or around boat docks, or domestic
wastes discharged from large boats equipped with toilets into tiie lakes.
In the future, the following situations may still have to be considered:
1. The definite possibility exists that the algae growths ob-
served are the result of natural, seasonal changes in water temperatures
and overturn in the lakes serving to recycle nutrients in the system.
If this is the case, then the observed algae "blooms" are likely to con-
tinue to occur even with decreased phosphate loading from improved waste-
water management.
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2. Insufficient data 1s available to define the contribution of
natural runoff and nonpoint nutrient sources to the dissolved oxygen and
related problems observed 1n Grand Lake and Lake Granby. Detailed In-
vestigations of runoff and stream flows should be undertaken to assess
their contribution to future eutrophlcation of the lakes.
3. It appears highly probable that, even with a basin sewage
system, failure to adopt more appropriate land use controls will still
lead to some cultural eutrophicatlon of the lakes from nonpoint runoff,
sedimentation, and increased human impacts. Better protection should be
afforded the entire basin system through Improved land use control. While
Grand County is presently engaged 1n an effort to develop a new compre-
hensive plan and land use regulations, there 1s concern over possible
development that may be initiated 1n the Interim period before these are
Implemented (ref. No. 5).
It has been very difficult for the District's consultants, NHPQ, EPA,
the State, and others to be definitive about the trend of the water quality
of the lakes. A summary of the conclusions that have been drawn would
Include the statements that (1) the lakes are currently meeting State water
quality standards though there is no assurance that this situation will con-
tinue; (2) the major water quality problem is nonpoint 1n origin but point
sources, especially in view of the Town of Grand Lake's present substandard
discharge, must be controlled; and (3) that a positive water quality manage-
ment program emphasizing point and nonpoint control 1s the only safe course
of action to follow.
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Sedimentation and EPA's 1974 Water Quality Survey
In summer of 1974, EPA initiated further water quality investiga-
tions to assess the water quality status of the three lakes and the
effectiveness of the water quality management plan that had been proposed.
This water quality survey was designed to determine the existing physical,
chemical, and biological conditions in the lakes and tributaries, with
particular emphasis on determining the relative contribution of point and
nonpoint sources of nutrient inputs. The sensitivity of the lakes to
increased nutrient inputs in terms of algal productivity and eutrophica-
tion was also a major element of the study.
The 1974 water quality survey has been of particular importance
to EPA in its deliberations on the Three Lakes project for several
reasons. First, it was becoming increasingly evident before the study
was conducted that nonpoint source pollution had not been sufficiently
considered in past analysis of the lakes' water quality. This was true
even though it was becoming clear to many observers that sedimentation
was a very real physical type problem and that, in fact, Shadow Mountain
Reservoir was filling in to a degree because of this type pollutant. Second,
based on this study, EPA and others were becoming more and more aware that
any long-term water quality management plan for the lakes would have to
include some type of land use regulation (erosion control implies pre-
ventitive regulation such as not allowing construction activity on steep
slopes—nonpoint type pollutants are not receptive to treatment as are
domestic sewage wastes). The 1974 survey was thus intended to help
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clarify the impact of nonpoint pollution on the water quality of the
lakes and to help provide a basis for assessing the type of water quality
management plan needed to assure protection of the lakes.
As mentioned, numerous observers of the three lakes situation, in-
cluding the Park Service and marina owners, were aware that Shadow
Mountain Reservoir was receiving a heavy load of sediment from its west-
side tributary streams. A previous facility plan (ref. No. 5), prepared
by NHPQ for the District, contained an excellent discussion of the sedimenta-
tion problem. This discussion is reprinted in the following paragraphs.
Water, in the form of storm runoff and snow melt,
may carry particles of soil in suspension for some dis-
tances from their point of origin. As stream velocity
decreases, sediment particles tend to be deposited. The
inlet of the Colorado River Into Shadow Mountain Lake is
a place where the stream water slows as it enters a con-
stant level lake. The resultant deposition creates an
alluvial fan-shaped deposit, which is undesirable for
several reasons. Shadow Mountain Lake is quite shallow
at this end, and the accumulated sediment causes difficul-
ties in recreational boating. The quantity of silica dis-
solved in the lake water is increased by the accumulation
of silt and may contribute to algae growth, specifically
of Diatoms. Excessive siltation also decreases the geo-
logic and productive life of the lake by deposition of
materials onto the lake bed.
Areas with sufficient natural vegetation yield sedi-
ment at fairly low rates, while disturbance of the soil by
agriculture or development increases the amount of sedi-
mentation drastically. Recent studies have shown that
land in the stage of total development of the Kawanechee
Valley can be expected to yield about 300 tons of sediment
per square mile per year. Estimating a weight to volume
ratio of 150 pounds per cubic foot, one year of runoff
from the north fork drainage basin would yield 412,000 cubic
feet of silt. Each year then, approximately this quantity
of silt could be deposited in Shadow Mountain Lake, ag-
gravating the boating problem and contributing to the growth
of algae.
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Only 8.2 percent of the drainage basin is now in
private ownership. Assuming that all federal land is left
in its present stage of development, only this 8.5 square
miles of private land could be modified to increase its
sedimentation yield. However, the consequences could be
significant. A recent article states: "The removal of
vegetation, and earth moving, during construction causes
sedimentation in streams and siltation of harbors. Sedi-
mentation from heavy development can be 100,000 tons per
square mile per year as compared to 300-500 tons from a
rural area." The same article includes the following
table:
Sediment Volume - Tons/Square Mile/Year
1. Woodland 100
2. Mixed Rural Areas 300
3. Farm Land 500
4. Light Development 10,000
5. Heavy Development 100,000
Using the figure cited for light development, the 8.5 square
miles of land would yield 85,000 tons of silt per year. This
would occupy 1,133,000 cubic feet, nearly three times as much
as present conditions.
However, caution must be used in applying generalized
findings such as these to specific areas, such as the Three
Lakes region. Differences in soil types, geology, vegeta-
tion, slope, and climate all have considerable effect upon
sedimentation. Construction would increase the amount of
sedimentation and poor practices, such as development on
steep slopes, excessive grading and excessive removal of
vegetation, would cause serious erosion and consequent
sedimentation.
Estimates of sedimentation, for the total watershed
of the Three Lakes region, are shown in Table 1. It should
be pointed out that design of new developments can control
sedimentation to a very large extent, if proper criteria
are used and sound construction practices are followed. Due
to the importance of the quality of the lakes to the economic
future of the region, degradation of the water by sedimenta-
tion is of serious consequence. Therefore, it is strongly
recommended that development and construction standards be
enacted and enforced to minimize development-caused sedi-
mentation. (Ref. No. 5.)
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TABLE 1
SILTATION
Still water North & East
North Fork South Fork Creek Inlet Willow Creek Total
1. Total area,
square miles 103.0 65.3 24.5 73.7 128.0 394.5
2. Current silt
production,
cubic feet per
year' 412,000 87,067 98,000 98,267 512,000 1,207,334
3. Privately owned
land, square
miles 8.5 0.5 8.0 1.0 17.0 35
4. Percentage of
private land 8.2% 0.8% 32.6% 1.4% 13.3% 9%
5. Additional silt
from development
of private land,
cubic feet per
year2 1,099,333 64,667 1,034,667 129,333 2,198,667 4,526.667
6. Forest Service
estimates (pri-
vate land),
cubic feet 775,000 to 5,000 to 375,000 to 9,000 to 750,000 to 1,214,000 to
per year3 800,000 6,000 400,000 10,000 800,000 1,296,000
1 Sediment volume 1n tons per square mile per year = woodland -100, mixed
rural -300, light development -10,000. Estimated mass = 150 rounds per
cubic foot.
2 Estimate based on 10,000 tons/square mile/year.
3 Forest Service hydrologists feel that the 10,000 ton figure is too high for
the Three Lakes region. Their estimates assume all development has a well
designed road system with grades not exceeding 8%, necessary cross drainage,
and the slope of the average developed lot not exceeding 10 to 12%. Steep
road and lots could easily increase the sedimentation by a magnitude of
three to four times according to Forest Service estimates.
Source: NHPQ (Forest Service as noted).
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The 1974 EPA water quality survey was thus undertaken to better
define the nature of the nonpoint problem for the three lakes and also
to better devise a plan to control these pollutants. The results of
the survey can be summarized as follows (see also pages III-8 and III-9
of the facility plan for discussion on the same subject):
1. Water quality standards for numerical criteria were not
found to be violated from any of the samples taken from the lakes or
tributaries.
2. Point sources account for approximately 7% of the total
phosphorus and 2% of total nitrogen entering the lakes over a hydro-
logic cycle (it must be pointed out that during the September low-flow
period the Grand Lake treatment plant discharge accounted for a signif-
icant quantity of phosphorus and nitrogen—see page 111-8 of the
facility plan).
3. The influence of man's activities in increasing the
nutrient yield of the watersheds was very apparent. "Undisturbed"
watersheds account for nearly two-thirds of the stream flow entering
the lakes but only a small percentage of the nutrients. On the other
hand, it was found that sedimentation and associated nutrients increased
substantially from areas influenced by man's activities (no attempt was
made to allocate sediment production to particular activities; thus,
the relative contribution of grazing, road building, construction, etc.,
have not been differentiated).
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4. The lakes are currently classified as mesotrophlc. Algal
growth 1s currently limited by nitrogen 1n Grand Lake and phosphorus
and nitrogen 1n Shadow Mountain and Granby Lakes.
5. The lakes are not particularly sensitive to nutrient
Increases over the range of nutrient Increases tested (ref. No. 4).
Based on the 1974 and other surveys, EPA drew various conclusions
about the type of water quality management plan needed for the Three
Lakes area. EPA conclusions can be summarized as:
1. nonpolnt type pollution 1s a major water quality problem
for the three lakes; any plan to protect the future quality of the lakes
must Incorporate control of these pollutants;
2. point source pollution, though not of the same magnitude
as nonpolnt, must also be addressed 1n the water quality management plan;
a combination of point and nonpolnt controls is called for;
3. acceleration of land disturbance 1n the area from road
building, home construction, etc., must be carefully evaluated and should,
as far as practicable, be controlled by the level of government having
legal jurisdiction over the land area involved.
An additional EPA water quality survey conducted 1n 1975 (see page
III-9 of the facility plan), though not as comprehensive as the 1974
effort, drew similar conclusions about the water quality of the three
lakes. That 1s, nonpolnt type pollution comprises the greatest pol-
lutant load reaching the lakes with point sources contributing a smaller,
though still Important, load.
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Mater Quality of the Tributaries and of Willow Creek
As discussed, the water quality of the lakes is dependent to a
large extent on the quality of the water reaching them from their
tributary streams. Also as discussed, the quality of the lakes'
tributaries are (1) currently (1974) meeting numerical water quality
standards, (2) contributing significant amounts of sediment and nutrients
attributable to human land use activity, and (3) must be considered
in any water quality plan for the area. Additional discussion on these
subjects will be found under sections of this EIS dealing with impacts
of the various alternatives and with mitigative measures. Specifics
of the 1974 survey, such as sampling locations, pollutant quantity and
type found, etc., are contained in reference No. 4 on file with other
supporting documents.
The water quality of Willow Creek, though it does not discharge to
the lakes, must also be considered because the discharge of the District's
new preferred alternative would discharge into an irrigation ditch, which
in turn discharges into a tributary of Willow Creek (see figures III-l, VI-8,
and VI1-2 of the facility plan). A discussion of the present water quality
of Willow Creek is found on pages 111-7 and 111-8 of the facility plan.
Lower Willow Creek, that portion related to this project, contains
both brook and brown trout, though the stream is of negligible importance
as a sport fishery and is not open to general public use. Willow
Creek in this area is roughly divided in half by a series of beaver ponds
approximately 1.5 miles upstream from the confluence with the Colorado
River. These ponds act as a barrier to upstream fish movement. From the
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beaver ponds downstream the creek represents fairly productive brown
trout habitat.
Brown trout numbers drop considerably during spring and summer
due to reduced water levels and Irrigation return flows, but Increase
significantly 1n the fall. The lower portion of Willow Creek appears to
function primarily as a nursery and spawning ground and thus contributes
to the Colorado River fishery (see letter from Dames and Moore to Paul
Seeley, NHPQ, and from Colorado Division of Wildlife to Paul Seeley
1n Appendix A of the facility plan).
Basic Conclusions on Three Lakes Water Quality
To summarize, 1t 1s obvious that opinions have differed on the
actual quality of the lakes and on whether the trend of this quality 1s
downward, stable, or actually showing Improvement. As the facility plan
points out, the lakes have a complex hydrology, sampling techniques and
procedures have varied, and the Three Lakes system has been going through
changes Inherent to all man-made lakes. EPA's conclusion, based on all
these factors and the past studies, 1s that 1) numerical water quality
standards are presently being met 1n the lakes; 2) the Grand Lake treat-
ment plant discharge needs to be corrected; 3) nonpolnt type pollution 1s
the major water quality problem and Its control 1s essential; and 4) the
many uncertainties and the risks Involved with a do-nothing approach would
not be acceptable. Last, EPA believes a "sufficient" water quality control
program would be comprised of some type of centralized sewage collection
and treatment system 1n combination with nonpolnt controls.
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SECTION ft U
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V. Environmental Impact Evaluation of the Alternatives
As with any area, there are a multitude of sewage treatment types
and sewage collection system configurations that could be devised to
serve the Three Lakes Water and Sanitation District. Obviously, however,
the past experiences (of the engineering consultants, EPA, and the State)
?
with treatment plant types and use of easily comparable factors such as
cost have served to narrow the possible alternatives down to a reason-
able number. In the last phase of this project, prior to issuance of
this EIS, EPA and the District agreed that the six alternatives as pre-
sented in the facility plan, plus consideration of septic tanks and
neighborhood units, sufficiently gave representation to the various
environmental, cost, locational, etc., factors that had been of concern
throughout the long history of this project.
These alternatives are Do Nothing, Upgrade Existing Facilities,
Regional System (original District proposal), Willow Creek Lagoon, North
Shore Plant, and Stillwater Creek Lagoon. It is suggested that the reader
review the alternatives section of the facility plan (Chapter VI) before
proceeding further with the EIS. The facility plan offers specifics
(location, plant type, etc.) on each alternative.
As was stated in the beginning of this EIS under "Issues," these
alternatives were evaluated and compared on some twenty-four different
criteria in the facility plan. This EIS, however, will separately discuss
each alternative only in terms of the major issues which are: type of
point source control needed; nonpoint source control; the effects of the
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alternatives on Shadow Mountain National Recreation Area; water rights;
land development; costs; technology; phasing of the system; and septic
tanks. The facility plan covers the other evaluation criteria, though
further comments will be made on several of them in this separate EIS
document.
A special note should be made here on the source of an important
segment of data and impact analysis that EPA has used in this alternatives
evaluation. As previously noted in this EIS, Grand County, along with
the Northwest Colorado Areawide Water Quality Management Project and
financial support from EPA, hired COMARC Design Systems to do a detailed
land capability study for the Three Lakes area. EPA provided partial
funding for the COMARC effort in order to obtain a data-based assessment
of existing and potential land use/environmental factors related to
the Three Lakes sewerage project. It should also be reemphasized that
Grand County intends to use the COMARC analysis to revise its land use
plans and regulations—an undertaking that is the basis for the mitigation
of impacts associated with wastewater treatment plans for the area.
COMARC and the County have provided EPA with an analysis of sixteen
factors associated with the sewage collection system and treatment plant
sites associated with the five alternatives under consideration. (The
"Do Nothing" alternative was not analyzed by COMARC.) These sixteen
factors were land use type, soils, geology, slope, flood hazards, surface
water, wildlife, land ownership, subdivisions, jurisdictions, septic
tank limitations, construction limitations, slope stability, erosion
hazards, runoff potential, and wildfire hazards. The COMARC analysis
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was based on 400' x 400' (3.67 acres) cells or units. This level of "site-
specificity," though not as detailed as some might desire, offers a level
of detail based on actual data that is seldom available for planning
areas such as at Three Lakes. This information has been of great benefit
in this EIS analysis.
Before discussing each alternative in terms of the major issues,
three basic assumptions underlying a_ll_ alternatives must be explained.
These three assumptions deal with population forecasts, Grand County
land use control, and the NRA.
First, population forecasts are one of the most difficult aspects
of wastewater system planning. In an area like Three Lakes, such un-
predictable factors as general economic conditions, transportation cost,
a possible ski area, people's preferences for vacation and second home
sites, etc., are all variables that would have to be considered as
having an influence on the future population of the area. Obviously,
these factors make population estimates speculative. For that reason, the
population projections presented in the facility plan, based on historical
trends, have been deemed reasonable by EPA and the County. The Northwest
Colorado Areawide Water Quality Planning Project uses the same figures
as the County. The size of the treatment facilities presented in the
facility plan appears reasonable and is that used in this EIS analysis.
Second, because there will undoubtedly be some amount of land
development due to the provision of sewerage service, the County's willing-
ness to control nonpoint pollution is essential to any alternative, in-
cluding "Do Nothing." The commitment made by Grand County, which will
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be required by EPA before construction funds are granted, to strengthen
its land use regulations thus is a basic assumption underlying the project.
Third, because of the realization of the importance of the NRA to
the future of the lakes, EPA has assumed that the County and the National
Park Service can mutually agree upon a plan for implementing a management
scheme for the area. Current negotiations between the County and Park
Service give every indication that this is a safe assumption.
The importance of this assumption is that EPA will not approve
permanent sewer service to "Neighborhood L" (page VI-43 of the facility
plan) until the County and Park Service can agree whether this area, or a
substantial part of it, is to be marked for purchase and inclusion in the
NRA. This area is a prime candidate for this type of action, and EPA
believes that it is proper not to sewer the area in lieu of a NRA decision.
The alternatives evaluation based on the major issues is as follows:
1. Point Source Pollution
Before discussing each alternative in relation to the point
source issue, several basic points need to be made. First, all parties
basically agree that the present Grand Lake plant, which is currently dis-
charging a substandard effluent, should be abandoned. Specifics on this
subject are offered on page V-10 of the facility plan. Obviously, the
fact that this present plant represents a water quality problem, the mag-
nitude of which will surely increase, and the fact that its discharge is
not meeting legal requirements (discharge permit is being violated) negate
the "No Action" alternative.
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Second, in terms of the Park Service facility, it should be
pointed out that the Park Service has been committed to its abandonment
whenever another system becomes available. The assumption here is that
equitable service charge and capital improvement fees can be negotiated
between the District and the Park Service.
Third, though the actual contribution of point source discharges
to degradation of the lakes is not now specifically quantified, sufficient
evidence and the past experiences of NHPQ, EPA, and the State lead to the
conclusion that the future of the lakes would be much more secure were
this effluent not discharged directly to them. The need to discharge ef-
fluent in some potentially less degrading manner becomes more important
when one considers the fact that the quantity of this discharge will surely
grow as the area population increases and that sewage treatment plants
invariably are subject to operational problems and mistakes.
Fourth, the question of the extent of a centralized sewage col-
lection system needs to be addressed. A most difficult aspect of this
question is that an extensive collection system will bring a larger quantity
of sewage to a central point. This sewage is now dispersed in a much
broader area via treatment (assuming the system works) by septic tank/
leach fields. At the same time, it has to be recognized that septic tanks
are currently a problem and that the whole area is generally unsuited for
their use. The heavily and more densely built-up areas are particularly
worrisome in this regard. In attempting to balance the first aspect against
the second, EPA has concluded that concentrating and properly treating area
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sewage (especially if no discharge to the lakes is involved) is preferable
to continued and probably accelerating use of septic tanks.
Thus, in terms of which specific areas should be included in a
centralized collection system, EPA believes the built-up areas identified
in the facility plan as D, C, B, A, F, G, H, I, 0, and K (page VI-43 of
the facility plan) should be given priority for service. Areas E, M, and
L are probably less of a priority in this regard, though EPA defers to the
Board of Directors, the County, and Park Service on policy for service
area priority and will participate in funding of sewerage service to these
areas to the extent regulations allow. Area L, however, should not be
sewered until the NRA issue can be resolved.
Another important factor that must be considered for all alter-
natives that include discharge of sewage effluent to the lakes is the
possibility that advanced waste treatment might have to be added in the
future. Water quality data available at this time does not support a
treatment level beyond the secondary stage. However, with the compilation
of more data based on more refined and extensive study, coupled with
population growth and development in the area, there is a very good chance
that a future conclusion would be that some type of advanced treatment
is needed. Costs for the alternatives presented in the facility plan are
not based on the addition of advanced treatment.
NHPQ furnished EPA with an estimate of the cost of advanced
waste treatment for the Upgrade Existing Facilities alternate and the North
Shore Plant alternate for use in this EIS. These calculations show
the following:
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Cost of Tertiary Treatment
Upgraded 0.5 MGD 1.3 MGD
Unit Process Grand Lake Plant North Shore Plant
Ammonia Removal
(Capital Cost) $110,000 $200,000
(0AM) 17,500 36,000
Phosphorus Removal
(Capital Cost) $161,000 $293,000
(O&M) 16,000 29,500
Multi Media Filtration
(Capital Cost) $289,000 $526,000
(O&M) 18,800 34,800
Activated Carbon
and Regeneration
(Capital Cost) $1,095,000 $1,990,000
(O&M) 17,500 32.400
Total Capital Cost $1,653,000 $3,009,000
Total O&M $71,800 $132,700
Though there is no way at present to calculate whether all or
part of these advanced treatment components might be necessary, it is a
very real possibility that they might be. This consideration has played
a role in EPA's and the District's selection of a preference for the
Willow Creek Lagoon alternative, which avoids the need for advanced treat-
ment because this alternate actually has an advanced treatment component
already included, i.e., secondary treated effluent will be used for hay
irrigation.
Given the above considerations, EPA has concluded that:
a. The Do Nothing alternative is unacceptable because it
allows substandard sewage effluent to continue to enter the lakes. This
situation will lead to water quality degradation.
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b. The Upgrade Existing Facilities alternate would require
a new treatment facility at Grand Lake which could take 1n more sewage
from presently unsewered areas around the Town of Grand Lake. The Park
Service facility, if it were to serve more area than at present, would
probably also be inadequate and have to be further expanded or replaced.
With one new plant and another new or greatly Improved plant there would
be two discharges to the lakes, the impact of which, though not quantified
at present, would have much more potential to degrade the lakes than a
no-discharge system. Also, these discharges would be subject to opera-
tional problems and plant breakdowns.
Were this alternative the one constructed it would be
logical to expand the collection system to take in the more densely developed
areas in the general area around each of the two plants. If this is done
the costs of this alternative would soon be comparable, or exceed, those
of the alternatives based on a one plant concept.
c. The Regional System and the Willow Creek Lagoon alter-
natives both have definite water quality advantages over the other alterna-
tives that discharge to the lakes. By discharging below Lake Granby, both
avoid the potential problems associated with discharging large amounts of
treated effluent to the lakes. Because they each include a type of advanced
waste treatment (land irrigation for Willow Creek and percolation ponds
for the Regional System), both will avoid possible future costs associated
with advanced waste treatment additions.
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Both the Willow Creek Lagoon and the Regional System alter-
natives would serve the more heavily developed areas in the District
which are now using septic tanks. The Willow Creek Lagoon, shown in the
facility plan as serving neighborhood area "L," would not serve this area
if the NRA decision is to purchase private lands located there.
Another distinct advantage of the Willow Creek Lagoon
system (also the Stillwater Creek Lagoon) is that aerated lagoons are
generally less prone to malfunction and operational error as are more
"mechanical" type treatment plants. Also important to these considerations
is that, for an area like Three Lakes where the bulk of sewage loads come
during a short time period, i.e., the peak summer tourist season of
approximately eight weeks, lagoons can more easily absorb and "level out"
these peak loadings.
d. The Stillwater Creek Lagoon alternative includes all
the same positive factors in terms of point source control as does the
Willow Creek Lagoon system (serves areas of concentrated development, uses
aerated lagoons) but has the negative feature of discharging to Stillwater
Creek, which in turn flows into Lake Granby. It should also be pointed
out that Stillwater Creek is a trout fishery and that this resource could
be negatively impacted by a sewage effluent discharge.
Though addition of land treatment in the future could be
part of this alternative, the lagoon site is not such that it could
easily discharge to the main irrigation ditch in the area, i.e., Red Top
Valley Ditch. Also, present water quality data is not sufficient to re-
quire this measure. The Willow Creek Lagoon, on the other hand, will in-
clude land treatment as an additional benefit because the lagoons are
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located at a site where their discharge will go Into the Red Top Valley
Ditch. The water 1n this segment of the ditch (the lower end) is used
to irrigate a large area of hay meadows. Thus, between the two lagoon
system alternatives, the Willow Creek system has a "built-in" advanced
waste treatment component and does not discharge directly into a trout
fishery.
2. Nonpoint Pollution
As discussed, the potential for a sewage collection system to
allow increased land development and thus accelerated soil erosion has
been one of the most serious objections EPA and others have had with the
District's plans for an expanded collection system in the Three Lakes
area. Nonpoint pollution has been identified as the major threat to
maintenance of the lakes' water quality. Again, the solution to non-
point water pollution is prevention and not treatment. Prevention of
nonpoint pollution, by its nature, involves some type of land use standards
for construction, setbacks, slope restrictions, etc.
Because nonpoint control is based on land use regulation, the
governmental entities with authority to control land uses must be involved.
Thus, Grand County, for private and nonincorporated areas, and the National
Park Service and U.S. Forest Service (also some BLM and BuRec), for federal
lands, are very much a part of a water quality management scheme for the
Three Lakes area.
The U.S. Forest Service is currently preparing a unit plan/EIS
for the Three Lakes region under its jurisdiction. They, like all federal
agencies, are required to meet water quality standards in their programs.
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The Park Service is subject to the same requirements. Both agencies operate
under performance.standards that fully take into consideration nonpoint
water quality pollution control, and both can be expected to meet these
standards.
Grand County (as do the federal land management agencies) does
not have the same extensive background in land and environmental planning.
To the County's credit, however, the County Commissioners and their
planning/management staff are making great strides toward placing County
land use policy on a data-based and up-to-date basis that fully recognizes
local government responsibility to control water quality impacts from land
uses under its jurisdiction. The previously referenced work by Colorado
State University, by Dr. Lynch and COMARC, and by the Three Lakes Planning
Commission under County direction represents a much greater land planning
effort than that conducted by many other Colorado mountain area counties.
The Grand County Commissioners are committed to a definite
course of action to control nonpoint pollution. The nature of this commit-
ment can be found by reading the letters on this subject found in Appendix
A of the facility plan. In EPA's opinion these actions by the County will
significantly assist the control of nonpoint pollution in the Three Lakes
area. The exact amount of this control cannot be quantified, but the
cumulative experience of those involved in this type of pollution control
on EPA's staff, and of other agencies involved, leads to the conclusion that
effective control can be realized.
EPA requested that COMARC evaluate the erosion potential of
each neighborhood area that would be served by the various alternatives
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and also to evaluate the erosion potential associated with development
along the interceptor (main collection line) associated with the Stillwater
Creek, Willow Creek, and North Shore Plant alternatives. The results of
this analysis are summarized by COMARC under the "erosion hazard" category
of land constraints and are as follows:
Neighborhood
A
D
F
G
H
I
J
K
L
M
Erosion Hazard
Not applicable - this area has
few remaining lots - no new con-
struction is anticipated
37 1/2% low hazard
62 1/2% medium hazard
73.3% low hazard
26.7% medium hazard
100.0% low hazard
100.0% low hazard
96.8% low hazard
3.2% medium hazard
100.0% low hazard
100.0% low hazard
100.0% low hazard
100.0% low hazard
83.3% low hazard
16.7% medium hazard
100.0% low hazard
Interceptor Line
*Area "E" is not in the COMARC study area.
94.2% low hazard
3.3% medium hazard
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Due to the level of detail of the COMARC analysis system, i.e.,
400' x 400' cells, to the fact that the use of geometric cells leaves a
certain amount of land area out of the analysis, and to the fact that it
is difficult to quantify exactly the difference between "low hazard" and
"medium hazard" (i.e., a low hazard area that is poorly managed can still
add a large quantity of sediment to receiving streams), the above calcula-
tions must be viewed as approximations of potential impacts. They do,
however, offer a picture of the general nature of the erosion hazard
associated with development of these areas.
Also, it should be noted that it is not possible at this time to
calculate the relative impact of various additional loads of sediment to
the lakes. Thus, EPA believes that strict control of all potential
sediment sources is necessary if management of the lakes is to err on the
"safe side."
It is very difficult to assess the differences between the
various alternatives as to how each may lead to accelerated nonpoint pol-
lution (assuming no controls are instigated). In general, EPA believes
that provision of a central sewer system will lead to a certain level of
development that would not take place without the sewer. There is no
doubt, in view of a record of fairly constant rates of development and of
a general demand for second homes, resorts, etc., that septic tank limita-
tions have led to a "brake" on some development.
On the other hand, it can be argued that a present lack of a
central sewer system has led, and will continue to lead, to more dispersed
growth (to meet County requirements of a two-acre lot size for septic tank
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use) and, as a result, to extra miles of road crossing more hazardous
areas. Proponents of this line of reasoning argue that the central col-
lection system as designed will concentrate growth into certain suitable
areas that have been shown to be less erosion prone by the County land
use planning process.
EPA's position is that both arguments have merit and that the
latter, i.e., concentration of growth along the sewage collection system,
coupled with the erosion control performance standards agreed to by the
County, is an acceptable conclusion. County land use control thus is the
key to nonpoint pollution prevention for the Three Lakes area.
Based on the above reasoning, EPA concludes that the Willow Creek
Lagoon, Stillwater Creek Lagoon, North Shore Plant, Regional System alter-
native, and the Upgrade Existing Facilities alternative (assuming this
last one also includes extension of the collection systems) would have
similar nonpoint impacts. EPA also concludes that these impacts can be
controlled to an adequate degree.
The Do Nothing alternative and the Upgrade Existing Facilities
alternative, if no collection line expansion is involved, would lead to
less erosion potential but would probably lead to more dispersed develop-
ment and thus possibly more erosion as a result of extra road mileage.
The exact amount of erosion from these alternatives, as with the others,
cannot be quantified because of the many unknowns involved. The nonpoint
impact of all alternatives must be mitigated by land use controls.
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3. The Shadow Mountain National Recreation Area
The .impact of a central sewage collection and treatment system
could actually impact the NRA in both positive and negative ways. On the
positive side, such a system could improve the general land use situation
in the area by helping to concentrate development in suitable areas. Also,
a system improving point source problems would obviously benefit the NRA
by helping to maintain a high level of water quality. On the negative side,
uncontrolled growth and development associated with the sewerage system,
especially as related to nonpoint controls and to developments located
at scenic viewpoints, etc., could also occur.
In terms of the alternatives, the Park Service has not indicated
any objection to the basic collection system common to the Willow Creek,
Stillwater Creek, and North Shore Plant alternatives. At the same time,
the Park Service has indicated a preference for a system that does not dis-
charge to the lakes (see Park Service memo of March 11, 1977. in Appendix
A of the facility plan). There is a strong indication, however, based on
the previous EIS written on the NRA and ongoing discussions, that the
extension of a sewer line south to neighborhood "L" could interfere with
plans to add much of that area to the NRA.
Thus, EPA concludes that:
a. The Do Nothing, Upgrade Present Facilities, Stillwater
Lagoon, and North Shore Plant alternatives do not meet NRA water quality
goals as well as the two alternatives that do not discharge to the lakes.
b. The Regional System, though nondischarging, would sewer
areas that may be added to the NRA.
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c. The Willow Creek Lagoon alternative, minus service to
area "L" until the NRA can be finalized, avoids these other objections.
d. The County's willingness to control nonpoint pollution
mitigates the issue of growth associated with the sewer lines.
4. Water Rights
As discussed, the U.S. Bureau of Reclamation and the Northern
Colorado Water Conservancy District have been part of the negotiations
on the Three Lakes project. Though the alternatives that return treated
effluent to the lakes would create no water rights problems, the two
alternatives discharging below Lake Granby, Willow Creek Lagoon and the
Regional System, are a different situation because this water would be
lost to Colorado-Big Thompson storage.
The Bureau of Reclamation and Northern Conservancy District
have Indicated, however, that the water rights issue Involving these latter
two alternatives can be resolved. EPA thus believes the water rights issue
is one that has been resolved for all alternatives. EPA will expect a
final agreement on these matters before proceeding to the Step 2 phase of
a Three Lakes sewerage project. (Step 2 1s the design phase.)
5. Land Development
The nonpoint pollution issue as related to land development
associated with provision of sewer lines has already been discussed. The
issue under this section is whether the collection line is actually needed
or is basically "speculative" In nature. Before beginning the discussion,
it should be pointed out that the same unknowns about potential growth rates,
build-out rates, location of development, etc., apply equally to this issue.
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EPA believes that the major presently developed areas now on
septic tanks present a water quality problem. Every indication is that
the majority of these areas are unsuitable for septic tank use and that
there have been considerable problems with such systems. Additional
discussion on this subject is found on page VI-7 of the facility plan
and shows that there are 4,632 population equivalents in these service
areas at present (figure excludes areas E, L, and M).
There are a large quantity of undeveloped lots in these same
areas. COMARC provided EPA with a listing of the approved subdivisions
in these areas, plus those along the interceptor line not included in
neighborhood units. This information was compared with County data on the
number of the subdivision lots that have been developed to give the fol-
lowing estimate of lots that could possibly be developed:
Neighborhood Undeveloped Lots
A 53
B 6
C 21
D 130
F 52
G 245
H 144
I 13
J 144
K 297
L 187
M 42
Interceptor Line 584
(common to Willow
Creek, Stillwater,
and North Shore -
Plant alternatives)
Total 1,918
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The reader should not get the Impression that there are 1,918
lots that will immediately be developed as soon as sewer lines are available.
Many of these lots are very small and were platted many years ago. A
number are not attractive for building, as the light build-out rate on
them would indicate, and many would probably be consolidated into larger
parcels as has been a common practice in the area. Other factors such as
general economic conditions, people's preferences for the Three Lakes area,
possible ski area development, etc., are unknowns that will also have sig-
nificant effects on the area build-out rates.
At the same time, the fact that these large number of lots do
exist is a worrisome situation. Perhaps the same situation is common to
many other areas as well. One thing that should be pointed out is that
many of these lots are in areas the County has indicated are acceptable
growth nodules or centers (the area northwest of Grand Lake and the area
between Shadow Mountain Lake and Lake Granby) and most are in subdivisions
that already contain numerous homes.
Though the existence of the 1900+ lots is one of the most per-
plexing issues surrounding the Three Lakes project, EPA has concluded
that (1) the existing unsewered development is at such a density in much
of the area that sewering is justified and (2) that Grand County's updated
land planning and proposed regulations will mitigate developmental impacts
to an acceptable level. That the sewer system will concentrate and channel
growth, thus tending to limit dispersed and random development, 1s also a
positive factor in favor of the collection system.
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6. Cost of Sewerage System
The costs of the various alternatives are fully explained in
the facility plan (page VI-34 of facility plan). As can be seen, the bulk
of these costs (except for the Upgrade Existing Systems alternate) are for
the collection system. The State of Colorado, acting through the Water
Pollution Control Commission, sets spending priorities for the federal
funds involved in construction of wastewater systems. Most important to
this project, the Commission has a policy of only funding treatment plants
and main interceptor lines. With this being the case, the Three Lakes
Water and Sanitation District would have to bear the bulk of the cost of
the various alternative systems (see cost breakdowns for each alternative
under Figures VI-2 through VI-10 of the facility plan). It should also be
pointed out that the Commission has the flexibility to waive this policy
and could fund the collection lines.
The impact of this requirement for a very large District share
of the cost for the collection systems of the alternatives is that to
build all alternatives, except Upgrade Existing Facilities, the District
must find a major source of outside funding. If this funding is not
available (the District is pursuing several sources) and if the District
maintains its policy of either serving a substantial number of the people
within its borders or serving none at all, then an outcome could be that
no system is constructed.
Another cost factor to be considered is the burden of the local
share on individuals owning property in the District. The figures found
on pages VII-11 through VI1-13 of the facility plan show the cost per unit
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to be $6.60, $4.20, and $1.60 per month, figured on the addition of 20,
40, and 80 new taps a year respectively. (These figures assume the
availability of a large outside funding source for the collection lines—
the local share is some $1,300,000 already authorized by a local bond
election.) These service charges do not appear unreasonable, especially
when one considers the inevitable cost of septic tank/leach field mainte-
nance and the increased value of property the addition of a sewer will
probably bring.
If the outside funding for the sewers 1s not found, however,
these calculations are not valid. If this occurs, then the District could
attempt to gain voter approval for more bond authorization, scale the
collection system down, or both. These factors are unknowns and can't
be predicted at present but are possible obstacles to completion of a
Three Lakes sewerage system.
7. Technological Aspects
There have been three issues associated with the technological
or type of "hardware" related to the sewage collection and treatment
alternatives at, Three Lakes. These issues are (1) use of vacuum lines
as part of the lake shore collection system; (2) type of treatment plant
best suited for the area; and (3) whether advanced waste treatment (AWT)
is needed for the plant that is installed.
First, EPA has concluded that the vacuum lines have too many
unknowns associated with their use and maintenance and have the potential
to cause unnecessary problems and possibly cause pollution of the lakes.
An alternate method of sewage collection using grinder pumps and conventional
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"1n-the-ground" sewer line 1s described in the facility plan and is the
one EPA prefers.
Second, EPA believes that the best choice for treatment plant
type for the Three Lakes area is an aerated sewage lagoon as described
in the facility plan under the "preferred" Willow Creek Lagoon alternate
and also under the Stillwater Creek Lagoon system. Lagoons offer the
advantages of greater simplicity of operation, ability to handle peak
period loadings as are characteristic of the Three Lakes area, lower
operation and maintenance costs, and the ability to produce an acceptable
effluent. It should be pointed out that the Regional System alternative,
while not "preferred" because of land use, NRA, and cost impacts, would
also have these same advantages as described for the lagoons.
The alternatives based on plant types of a more "mechanical"
nature (a bio-surf system is the type described in the facility plan) are,
in contrast, generally more complicated to operate, more subject to mal-
function and operator error, less able to handle peak loadings (without
sewage storage of some kind), and more costly to operate. In an area like
Three Lakes these are all very important considerations which have led
to a favoring of the lagoon system.
Third, the issue of AWT must be addressed. As mentioned elsewhere
in this EIS, present water quality data does not support the need for ad-
vanced waste treatment. Though the District, EPA, the State, and the Park
Service have all indicated a preference for having effluent not enter the
lakes, if possible, there is no data to require other than secondary level
treatment with lake discharge.
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The problems with this situation are several. First, as this
EIS points out, the available water quality data for the lakes is not
complete, is somewhat contradictory, and is drawn from a complex and changing
hydrologic system. EPA water quality analysts have concluded that in view
of this situation it would be best to have the effluent exit the basin.
Also, no assurance can be offered the District that AWT may
be required in the future. In fact, with increased human populations in
the area, there could be a very real possibility that AWT would be a
future requirement. The possibility for future additions of AWT would
apply to all treatment alternatives except the Willow Creek Lagoon and the
Regional System. Under both of these systems, a form of AWT is already
included, i.e., the Willow Creek Lagoon effluent would be used for crop
irrigation and the Regional System uses percolation/evaporation basins.
This additional benefit of the Willow Creek Lagoon alternative has been an
important factor in EPA's, and others', selection of this system as "pre-
ferred." All the other alternatives, except the Regional System, would
require expensive retrofitting of AWT components.
8. Phasing
EPA's position on sewering Neighborhood Area "L" has already
been discussed under the section on the National Recreation Area. This
position is that EPA will not approve a sewer line extension or a separate
neighborhood treatment plant for this area until the NRA is finalized. At
present, there is every indication that Grand County and the Park Service
are moving expeditiously on this issue and that a NRA plan should be agreed
upon soon.
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The other "phasing" issue concerns the already discussed matter
of the District having enough funding for the 25% local share of the project.
If the Willow Creek Lagoon alternative is given final approval following
completion of this EIS process, then the District is still some $2 million
short of having sufficient funds for construction. As explained, the major
expense is for the collection lines which the State Water Pollution Control
Commission has, in the past, chosen not to fund. Also, as mentioned
and as discussed in the facility plan, the Board of Directors of the Water
and Sanitation District have stated that if they don't get the additional
funds to construct the collection system they will petition the State
Legislature to dissolve the District.
The results of not getting the additional money, though this
is speculative, would be that the Three Lakes District could go out of
existence and the burden of providing sewage service would fall to the
four smaller sanitation districts located within the Three Lakes District's
boundaries. If this were to occur, the benefits of the centralized system
would be lost and there would be a great loss of time and effort with a
resultant negative impact on a process that has gone very far towards
developing an integrated water quality planning and control arrangement
which is somewhat unique to the State of Colorado.
Because funds to make up the District's shortfall are not assured,
EPA has urged, and will continue to urge, the Board of Directors of the
District to be somewhat flexible in terms of possible phasing of the
selected system. In terms of the Willow Creek Lagoon alternative, for in-
stance, a considerable initial savings could be realized by not building
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the proposed neighborhood treatment units and by eliminating segments of
the collection system. Though this action would require a much closer
evaluation (the financial arrangements would have to be refigured because
of fewer service fees being generated), it could mean the difference
between construction of a needed system and the construction of no system.
Though EPA has found the environmental impacts of all components of the
"preferred" Willow Creek Lagoon to be acceptable, the funding situation
leads EPA to encourage the District to be flexible in the possible phasing
of its construction.
9. Septic Tanks
As discussed in the facility plan (page VI-23), the District is
not interested in being involved in an extensive program of septic tank
management for the area. It has been suggested that a septic tank manage-
ment program, with the District actually involved in the construction and
maintenance of individual septic tank/leach field systems, could be a
treatment alternative used in lieu of a centralized sewage collection and
treatment system.
Though such a management system has certain benefits associated
with it (cost, for example), EPA has concluded that the Three Lakes area
is generally unsuitable for widespread septic tank use. Grand County has
repeatedly told EPA about septic tank problems in that region and is
adamantly opposed to any large scale septic tank program. COMARC also
performed a "septic tank limitation" analysis with the following results:
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Neighborhood Septic Tank Limitation
A no data
B 100% severe
C 100% severe
D 100% severe
F 100% severe
G 100% severe
H 100% severe
I 100% severe
J 100% severe
K 100% severe
L 100% severe
M 100% severe
Interceptor 97.5% severe
(Willow Creek Lagoon) 2.5% no data
EPA will be the first to admit that the scale (4001 x 400' cells)
of the COMARC analysis is such that there are undoubtedly areas where septic
tank use is quite acceptable. Obviously, many septic tanks are functioning
properly at present. The above analysis, however, coupled with Grand
County's communications on septic tank failures, leads EPA to conclude
that widespread use of this type of system will probably lead to increasing
water quality problems.
The various alternatives vary in their relationship to numbers
of septic tanks that would be in use. No Action would obviously continue
present, and undoubtedly increased future, dependence on these systems.
The Regional System, on the other hand, would eliminate the greatest num-
bers of their use. The other alternatives would provide for more of a
mix between sewered homes and those on septic systems. It should be again
pointed out that the centralized collection system, by concentrating growth
in a specific area, tends to help control more random and dispersed growth
that would rely on septic systems.
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10. Other Environmental Considerations
Several other aspects of the Three Lakes project need to be
briefly discussed here. These Include:
a. Archaeological resources - EPA funded a ground survey
of archaeological and historical resources. A report on the findings
of this work has been furnished the State Archaeologist, National Park
Service, U.S. Bureau of Reclamation, and U.S. Bureau of Land Management.
Any grant for actual construction of a sewerage system will be conditioned
to assure protection of these type of resources.
Two prehistoric sites were located, at a "neighborhood"
area and at one of the lagoon sites. A lagoon site also contained one
isolated prehistoric item and one small concentration of prehistoric
debris. Grant conditions will require test excavation of the neighbor-
hood site before construction and professional monitoring of construction
at the lagoon site.
b. Relationship of the Three Lakes Water and Sanitation
District to other water and sanitation districts within its boundaries
and with the National Park Service - A Three Lakes centralized sewerage
system would take in four other existing sanitation districts and National
Park facilities. Though no final agreements have been worked out between
these parties and the Three Lakes District for acquisition of existing
facilities, service charges, etc., EPA assumes that any difficulties that
might arise can be solved. Any final EPA grant for construction of
facilities would require that these matters be resolved.
106
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ISECTION ui
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VI. The Preferred Alternative
EPA, the District, State, National Park Service, Bureau of Reclamation,
Grand County, and others have worked long and hard to resolve the complex
issues involving water quality protection and provision of improved sewerage
service for the Three Lakes area. This EIS is only the "tip of the iceberg"
of the work that has gone into this project.
As stated, the EPA Regional Administrator has selected the Willow
Creek Lagoon alternative as a "preferred" system. The other agencies in-
volved have also agreed that this is the preferred system. The reasons
for this selection are:
1. The Willow Creek Lagoon alternative would provide service
to the major areas of concentrated development in the area. These areas
are ones of concentrated septic tank use.
2. Grand County will control nonpoint pollution arising from
land development. Though development will surely tend to concentrate along
the sewer line system, this concentration is compatible with County growth
plans and, in fact, assists the County by helping channel growth to suitable
areas.
3. The Willow Creek lagoon discharges out of the Three Lakes
basin. Though neither EPA or the State can quantify the impact of discharge
to the lakes, everyone agrees that it would be preferable to not discharge
to them if possible. This system thus offers definite point source-related
water quality benefits.
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4. The Willow Creek Lagoon system offers advanced waste treat-
ment via use of effluent (summer during peak loads) on hay meadows. AWT
may well have to be added to the other alternatives at a future date at
considerable extra expense.
5. The Willow Creek alternative uses aerated lagoons. Lagoons
offer the advantages of operational simplicity, less O&M cost, and the
ability to handle peak loads such as those that occur at Three Lakes.
6. The Willow Creek Lagoon would be located in an unobtrusive
area away from the sensitive shoreline areas of the lakes.
7. The Willow Creek Lagoon collection system, pending resolution
of the neighborhood "L" negotiations, is compatible with Park Service plans
for the NRA.
8. The water rights issue has been resolved.
9. The Willow Creek Lagoon alternative has the possibility of
being "phased" if the District's additional funding requirements are not
found.
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SECTION Vll
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VII. Irreversible and Irretrievable Commitment of Resources
Several commitments of resources have been identified with the im-
plementation of a wastewater treatment facilities plan for the Three
Lakes area. The extent of this commitment varies among the alternatives
considered. These commitments are necessary elements of the wastewater
treatment systems but must, however, be viewed in relation to the various
mitigative measures associated with them. These resource commitments
are (1) commitment of energy and economic resources and (2) commitment
of land areas to permanent sewage treatment facilities.
EPA does not believe that the treatment alternatives further commit
any land areas to future use for housing and/or commercial development.
The areas to be served have already been committed to these uses by the
local land use control authorities, and no changes, with the possible
exception of certain southwest shore of Lake Granby areas, are anticipated.
EPA, as stated in this EIS, will not approve sewer facilities for this
area until the NRA issue can be resolved between the Park Service and
Grand County. It should also be pointed out that Grand County favors the
"preferred" Willow Creek Lagoon alternative because it is compatible with
its land use plans.
The major mitigative measure related to all alternatives is Grand
County's commitment to control nonpoint pollution from developmental
activities that may be related to provision of a sewage collection system
in the area. This commitment is key to EPA's selection of the "preferred"
alternative and is key to the long-term protection of the water quality
of the lakes.
109
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In terms of commitment of land and associated resources (wildlife,
etc.) to sewage treatment facilities, the Do Nothing alternative would
have no impact. The Upgrade Existing Systems alternative would also
have no impact unless in the future additional lagoon area was needed
at the Park Service facility. In that case additional land area, pos-
sibly of the environmentally sensitive lake shore area type, might be
required. The Regional System would require the use of 28 acres of
land below Lake Granby. This plant site is highly visible and would
comprise some intrusion on visual resources.
The North Shore Plant alternative would require use of approximately
3.7 acres of federal land on the north shore of Lake Granby. Though
the area is already heavily impacted by the presence of Colorado-Big
Thompson pumping facilities, a sewage treatment plant would be very ob-
trusive and probably considered as an aesthetic detriment by many.
The Willow Creek Lagoon alternative would require the commitment
of 33.1 acres of lands presently used for livestock range (all but ap-
proximately 10 acres is federal BLM land). COMARC (ref. No. 3) analyzed
this site and found no significant impact on wildlife resources, though
there would be a loss of small game residing in the area and a loss of
a small area of big game habitat, principally deer winter range. The area
is located away from areas of heavy travel and visitation, however.
The Stillwater Creek Lagoon alternative would require the commitment
of 29 acres of private land now used for irrigated hay. These 29 acres
would also comprise that amount of loss of general deer winter range.
110
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Unlike the Willow Creek Lagoon site, lagoons under this alternative would
be 1n open land and much more visible to the general public.
Though none of the alternatives are large users of energy, there
are relative differences (see page VI-36 of facility plan). The Do
Nothing and Upgrade Existing Systems alternatives are low energy users,
while the two alternatives using lagoons and the Regional System use
moderate amounts. The North Shore Plant, on the other hand, uses a
high amount of energy relative to the other alternatives and thus would
require much higher operating expenditures by the District.
The economic commitments of each alternative are discussed under
Tables VI-4 and VI-5 and under Figures VI-5 through VI-10 of the facility
plan. While there are large calculable differences in cost between
treatment, collection, and O&M components of each alternative, it should
be pointed out that the probable negative water quality Impacts of the
Do Nothing alternative and the possible Impacts of the alternatives dis-
charging to the lakes cannot be quantified in terms of dollars.
Ill
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"^
SECTION
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VIII. Relationship Between Short-term Uses of the Environment and
the Maintenance and Enhancement of Long-term Productivity
Wastewater generation and the necessary management and disposal of
wastewater is a long-term fact of life. The proper management of this
wastewater in the Three Lakes area and the subsequent water quality
benefits constitute the basic maintenance and enhancement of long-term
productivity associated with this sewerage project. This long-term
productivity is viewed as maintaining a high level of water quality
in the lakes and as assuring the compatibility of the sewerage system
with the National Recreation Area and County long-range land use plans.
None of the alternatives considered here can be considered a strictly
short-term use of the environment with the exception of Do Nothing.
Do Nothing can only be a short-term situation because the present Grand
Lake treatment plant discharge is in violation of its Federal Discharge
Permit and thus will not be allowed to continue. The other alternatives
reinforce the use of the land areas to be served as sites for housing
development and other development.
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SECTION IX
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IX j
References
1. Nelson, Haley, Patterson, and Quirk, "Three Lakes Regional Plan-
ning Study," Greeley, Colorado, 1973.
2. Grand County Department of Development, "Data On Three Lakes
Area Land Use and Subdivisions," Hot Sulphur Springs.
3. COMARC Design Systems, "The Three Lakes Prototype Study Area,"
San Francisco, California, May, 1977.
4. National Park Service, U.S. Department of Interior, "Master Plan For
Shadow Mountain National Recreation Area," Denver, Colorado, May,
1975.
5. U.S. Environmental Protection Agency, "Draft Water Quality Analysis --
Grand Lake, Shadow Mountain Lake, Lake Granby, Colorado," Denver,
Colorado, January, 1975.
6. Nelson, Haley, Patterson, and Quirk, "Final Environmental Assessment
Three Lakes Water and Sanitation District Master Plan," Greeley,
Colorado, February, 1975.
7. Rocky Mountain Center on Environment, "Environmental Assessment
Wastewater Treatment Facilities Plan Three Lakes Water and Sanita-
tion District," Denver, Colorado, May, 1977.
8. White and Burke, "Review And Analysis of Grand County, Colorado,
Land Use Laws Related to WAter Quality Protection," Denver, Colorado,
January, 1977.
9. U.S. Environmental Protection Agency, "Staff Position On Three
Lakes Project," Denver, Colorado, August, 1975.
10. Letters of Comment from various agencies and groups on "Final Environ-
mental Assessment Three Lakes Water And Sanitation District Master
Plan," 1975.
11. Grand County Department of Development, "Three Lakes Plan," Hot
Sulphur Springs, Colorado, July, 1977.
115
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Colorado Division of Planning *^SB'
Philip H. Schmuck, Director TarS
Richard D. Lamm, Governor
November 14, 1977
Mr. Alan Merson, Regional Administrator
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
SUBJECT: Draft Environmental Impact Statement
Three Lakes Wastewater Treatment Facilities
Dear Mr. Merson:
The Colorado Division of Planning has reviewed both the facility plan and the
draft environmental impact statement (DEIS) for the proposed Three Lakes Waste-
water Treatment Facilities. We share EPA's belief that a regional wastewater
treatment and collection system is vital to the continued protection and
improvement of the water quality in the Three Lakes region. However, we must
point out that the DEIS is inadequate in either identifying or discussing the
secondary or indirect effects that could result from construction of such
facilities.
^m
The rules and regulations covering EIS preparation state that:
"...the effects of the proposed action on population and growth may
be among the more significant secondary effects. Such population
and growth impacts should be estimated if expected to be significant
and an assessment made of the effect of any possible change in popula-
tion patterns or growth upon the resource base, including...public
service, of the area in questions."^
This would seem particularly appropriate to Three Lakes in view of a Council on
Environmental Quality (CEQ) report which argued that, "sewers (have) a powerful
effect on the location, pattern, and timing of...residential development."2
These concerns are not adequately addressed by either the facility plan or the
DEIS. As for the 3283 undeveloped lots that currently exist within the Three
Lakes Water and Sanitation District boundaries (page 53), the DEIS only states
that "provision of sewer lines may make these lots...much more "developable"
than if no sewer were available (p. 51)." This is hardly illuminating in that
Section 1500.8 Content of Environmental Statement (a)(3)(ii), page 20533,
Federal Register, Vol. 38, No. 147-
Growth Shapers, Urban Systems Research and Engineering, Inc., Washington,
D.C., May 1976, p. 48.
520 State Centennial Building, 1313 Sherman Street, Denver, Colorado 80203 (303)892-2351
116
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Mr. Alan Merson
Three Lakes DEIS
November 14, 1977
Page 2
Grand County's zoning resolution presently requires a minimum of two acres for
residential building in unsewered areas—a size that is considerably larger
than most of the undeveloped lots (Table IV-5, pp. IV-24 and IV-25).
^B
The facility plan argues that the secondary growth impacts for Alternatives 4-
6—all of which are regional in scope—will be minimal "because the interceptor
(sewers) will give Grand County the opportunity to encourage replatting of
inactive subdivisions in close proximity to the interceptor and (will) en-
courage new growth to locate in suitable areas close to existing facilities
and utilities (p. IV-21)."
While this would appear to be an admirable objective, unfortunately, it is
at best a remote possibility as the DEIS points out on page 39. Replatting
could only be accomplished with the subdivider's approval and that person
would be less inclined to do so in view of the increased value that the land
would be worth with a central sewer. The aforementioned CEQ report estimated
that sewered, vacant land in suburban communities is worth from two to four
times as much as equivalent unsewered land in the same communities. Since the
Three Lakes region is a popular recreational area, that figure might be even
higher.
••
Hence, in order to adequately address secondary or indirect impacts,the follow-
ing topics must be dealt with:
A. Population. The facility plan states that a "potential peak population
of 9377 persons was projected for the study area by the year 2000." When
motel and camp residents were added, the total population figure swelled to
13,400(p. IV-16). However, as far as we can determine, these figures
were arrived at independent of any consideration involving added popula-
tion encouraged by a regional sewerage system. Since the differences
between Alternatives 1-2 and 3-6 are significant (in terms of the size of
the collection systems), it is difficult to believe that the above-stated
population figures will be the same for all six alternatives.
B.
Pattern of Development. In addition to the facility plan's remarks on
replatting of inactive subdivisions, the DEIS adds "that the provision
of a centralized sewage collection system can channel and concentrate
growth into areas deemed acceptable and suitable for it (p. 12)." In
support of this idea, the facility plan identified fourteen such "service"
areas for Alternatives 3-6 (Figures VI-7 through VI-10 of the Facility plan)
However, neither the facility plan or the DEIS indicated how the four
alternatives would have affected development patterns within the neighbor-
hood. Also, are we correct in assuming that the collection line system
is identical for Alternatives 3-6?
117
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Mr. Alan Merson
Re: Three Lakes DEIS
November 14, 1977
Page 3
Finally, since the service areas or neighborhoods are almost all inter-
connected, what conditions are present to reduce the intensification of
sprawl development along the western shore of Shadow Mountain Reservoir
and Lake Granby?3
C. Location of Development. Based on the DEIS figures (p. 51), the Three
Lakes Water and Sanitation District proposes to serve 1900 units
(residential, motel and campground) at the outset. How will these 1900
taps be allocated among the fourteen neighborhoods (again assuming that
the collection systems are identical for the fourteen service acres)?
D. Timing of Development. As far as we can determine, Alternatives 3-6 would
not be appreciably different in affecting the timing or rate of growth.
In fact, neither the DEIS nor the facility plan addressed the relationship
between the regional system's presence and its possible effect on the
area's growth rate. This is a glaring shortcoming in view of the potential
impact that growth encouraged by such a system could have on the public
costs for streets and highways (especially U.S. 34), police and fire
protection, schools and hospitals.
E. Phasing and Fiscal Costs. Related to the timing question, the issue of
phasing is inadequately covered in both the facility plan and the DEIS.
We believe phasing is necessary both for the reason given above (i.e. to
achieve "manageable" growth rates), and because of the Three Lakes Water
and Sanitation District's financing problems. The aforementioned CEQ
report, The Growth Shapers, argues that:
"Breaking down a project into successive stages of construction (i.e.
phasing)...has two side effects. First, it confines immediate development
to smaller areas and reduces leap frogging. Second, the resulting popula-
tion forecasting period is shorter; it therefore allows for more accurate
population projections and gives flexibility if population growth departs
from predictions. Such phasing, if intelligently planned, is unlikely to
increase project costs significantly. Any increased costs should be balanced
by the benefits of better community planning and a lessening of the immediate
financial burden of the project on present residents."^
CEQ reports, The Growth Shapers states that "in areas with heavy growth
potential, local level zoning and planning processes often cannot control the
development pressures which sewers release (p. 48)." In a similar vein, the
Colorado Supreme Court ruled in the Robinson vs The City of Boulder case that
a "sole and exclusive provider of water and sewer" (which the city was) could
not deny services to a landowner unless there was a "utility related reason"
(such as insufficient treatment plant capacity). Hence, if Grand County's
zoning resolution permits development outside of the fourteen neighborhoods,
and if the development is close to the collection lines, the Water and Sanitation
District will have to provide service. (Pacific Second Series, Vol. 547, p. 232)
*Ibid., p. 55
118
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Mr. Alan Merson
Re: Three Lakes DEIS
November 14, 1977
Page 4
Since the system's major expense is its collection lines (an item the
State Water Quality Control Commission has not funded in the past), it
would be useful to present a seventh alternative that considers a scaled
down collection system. We believe this is a reasonable request, in
view of Figures VI-2 through VI-4 (of the facility plan) which show
collection lines being planned in areas that appear to be vacant (most
notably in Service Areas "G", "H", and "I" in Figures VI-3 and "K" in
Figure VI-4). A reduction in the size of the collection system, along
with the elimination of the proposed neighborhood treatment units (sug-
gestions made by EPA), would relieve the Water and Sanitation District
of most of its financing problem. It would also make the entire project
more economically feasible—not to mention, environmentally more attractive.
F. Ski Area at Bowen Gulch. The DEIS on page 35, and again on page 60,
raises the possibility of ski area development at Bowen Gulch. However,
the DEIS avoids analysis by arguing that "Bowen Gulch development is
speculative...(which)...makes evaluation of its possible relationship
to a sewerage system equally speculative." Based on a preliminary assess-
ment, we believe that the development of Bowen Gulch for winter sports
would be compatible with many of the goals of the State of Colorado.
Therefore, we feel that the final environmental impact statement should
address the possible impacts that a ski area could have on the effective-
ness of the Willow Creek Lagoon system (especially if effluent discharge
into the creek is greatly increased).
In addition to the DEIS's shortcomings on secondary or indirect effects, we
would also like to take exception to a statement in Section 7 (Irreversible
and Irretrievable Commitment of Resources) . The DEIS states that "EPA does
not believe that the treatment alternatives further commit any land areas to
future use for housing and/or commercial development. These areas to be served
have already been committed to these uses by the local land use control
authorities, and no changes, with the possible exception of certain southwest
shore of Lake Granby areas, are anticipated." (p. 109)
This is a decidedly misleading argument in that it contradicts an earlier DEIS
position (previously quoted in this letter) which stated that provision of sewer
lines could make the (undeveloped) lots more "developable". It also conveniently
forgets to inform the reader that many of the existing undeveloped lots could
not be developed because they are not large enough to meet the county's two-acre
minimum lot size. This is a minor point perhaps, but we strongly feel that the
DEIS should not downplay the potential influence of the Willow Creek Lagoon systa
in the Three Lakes region.
This potentially significant influence should have been discussed in Section 9
(Relationship Between Short-term Uses of the Environment and the Maintenance and
Enhancement of Long-term Productivity). While proper management of wastewater
in the Three Lakes area will constitute an improvement in water quality it will
119
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Mr. Alan Merson
Re: Three Lakes DEIS
November 14, 1977
Page 5
also result in a change in the "quality-of-life" for the current residents of
the area. The existence of an extensive treatment and collection system will
encourage what we feel will be major development pressures. Whether these
growth pressures will reduce long-term productivity is an unanswered question—
but one that deserves consideration nevertheless.
^•B
In conclusion, we feel that much of the success or failure of the Three Lakes
Wastewater Treatment Facilities System rests with Grand County. We applaud
EFA's efforts towards development of adequate non-point source pollution controls,
and we are encouraged by the county's willingness to consider these and other
land use measures. The formation of a strong Three Lakes area unit plan, backed
up by revisions in the county's zoning resolution, partially hold the key to
insuring orderly growth of this important recreational area. These, together
with phased development of a regional wastewater treatment and collection system,
can serve as a model of what land use planning can achieve in Colorado.
Very truly yours,
Peter Naseth
Planner
Reviewed:
Philip H. Schmuck, Director
PN/vt;
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Response to State Division of Planning:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
^ v REGION VIII
'
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We should emphasize that our Involvement 1n local land use affairs
has been basically associated with our authorities in water quality pro-
tection (In this case as related to not only sewage treatment but also to
the aforementioned Impact of sewerage system related growth on accelera-
ted non-point pollution).
2. We have come to the conclusion that a centralized sewerage col-
lection system (one serving the main "built-up" areas) and one
that does not discharge effluent to the lakes 1s needed for the
long-term protection of the water quality of the lakes. Con-
versely, continued use and additions of septic tanks 1n large
concentrations, continuation of the Grand Lake sewage plant
discharge, and the addition of probably another substantial
sewage plant at the North Shore area (with lake discharge)
are not thought to be desirable. Non-point control, of course,
must be an essential part of any water quality plan for the
area.
The proposed sewerage system as described 1n the EIS has the follow-
ing advantages: (a) serves heavily developed areas now relying on
septic tank systems; (b) avoids the situation of having two major sewage
treatment plants both discharging to the lakes (two plants would probably
result because of high development concentrations at Grand Lake and again
at the "north shore" area); (c) avoids any lake discharge of sewage effluent
(effluents will only Increase 1n the future), and; (d) provides a safe and
reliable treatment method with low O&M, capacity for reasonable future
growth, and offers land treatment during the high load summer season.
3. We have realized that the provision of a centralized sewerage sys-
tem will no doubt play a role 1n allowing a certain amount of
"new" growth 1n the area. Neither EPA nor local government can,
however, predict the actual amount of growth that will be associated
with sewering additional parts of the Three Laksj area.
We have accepted the fact that a certain amount of growth will In-
evitably occur due to the availability of sewers because Grand County
has, and continues, to make Impressive progress 1n the area of
local land use planning for the area and thus will be 1n a position to
mitigate the Impacts of this growth. Most Important, Grand County has
reached agreement with EPA and the Sanitation District to Implement actual
controls needed to mitigate our concerns over potential environmental dam-
age related to secondary growth.
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Grand County's efforts 1n the land use area have, 1n fact, been
the basic factor leading to resolution of differences on this project.
Again, though we can only agree that the sewerage project will lead to some
level and type of secondary Impact, we believe that these Impacts can
be satisfactorily mitigated by the County.
Specific actions that Grand County, 1n cooperation with the Northwest
Colorado 208 Project and others, have taken Include:
a. Institution of the COMARC Design Systems computerized land
use/environmental planning and analysis process for the Three
Lakes area. This system has resulted 1n a set of detailed
"source" maps and data files (soils, land uses, topography, cultural
features, proposed sewerage facilities, etc.), a number of "inter-
pretive and suitability" maps (septic tank limitations, erosion
potential, aspect, flood prone areas, proximity to roads, etc.),
and a number of "issues" maps (environmental limitations, develop-
ment suitability, etc.) In our opinion, the COMARC system has given
Grand County one of the more data-based and detailed planning and
management tools of any rural county 1n Colorado or of many
other states, for that matter.
b. Grand County 1s now working on revisions to Its land use regula-
tions which the COMARC process and County experience have shown
to be necessary. Part of the County's activity is also based on
the findings of an EPA-Grand County cooperative study titled
"Review and Analysis of Grand County, Colorado, Land Use Laws Relatec
to Water Quality Protection," by the Denver law firm of White and
Burke. As stated on the draft EIS, enactment of certain land use
controls as discussed by White and Burke and as discussed by EPA
and the County in the letters appended to the Facility Plan must
take place before EPA will approve Step II (design) or Step III
(construction) of any wastewater facilities at Three Lakes.
We do not pretend that our efforts will lead to some "perfect" level
of future land use control at Three Lakes. Poorly plarr.ed and envlronmental 1)
damaging development may occur in the future despite everyone's good inten-
tions. We are saying, however, that 1n our opinion., the combined efforts
of all involved 1n the seven plus years of deliberation over the Three Lakes
sewerage project has resulted in a great improvement in land use planning
and environmental protection for this area and that the sewerage project,
as proposed, Is compatible with these goals.
Responses to your specific comments are as follows (we have numbered
your comments to correspond to our response):
(1) One thing that should be clarified about the 3283 lots and 2-
acre minimum lot size for unsewered areas is that the 2-acre
standard applies only to areas receiving subdivision or building
approval after 1972 (the date when the County enacted this
regulation). For lots approved prior to 1972, a category Into
125
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which most of the 3283 lots fall, a septic tank/leachfleld
system may be used 1f State Health regulations are met (100*
distance from well to leachfield plus adherence to design
specifics for the leachfield, tank, etc.). We admit to sharing the
Idea that the use of septic tanks was strictly related to the
2-acre minimum lot size and Incorrectly conveyed this 1n the
draft EIS. We have only recently been corrected on this Issue
by Grand County via their review of the draft EIS.
It should also be pointed out that the figure of 3283
undeveloped lots 1s derived from a calculation of all un-
developed lots 1n Grand County planning area "c". "Many of
these lots are not 1n close proximity to the proposed sewer
lines and are not being considered for service by the Sanita-
tion District. We believe a much better number for undeveloped
lots that could be served by the proposed system 1s that found
on page 97 of the EIS, I.e., 1918 lots. This figure
was derived by calculating only those lots 1n areas to be
served by the proposed sewers. Though the Robinson Decision may
possibly mean that those lot owners not Included 1n the 1918 lot
figure could hook onto the proposed system, were they to decide to
make the necessary Investment, the economic realities of Individual
lot owners making this decision tend to argue against substantial
amounts of this type activity occurring. For purposes of Impact
evaluation, however, we believe that use of the 1918 figure for
estimating possible development potential 1s more accurate and realistic.
Even though the lots approved before 1972 do not have
to meet the 2-acre lot size minimum, we find 1t very difficult
to calculate the number of these lots that might be developed
were a sewer line available. For one thing, we do not have the
level of soils and geology data that will reveal which lots may
or may not meet State septic tank leachfield standards at pre-
sent and thus aren't being developed for this reason. The best
we have been able to do 1s to calculate that the area 1s generally
"unsuitable" for such use while, at the same time, recognizing
that a number of these systems are being Installed 1n the area
each year after site specific evaluation by the County Sanitarian.
It should be pointed out that a builder, 1f he chooses to
make the Investment, can overcome certain of the "natural"
restrictions of this land for sewage disposal. This 1s, 1n fact,
what many people have done 1n the Three Lakes area at present.
On the other hand, there are currently a probable number (?)
of lot owners who are holding off building decisions until
the sewer Issue can be worked out. Common sense would dictate
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that you not make a substantial investment in a septic system
only to abandon it after a short period of Lise. How many
people there are of this type, we do not know.
In Grand County's opinion, (personal conversation with
Leroy Scott, Director of Development) provision of sewer
lines may initially lead to a release of certain amount of
presently "pent up" building demand owing to a present lack
of such service. No attempt to quantify this demand
has been made. The County is also of the opinion that once
this initial build-out occurs growth will then level off to
match expected County growth forecasts. The County does accept
the population growth estimates as presented in the draft EIS
and Facility Plan and as stated, believes that a new sewerage
system will not appreciably effect this long-term figure.
Another factor that should be considered is that sewer
service is already available in the Grand Lake-Columbine Lake
areas yet substantial unbuilt-upon lots exist in these areas.
It would appear that the existance of an available centralized
sewer system is not the only reason these lots aren't being
developed. Thus, it would appear that the existence of the
Grand Lake sewerage system in combination with the probable
ability of many of the 1918 lot owners (numerous individuals
may own more than one lot) to meet State septic tank regula-
tions already provide for a substantial amount of potential
growth in the Three Lakes area, at least as related to avail-
ability of sewerage service.
The question still remains, "How many of the 1918 lots
will be developed if sewer lines are greatly expanded in the
area?" Surely all 1918 won't be built on, at least initially.
For purposes of discussion, we could assume that if the sewerage
system is constructed, then one-third of those lots will be
built on within 5 years (a risky assumption at best, given the
uncertainties of people's preferences, economics, ski area
development, etc.). If this build-out rate were to occur, the
resulting population (figured at 3.0 people per household)
would be approximately 1918 people. Assuming an approximate
3 to 1 ratio between summer and permanent residents (roughly
the ratio used in the Facility Plan), this would result in about
639 new permanent residents and an additional 1279 summer residents,
Because there are less than 533 permanent residents in the
area at present, and this figure has only grown very slowly in the
last 10 years or more, it is hard to visualize provision of sewer
service leading to a more than doubling of this number It
would probably require development of a ski area at Bowen Gulch,
an undertaking that is purely speculative at this time, to pro-
vide the economic base to support this many new permanent
residents. The addition of summer homes, with some level of
year-around use, might more realistically be the type development
that actually takes place.
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(2) As you point out, we do not share the belief as stated in
the Facility Plan that the provision of sewer lines will
necessarily lead to any wholesale replattlng of old sub-
divisions and thus a lessening of secondary growth Impacts.
We have Instead attempted to evaluate Impacts from the pro-
posed project based on the possible development of lots as they
now exist.
Grand County has, however, expressed their belief (Stan
Broome, County Manager) that provision of sewers may lead to
a certain amount of "replattlng." They base this opinion on
the belief that a central sewer will make certain of the areas
of very small lots more attractive for higher density develop-
ment. The County believes that if this occurs, 1t will be an
environmental benefit because 1t will allow the County to exercise
strong control over the new development via their PUD and sub-
division regulations. In view of the work the County is now
doing In land use and environmental planning we tend to agree
that there could be some very real benefit in replattlng. We
would not, however, want to convey the impression that we believe
this potential activity 1s certain to occur.
A major point to be discussed in regards to the proposed
sewerage project as 1t relates to location of growth in the ser-
vice area 1s whether or not this growth will occur in environ-
mentally acceptable areas and whether or not this location would
be compatible with local land use plans. A related issue is
whether or not the means exist to mitigate growth impacts if it
1s found that such growth might be allowed to occur in unaccept-
able (soils, slope, etc.) type areas.
In terms of the compatibility of the sewer line to local
land use plans probably everyone 1s in agreement that new develop-
ment will tend to locate in areas that have ready access to the
sewer lines. First, it should be pointed out that Grand County
believes that the proposed sewer lines are compatible with its
on-going land use plans and projections for the area (see letter
no. 10 and 12 in the appendix of the Facility Plan). Also, the
County believes that they can control the growth as it material-
izes.
In our opinion, the sewer lines, as proposed, will have the
following effects: (a) will tend to concentrate the growth that
does occur and thus help dampen tendencies for random and dis-
persed development with this type development's attendant impacts
(excess road building, loss of wildlife habitat, etc.); (b) will
not greatly Impact development along the Immediate west shore of
Shadow Mountain Reservoir because little "developable" land remains
1n this area; (c) will not encourage extensive development along
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the west shore of Lake Granby because of extensive public lands
along this shore-line and because of EPA's position of not ap-
proving the southern extension of the interceptor to Area "L"
(at least until the NRA issue is settled), and; (d) will tend to
focus development into the two general areas, i.e., Grand Lake/
Columbine Lake and the North Shore of Lake Granby which are both
areas where land use planning for the area recommends growth be
located.
We are, of course, basing a certain amount of these opinions
on land use on Grand County's efforts to improve its
land use planning. Again, neither EPA nor the County wants
to paint an over-optimistic picture that there will suddenly be
a complete switch away from what many consider present land use
abuse in the Three Lakes area. We do believe, however, that the
County is moving in a very positive manner 1n these regards and
that their efforts should result in a more orderly and environ-
mentally acceptable situation in the future.
(3) As you know, population projections are one of the most diffi-
cult aspects of any planning or EIS analysis and Three Lakes has
proven no exception. In terms of our own analysis for this pro-
ject, we have found no reason to question the year 2000 popula-
tion figure of 9377 as used in the Facility Plan. Grand County
and the Northwest Colorado 208 (see attached letter from the NW 208)
also agree that this is a reasonable "planning" figure. The 9377
figure was derived independently of the assumption that an expanded
sewer system would lead to a higher population than would result
if the system were not built. As stated, the County and the Sanita-
tion District do not believe that construction of the system will
effect the total number of people who may live in the area.
In our opinion, the availability of a centralized sewerage
system will make it easier and more desirable to build in the
area. The amount of this induced activity is impossible to esti-
mate but, if the figures we used earlier in our response make any
sense, the induced growth would be well within that predicted by
the Facility Plan, i.e., 9377 by the year 2000. Actually, if
single family residences were constructed on all 1918 lots to be
served by the sewer lines (at 3.0 people per residence), this would
result 1n 5754 people. Again, this is considerably less than the
figure used 1n the Facility Plan.
Also, 1t should be pointed out, that practically speaking,
the real differences among the various alternatives in allowing
growth in the area (ultimate numbers) is between the "Do Nothing"
alternative, on one hand, and all the other alternatives, on the
other. We would include Alternate 2, "Upgrading Existing Facilities"
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8
along with Alternatives 3-6 because sewer lines could be extended
from the two existing plants (upgraded) to cover nearly all the
same service areas as covered under the other sewer line alter-
natives. One of the tough problems with this project all along
has been how to best serve those areas already heavily built up.
The result of our thinking on this problem has been the conclusion
that whether you build one treatment plant or two, many of the
present unplatted lots are 1n close enough proximity that sewers
could be extended to them, alblet at Increased cost, Increased
O&M, etc. for 2 plants as opposed to one. Two plants with lake
discharge, however, are much less desirable from a water quality
viewpoint than the system proposed.
In our opinion, the 9377 population figure 1s a high one
unless, for Instance, a ski area of some size were to be developed
1n the area. A more realistic ultimate growth figure might be
only one-half or less of the 9377 number. Though here too, the
many variables Involved make these calculations purely speculative.
The real difference, as we stated, 1n population potential
between the various alternatives 1s probably between the "Do
Nothing" alternative and all the others. We would estimate that
"Do Nothing" would lead to a permanent and summertime population
growing not much larger than at present rates. The population
growth associated with the other alternatives would possibly show
an Initial surge of growth as those who have been waiting on the
sewage system take action. In the long run, the central sewer
system alternatives will lead to larger absolute numbers of people
1n the area (possibly the number we have speculated on) as opposed
to "Do Nothing."
(4) In our opinion, the sewer system configuration, as proposed, will
be a major factor 1n where development occurs 1n the Three Lakes
area. This tendency for growth to concentrate 1n areas with close
proximity to the sewers 1s the reason we retained COMARC to analyze
the Impacts of development of these particular areas at Three Lakes.
This Informalton supplied by COMARC 1s the basis of much of our
analysis 1n the EIS.
Previous land use plans have Identified two major "growth"
centers 1n the area. These two are the Columbine Lakes/Grand
Lake area and the North Shore of Lake Granby area. A majority
of the developed lots that would be served by the proposed system
fall In these two general growth areas (these are neighborhood
areas D, C, B, A1, A, F, H, I, and J). Me have thus concluded
that the proposed sewerage system 1s compatible with general growth
location plans for the area. Neighborhood Area "K" 1s also being
considered a probable growth area by Grand County and 1t, too,
1s the location of a considerable amount of existing development.
Neighborhood Area "L" 1s the one we will not authorize for
sewering (or possible Individual treatment system of some type)
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until the NRA Issue can be worked out. The resolutions from
the Sanitation District as found in Appendix A of the Facility
Plan show that they basically agree to cooperate on this issue.
Figures VI-2 through VI-4 show the configuration of the
proposed sewage collection lines for each neighborhood area.
These figures are the best indication we have as to where growth
will probably locate as related to proximity to sewer lines.
Again, we believe the sewer system which has been proposed will
encourage build-out 1n existing subdivisions (these are also where
present development concentrations are located which should be
served) and thus tend to concentrate growth in these areas.
The collection Tines for Alternatives III through VI are
the same, with one exception. Alternative III is based on an
extension of the Interceptor sewer to the south end of Lake
Granby and also north to area "E". This configuration includes
sewers serving all Neighborhood areas shown in the Facility Plan,
one main interceptor sewer, and one treatment plant.
Neither EPA nor Grand County can offer absolute assurance
that the proposed sewer system will not lead to some type and
degree of "strip" development. A considerable amount of commer-
cial development already exists along the west shore of the Lakes
and the Highway 34 corridor. Factors that will tend to discourage
or stop this type of development along the West shores of Shadow
Mountain Lake and Lake Granby are: (a) a significant amount of
Federal land, especially along Lake Granby (see Figure IV-15,
Facility Plan); (b) continuing efforts by the Park Service to
establish NRA policy w11ch includes probable purchase of some
lake shore areas; (c) EPA refusal to approve extension of a sewer
to Area "L" until the NRA issue is settled, and; (d) Grand County
desire to control this type development. For the private lands
Involved, 1t will ultimately be up to the County (for non-munici-
pal areas) to control development. Grand County Is currently
attempting to revise its land use regulations to better control
such things as strip development, and, as we have stated, have
already reached agreement with EPA on specifics related to this
issue.
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10
(5) Data on the allocation of taps per neighborhood areas 1s found
on pages Vl-7 and Vl-8 of the Facility Plan. These figures are
given as "population equivalents" but do give an accurate pic-
ture of where existing development 1s now located.
(6) We have discussed at length, the subject of the potential effect
of the proposed sewerage system on population growth 1n proceed-
ing parts of this response. To reiterate, we are of the opinion
that (1) the system will allow some Increased level of growth
1n the area which 1s now stymied due to people's unwillingness to
Invest 1n septic tank systems; (2) the amount of this growth,
though nearly Impossible*to estimate with any degree of accuracy,
should not exceed that predicted by Grand County and the NW
Colorado 208 and will probably be much less than the Facility Plan
"design" figure; (3) any very rapid or large population Increase
1n this area would probably be associated with construction of
a ski area; (4) growth and Its Impacts, associated with ski
area type development would be covered by a separate Federal EIS
(assuming Federal actions are Involved).
Though we do not believe that 1t 1s possible to predict the
level of growth that might be attributable to provision of sewerage
service, we believe the necessities of water quality protection for
the area require a substantial Improvement 1n waste treatment. Most
Important, we believe that Grand County 1s making positive efforts to
control growth related Impacts. This later factor, plus our own COMARC
system based analysis of the probable growth areas, have led us to
the conclusion that future growth should occur 1n a manner more
compatible with the environment of the Three Lakes area than has
been true 1n the past.
(7) The possibility of "phasing" the proposed Three Lakes sewage
system has been a topic of dlcussslon between EPA and the Sanita-
tion District on numerous occasions. We have found there are two
sides to the "phasing" question, one environmental and the other
financial.
In terms of environmental factors, we concluded that we should
analyze the potential Impacts of the entire proposed system. A
facility plan and EIS analyze long-term water quality management
plans and, even though factors may change as time goes on, all
components of the plan must be looked at during this Initial phase.
Thus, our analysis looks at each neighborhood area Including the
two outlying ones that would be served by separate small treat-
ment plants even though financial restraints may not allow con-
struction of these components until some future date. What our
draft EIS means then 1s that as far as environmental factors go,
we have looked at an entire proposed sewerage system and have
judged that Its Impacts are acceptable and controllable.
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11
As you note, we have suggested in our draft EIS that the
Sanitation District strongly consider phasing parts of the pro-
posed sewerage system for financial reasons. We believe that the
most logical way to phase the system would be to not initially con-
struct the two separate neighborhood treatment plants at areas "E"
and "M" nor attempt to serve area "L" (the area in conflict with
NRA plans). Elimination of these components results in a savings
of approximately $600,000 (EPA would have contributed about $210,000
of this total assuming no collection line funding).
The neighborhood areas you mention as being apparently vacant
actually have a considerable amount of present development.
Expressed in terms of population equivalents (PE) these areas show
the following levels (existing PE/year 2000 PE): area "G" - 694/950;
area "H" 370/800; area "I" - 420/930; area "K" - 832/2410. As
you can see by comparing the development levels of these neighbor-
hoods with the others proposed for service (See pages CI-7 and
VI-8 in Facility Plan) they include some of the higher development
densities in the service area.
The Sanitation District may well be forced to cut back on
proposed sewer line extensions to the various neighborhoods
because of financial reasons. We cannot make any determination
given the present distribution of PE's, just where this possible
cut back should occur (except for the obvious areas "E", "M",
and "L"). If the Sanitation District does not receive the full
amount of funds they need for the collection system they will
have to make some very hard, and probably unpopulat, decisions as
to which areas will not receive initial service.
Under Federal regulations, the Sanitation District must show
that it has the financial capability to insure adequate construction
of a sewerage system which has received conceptual approval by
EPA. This financial capability must be shown before we approve
any Step II (preparation of plans and specifications) for the
project. These regulations thus make it a requirement that the
Sanitation District have its financing "in hand" which, in the
Three Lakes situation, may well mean deletion of parts of the pro-
posed system.
(8) We hope we did not convey the Impression that we have ignored
consideration of a potential ski area at Bowen Gulch in our deli-
berations over a sewerage system for the Three Lakes area. One of
our concerns with the originally proposed underwater vacuum collec-
tion lines and with lake discharge of effluent was related to con-
cern about greatly Increased winter use of these systems due to ski
area development and associated increased wintertime sewage loads.
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12
At the same time, there 1s no assurance that Bowen Gulch, or
any other Three Lakes site, will ever be developed as a winter
sports site. If a ski area 1s to ever be developed 1n this area,
1t must (1) have financial backing and (2) receive full analysis
and public scrutiny via a separate Federal EIS (assumes all sites
are on Federal lands). To our knowledge, the first factor, I.e.
a financial sponsor, does not yet exist and therefore, even though
there 1s much local conversation over such a development, 1t remains
a matter of "specualtlon."
The proposed lagoon system has been designed with a certain
amount of growth taken Into consideration (see page 6-3 1n
Facility Plan for design specifics) 1n Its sizing and process
configuration. If the Three Lakes area were to outgrow the pro-
posed lagoons, they could be expanded to Include additional cells
and possible changes 1n the treatment process to accommodate
this growth. This would be true for both summer and winter loads.
(9) We did not Intend to down-play the role of the proposed sewerage
system on Three Lakes area land use. The statement you quote
was Intended to point out that the basic direction of land use 1n
the area has already been set, I.e., commercial and residential
development 1n the areas to be served with sewers. These areas
are already largely committed to these uses via County zoning and
the existence of present development and subdivision plats. The
sewage system will, of course, tend to reinforce the location of
these type land uses 1n the sewer service area.
The potential land use Impacts of the proposed system have
been the major point of discussion on this project. It 1s only
because Grand County has agreed to enact non-point pollution con-
trols and because the sewerage system 1s compatible with local
land use planning that we have been able to proceed with the
project. However, we do believe the sewerage system can be a positive
force 1n growth control and locatlonal decisions at Three Lakes.
The residents of the Three Lakes area have expressed support
of the proposed system via their passage of a local bond Issue
and through their statements at numerous public meetings held
on the sewerage project and on the County land use plan. The
system will surely lead to some higher level of development than
currently exists yet without some major economic boost such as a
ski area we do not believe that the growth rate attributable to
the sewerage system will "overwhelm" the present residents. Again,
we are of the opinion that the system can be used to not only bene-
fit water quality, but can also be a positive factor 1n local land
use and environmental control.
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13
We hope we have answered your questions on the draft EIS. We
especially appreciate your recognition of the efforts which we, and many
others, have expended on this project and Its many ramifications. Since
it 1s our understanding that your agency has not given A-95 approval to
this project, pending our answer to your comments, we would ask that you
review our answers and give us your response as soon as possible. We
would Intend that your response back to EPA be either your formal A-95
approval of the project or, 1f you do not agree with our response, your
continued disapproval. We will be happy to meet with you at any time on
this project 1f you believe 1t would be helpful. We are sure that
Grand County, the 208, and the Sanitation District would also be more than
willing to meet with you also.
Again, thank you for your interest in the Three Lakes project and
your concern with land use and environmental impacts in this beautiful
area.
Charles W~. Murray, Jr.
Director, Water Division
Enclosures
cc: Sam Hazelbart, Chairman, Three Lakes Water and
Sanitation District
Evan Dildine, Secretary, Colorado Water Pollution
Control Commission
Stan Broome, Manager, Grand County
Philip Schmuck, Director, Colorado Division of
Planning
Frank Rozich, Water Quality Bureau, Colorado Department
of Health
135
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Department of Local Affairs
Colorado Division of Planning
Philip H. Schmuck, Director
Richard D. Lamm, Governor
MEMORANDUM
TO: State Clearinghouse
FROM: Division of Planning
DATE: February 8, 1978
SUBJECT: Final Wastewater Treatment Facilities Plan
#77-502500-008
On February 7, 1978 the Division of Planning received a letter from
Mr. Charles W. Murray, Jr. of the Environmental Protection Agency
(EPA) concerning the above referenced project. Mr. Murray's
letter dealt at length with the concerns that we raised in our
review of EPA's draft EIS on the Three Lakes Wastewater Treatment
Facilities.
Generally, we feel that Mr. Murray's letter adequately addresses
our concerns. As a result of this information, the Division would
like to recommend approval of the Willow Creek Lagoon System.
Prepared by:_
Pete Naseth, Planner
Reviewed by:
Philip H. Schmuck
Director
PN/btm
121
:313 Sherman Street, Denver, Colorado 80203 (303) 892-2351
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Department of Local Affairs
Colorado Division of Planning
Philip H. Schmuck, Director
COLORADO CLEARINGHOUSE
'816
Richard D. Lamm, Governor
REVIEW SUMMARY
TO:
THREE LAKES WATER AND SANITATION DISTRICT
Attn: Sam Haszelbart
STATE I.D. NO.
SUBJECT:
DATE: February 9, 1978
77-502500-008
Final Wastewater Treatment Facilities Plan
The Colorado Clearinghouse has reviewed your notice of intent to apply for federal
aid and has submitted it to appropriate state agencies. As a result of this review:
X Based on information available at this time, it has been determined that
the project does not appear to conflict with state plans, programs, or
objectives.
However, it is recommended that the following conflicts, difficulties, or
conditions be met or solved:
The clearinghouse has no objections to the funding of the project when the
above have been resolved.
A request has been received from one or more state agencies that the final
application be submitted for review. The project cannot be signed off
until the application has been reviewed.
It is recommended that approval of the project be withheld, for reasons
stated in the attached letter from
Stephen 0. Ellis
Principal Planner
This form and all attachments must accompany your application to the Federal fund-
ing agency.
cc: Northwest Colorado Council of Governments
(Environmental Protection Agency
12?
SOC-4, Revised August 1977
520 State Centennial Building, 1313 Sherman Street, Denver,
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
MISSOURI BASIN REGION
IN REPLY RKFER TO. BUILDING 67. DENVER FEDERAL CENTER
ER 77/929 DENVER. COLORADO sozzs
MOV i 7 1977
Mr. Alan Merson
Regional Administrator
Environmental Protection Agency
Region VIII, Suite 900
1860 .Lincoln Street
Denver, Colorado 80203
Dear Mr. Merson:
This is in response to your September 2, 1977, request for Department
of the Interior review of the Draft Environmental Statement (DES) for
the Wastewater Treatment Facilities and Sewerage for the Three Lakes
Water and Sanitation District. We have completed the requested review
and have the following comments:
General Comments
1. The environmental statement and final facility plan are generally
adequate in their presentation of existing fish and wildlife resources.
U) The impacts associated with each of the alternative plans are addressed,
but those related to the primary and secondary impacts to fish and
wildlife resources should receive more attention and clarification.
Based on our review, it appears that the Regional System minimizes
damages to fish and wildlife and satisfies the wastewater management
requirements.
2. Grazing privileges for the public lands affected by the preferred
Willow Creek Lagoon alternative are leased to the Stillwater Cattle
. Company. If converted to sewage treatment use, the impacted area will
**/ represent a loss of approximately 4 AUMs out of a total of 84 AUMs of
Federal grazing privileges. Presently the season of use is May 1 to
September 30, and the class of livestock is cattle.
3. Severe erosion occurs in the unnamed tributary to Willow Creek.
There is no right-of-way for the Red Top Valley Ditch crossing the
(3) public lands. Prior to any BLM use authorization for the Willow Creek
Lagoon site, it would be necessary for the operator of the ditch to
obtain a right-of-way under the provisions of Title V, P.L. 94-579.
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4. Descriptions of the Willow Creek Lagoon site in Chapter 7 and in
Appendix C of the Final Waste Water Treatment Facilities Plan show
the proposed access road following the east boundary of the public
land. From preliminary field review, this does not appear to be an
appropriate location for an access road because the route crosses
timbered land, and the natural contour would require large cuts and
fills to remain within 8 percent grade parameters. Access from an
existing road within the Stillwater Estates subdivision would require
less construction and may be preferable.
5. We suggest that the preferred alternative should receive at least
' ' qualitative evaluation of impacts on water supply at this stage. Since
this alternative would involve reuse of effluent for crop irrigation,
the statement should consider the potential for impacts on ground water,
particularly because of the commonly very shallow water-table conditions.
6. The water rights issue is mentioned or discussed at several points
(6) in the DES (pages 11, 32, 96, and 108). The discussion on page 96
most accurately describes the current situation with respect to the
concerns of the Bureau of Reclamation and the Northern Colorado Water
Conservancy District. We concur in this assessment of the situation
and EPA's stipulation as to what is expected prior to proceeding to
Phase 2 of the proposal.
7. The Intermountain Field Operations Center of the Bureau of Mines is
interested primarily in the effects of such projects upon mineral
(7) resources and the mineral industry. Few, if any, direct impacts of
this nature are identifiable, except perhaps for a limited and temporary
need for sand and gravel for construction purposes. Thus, we have no
objection to the environmental statement and facilities plan as written.
8. The Environmental Protection Agency has well discussed the issues,
. . especially the nonpoint type water pollution effects which could result
* ' from the project. As emphasized, nonpoint pollution is the major water
quality problem of the Three Lakes area, not point pollution for which
the project is designed. The basic conclusions on page 75 support
this point.
9. We note that EPA has compiled a list of the known prehistoric and
(9) historic sites in the area of the Three Lakes Water Treatment Facility
(p. IV 27-29 of Final Wastewater Treatment Facilities Plan). However,
the final statement should provide clarification of apparent problems
concerning the cultural resources section of the draft statement.
Page 106 of the draft environmental impact statement refers to an
archeological survey, but the report is not specifically cited. While
we appreciate that the report has been distributed to those agencies
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with the greatest concern for the cultural resources of the area, it
would seem desirable to fully document in the environmental statement
the measures that have been undertaken. The name of the archeologists
conducting the survey and the affiliated institution or corporation
should also be included. With known historic and prehistoric resources
in the area (pp. IV 27-29, Final Wastewater Treatment Facilities Plan),
it is essential that a 100 percent survey of the project area be
conducted to prevent loss of any cultural values which may exist in the
area. This would be in keeping with the letter and spirit of the
National Environmental Policy Act, Executive Order 11593 and the
Advisory Council on Historic Preservation Procedures for the Protection
of Historic and Cultural Properties (36 CFR 800). In addition, the
final statement should also reflect measures to be implemented in the
event that previously unknown cultural resources are encountered during
construction.
10. A letter from the State Historic Preservation Officer should be
,-.% included along with his comments concerning the survey(s) of the project
* ' area. It appears that none of the National Register Sites in the area
will be affected by the proposed project. However, this should be
confirmed in the letter from the State Historic Preservation Officer.
Specific Comments — DES
(11) 1. Page 2: The introduction, summary, and other sections where necessary,
should clarify that the neighborhood systems will continue to discharge
to the Three Lakes Basin.
/... 2. Page 6, first paragraph: According to water analyses results in
* ' the area described, the statement that the Shadow Mountain holding
lagoon is a source of point pollution is incorrect.
3. Page 10, second paragraph: Although revised National Recreation
Area (NRA) planning is in the preliminary stage, the National Park
Service's objectives for the west and south shorelines of Lake Granby
(13) are to provide more open space by eliminating nonconforming obtrusive
uses and to provide more visitor day use opportunities through pro-
vision of increased accessibility and day use facilities.
4. Page 25: The additional growth stimulated by each alternative
plan may have adverse secondary effects on fish and wildlife resources.
According to the DES, the growth rate associated with the Regional
System (80 taps per year) is unacceptable, yet page 94 states that
the nonpoint impacts associated with each alternative plan are similar.
Specifically, what are the objections to the Regional System's growth
rate and how are these objections mitigated with the Willow Creek
alternative?
3
138
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5. Page 26: The secondary impacts associated with each alternative
plan are major considerations in selection of the preferred alternative.
We believe development of lands proposed for addition to the NRA
would not be in the best interest of fish and wildlife resources.
However, in view of the zero discharge design of the Regional System,
it should be clarified whether the presence of a sewer line will
necessarily result in the development of lands proposed for addition
to the NRA. Could the NRA merely serve as a right-of-way for sewered
service to Sunset Point?
-. . 6. Page 41: The type of land use controls to be implemented by
* ' Grand County should be specified in the DES if the facilities plan
will not accompany the DES for public review.
7. Page 53: Column 3 of the table that appears at the top of this
,._, page only totals 83 percent. Either a category of ownership was
* ' missed or incorrect percentages have been included.
8. Page 82, third paragraph: Although the COMARC study considered 16
factors of resource and land uses to develop a number of interpretive
(18) and constraint maps for land use capability, it did not consider
visual vulnerability. The primary thrust of the COMARC study was
water quality, as stated on page 43 of the draft environmental state-
ment. In contrast, the Three Lakes Regional Planning Study (CNC/NHPQ
1973) considered visual vulnerability a key factor in developing its
land use capability maps. The present NRA plan considers visual
vulnerability a key element in developing its suggested land acqui-
sition and facilities development programs, not only for Neighbor-
hood "L," but Neighborhood "M" and part of Neighborhood "K," as well.
Most of the undeveloped lots are either in area "L" on the steep,
unforested slopes of Table Mountain, or in area "M" on an open, flat
grass/sagebrush ecosystem quite visible from U.S. 34 and Colorado 150.
Area "K" involves several nonconforming obtrusive commercial develop-
ments which the National Park Service would obliterate in conformance
with the above-mentioned NRA objectives. The erosion hazard evaluation
on page 92 of the draft environmental statement does not consider the
steep terrain outside of the interceptor critical to resolving the
NRA issue.
9. Page 100: We believe the use of vacuum lines would be detrimental
(19) to aquatic resources. It would be helpful to clarify whether or not
this technique is incorporated in the Regional System.
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10. Page 110: A complete summary of the COMARC analysis should be
(20) included in the DES. Also, the impacts expected to wildlife resources
at each alternative site should be specified.
Specific Comments - Facilities Plan
1. Page IV-9, Fish/Wildlife: Discharges are proposed for Red Top
Valley Ditch, the unnamed tributary and the North Fork of the Colorado
River. This section should, therefore, include an assessment of these
tributaries' aquatic resources.
2. Page V-5, Facilities Plan: The National Park Service will be issued
a discharge permit for the Stillwater Campground facility in the near
future. Although BOD criteria are still in excess of the effluent BOD
(22) criteria of 30 mg/1, use of the trailer dump station has been terminated.
The facility will be monitored closely in 1978 to determine if toxic
chemicals utilized by trailer owners inhibit the treatment process.
3. Page VI-1: According to the results of recent water analyses,
... the statement that the Shadow Mountain lagoon is a source of water
* ' pollution is incorrect.
4. Vage VI-18, Fish/Wildlife: The potential disturbances to elk,
,„.» deer, bighorn sheep and other wildlife resources should be specified
» ' for each alternative plan.
5. Page VII-2, Water Quality: Will the entire volume of treated
effluent be utilized for irrigation? An analysis (similar to the
(25) analysis of the Sun Valley Ranch effluent), of the impact the Willow
Creek and Sunset Point Plant effluents may have on receiving waters
would aid in evaluating the impacts to fish and wildlife resources.
6. Page VII-4: There is recent evidence to document that chlorine
/«-% may adversely affect fish resources at concentrations neaj the limits
' ' of detection. We believe the potential impacts to fishery resources
associated with the chlorinated effluent deserves further evaluation.
Sincerely yours,
f\
E. RAYBOURN (J
Regional Environmental Officer
140
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LU uc\Jdf UI«IIL Ul 1IILCI IUI i v.uiiiiiicnt.0
(1) We believe that the primary and secondary impacts to fish and wildlife
resources from the proposed sewerage system (Willow Creek lagoons) will
be minimal. In terms of primary impacts, the areas that will be served
by collection lines (also the areas where "new" growth will tend to locate)
are already developed and thus any loss of "critical" elk, deer, etc.,
habitat to development has already occurred. The wildlife species currently
using these developed areas for habitat would be ones adapted to human
presence and should not be qredtlv effected bv a moderate amount of qrowth
as is expected (see resuorise to Colorado uivision of Hlannind for a discus-
sion ot expected yruwu pacLb;. me layoon site is located in an area
classified as "general" deer winter range. Though approximately 30 acres
of land in this category would be lost to the lagoons and associated struc-
tures, this is a very small percentage of the total land in the general area
under such classification. Operation and maintenance of the lagoons would
present a minimum of human activity, especially in the winter, and should be
of little impact to wintering deer.
Primary impacts on fisheries should be minimal (See letter from Colorado
Division of Wildlife). One primary reason for recommending the Willow
Creek Lagoon site is that this system would eliminate sewage effluent dis-
charge to the lakes (except for the two proposed small neighborhood units).
This will be a definite benefit to the lakes' fishery resource.
The Willow Creek lagoons are also considered advantageous because the
effluent they discharge during the peak use warm months will be applied to
hay meadows. This arrangement, in effect, adds a "land treatment" component
to the system and thus provide additional reductions of nitrogen, phosphorus,
total suspended solids, and BOD.
Secondary impacts from the proposed system are much more difficult to
anticipate. In our opinion, the basic secondary impact from the proposal
would be that related to any possible generation of growth and additional
population in the Three Lakes area. Again, these matters are discussed at
length in our response to the Colorado Division of Planning letter, but,
in summary, we do not believe that the system by itself will lead to any
extreme amount of new growth. The growth that will occur should be control-
led by Grand County. At the same time, we believe the proposed system will
have definite value in concentrating future area growth in the sewer service
area and thus tend to hold down more random and dispersed type development.
2. The Three Lakes Water and Sanitation District is responsible for
negotiation and final settlement for use of any land needed for their sewer-
age system. These matters must be finalized before EPA approves construction
funds
3. Money has been allocated in the Three Lakes Facility Plan for improve-
ments to the Red Top Valley Ditch. The necessary rights-of-ways must be
obtained before proceeding to the construction phase of the project
141
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4. The final layout of the road will be part of Step II (design and
specifications) of the sewage treatment planning and construction process.
Any necessary road changes can be made at this time and as part of the
Three Lakes Water and Sanitation District's necessary compliance with
BLM regulations.
5. Based on a peak summer effluent flow of 1.34 mgd (2.0 cfs) a
maximum effluent NOaN concentration of 30 mg/1, a 3 month application
period, and 900 acres of irrigated hay meadow, the maximum application of
NOsN would be 33 pounds/acre-year. From communications with Burn Sabe,
CSU Agriculture Department, this is a very low rate of application. At this
loading rate, it is very likely that all applied NOa will be taken up by
the crop Irrigated. CSU's experience at Hayden, Colorado, indicated
that at a loading rate of 50 pounds/acre-year there was no noticeable
increase in groundwater NOsN concentrations. Because the wastewater treated
is domestic in nature, no other constituent in the effluent should present
any adverse impact to groundwater supplies, (data supplied by Three Lakes
District's consultants, NHPQ).
6. As we have stated numerous times, EPA will not approve the construction
of the Three Lakes sewerage project until the water rights Issue 1s resolved.
The draft EIS did, however, Incorrectly state that this resolution must take
place before Step II of EPA's construction grant process. Because Step II
will begin as soon as funding is approved for the project -- the same time
frame during which the final resolution of the water rights issue must be
completed — the issue must be resolved before proceeding to Step III
(construction). The use of the beginning of the Step III phase for resolution
of water rights problems allows the Step II (design and specifications) phase
to be used to work out the specifics of the resolution.
7. No comment necessary.
8. No comment necessary.
9. The cultural resources survey was conducted by Gordon and Kranzush-Archaeo-
loglcal Consultants, Boulder, Colorado. Gordon and Kranzush is a firm
approved by the State Archaeologist and 1s one with wide experience in
this type work.
Gordon and Kranzush performed a 100% survey of the proposed sewer
Interceptor route, the Willow Creek lagoon site, and the two small treatment
plant sites. The report from this survey has been submitted to and has
gained approval from, the State Historic Preservation officer and the State
Archaeologist. The abstract from this report is attached.
EPA was adlvsed not to publish the full text of the report because of
the possibility that it might be used by "pot hunters" to locate some
142
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potentially significant archaeological resources which were discovered.
EPA will require the Three Lakes Water and Sanitation District to meet
the stipulations as discussed in the abstract, i.e., archaeologist on
the scene during construction and complete "testing" of the other site.
EPA also requries a "stop work" and recovery if necessary, profes-
sional evaluation type procedure if cultural resources are found during
any of the proposed construction activity. The above procedures will be
in keeping with Section 800.4 and 800.5 of the Procedures For The Protection
of Historic and Cultural Properties (36 CFR 800~T
10. We have met with the Office of the State Historic Preservation Officer
who concluded that no National Register Sites or potential sites (i.e.
Town of Grand Lake) would be affected by the proposed project. Their
letter 1s attached.
11. Statements about the discharge of the two proposed neighborhood treat-
ment units has been added to the Introduction and Summary of the EIS. More
complete discussion of these units is found on pages VI-32, VIII-2 thru VIII-5,
and 6-1 through 6-3 of the Facility Plan which is part of the EIS.
12. The draft EIS incorrectly gave the impression that the NPS facility
was "polluting." The final EIS has been corrected.
13. Clarification noted.
14. EPA's objection to the original regional sewerage system as related
to potential growth impacts was that local government (Grand County) was
in no position to control non-point pollution that might arise from develop-
mental activity. We also questioned the financial feasibility of a system
that depended on the addition of 80 new taps a year.
We do not believe that the proposed sewerage system will be a major
growth "generator" though it will release a certain amount of presently
pent-up growth demand in the Three Lakes area (see our response to the
State Division of Planning for a more complete discussion on this topic.)
The important point about the whole project is that Grand County has agreed
to enact non-point pollution controls (see letters in appendix of Facility
Plan, sections in EIS on this subject, and response to State Division of
Planning). This is the reason EPA's former objections to any centralized
sewerage system in the area has been mitigated.
For purposes of financial feasibility analysis NHPQ, consultant's to the
Sanitation District, used figures of 20 and 40 additional taps per year (page
VII-9 through VII-12 of Facility Plan). This analysis revealed that the
District could afford the proposed system if only 20 new taps were added per
year. Twenty taps is approximately the current growth rate in the area and is
well within Grand County's planning projections.
143
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15. We have met with the National Park Service on numerous occasions in an
attempt to not approve a sewerage system that 1s Incompatible with the
existing or proposed NRA. One very difficult aspect of the NRA question
is that no specific NRA land use plan has been developed other than that
first appearing 1n the NPS draft EIS on this subject several years ago.
Though we believe 1t 1s unfortunate that the NRA proposal has not been
finalized, we believe that the continued sub-standard effluent discharge of
the Grand Lake treatment plant, probable continued septic tank pollution,
and an ever lengthening time factor make 1t necessary for EPA and the District
to move forward with a plan for sewage treatment for the area.
Our analysis of the proposed sewerage system leads us to believe that
1t would not be detrimental to fish and wildlife resources. This belief
is based on the fact that the system will (1) eliminate presently poorly
treated sewage to the lakes; (2) eliminate the majority of future effluent
discharge to the lakes; (3) serve basically areas that are already developed
and; (4) tend to concentrate the growth that will occur 1n the area as op-
posed to more random development dependent on septic tanks. We should also
point out that the COMARC analysis performed for Grand County and EPA found
np__w1ldlife impacts due to sewering the areas proposed for service (this
analysls'was based' on the area's resident big-game species).
As stated 1n numerous places in the EIS, we will not approve service
to Area "L" (southwest shore of Lake Granby) until the NRA issue can be
worked out. It has always been our understanding that prevention of
development 1n this area was a priority with the Park Service. Sunset Point
service is to be via a separate "neighborhood" treatment plant and not by
sewer line connecting to the central Willow Creek lagoon system. No right-
of-way to Sunset Point 1s thus required.
With the elimination of service to Area "L" (at least until the NRA
issue is resolved) we do not believe there are any major incompatibilities
with the NRA. The argument 1s still valid, however, that if some of the
lakeside trailer court developments such as along Shadow Mountain Reservoir
are sewered that might be considered for later NRA purchase, the cost would
be higher than if they are not sewered. Quite frankly, our'only conclusion
about this possibility is that the Park Service should approach the Sanitation
District about not Initially serving these developments until the NRA issue
is resolved. EPA will not fund actual service to these areas but will fund
75% of the major Interceptor to which they would connect. Because of the
definite advantages of the Willow Creek lagoon system, we are faced with an
Interceptor sewer running along the west side of Shadow Mountain Reservor and
NW shore of Lake Granby. Future control of growth 1n these areas will be a
function of Grand County and the Federal agencies Involved.
16. The Facilities Plan was considered part of the draft EIS and in all cases
accompanied the EIS when 1t went out for public review.
144
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17. The category of ownership left out was water which totaled 17% of
the COMARC analysis area.
18. Though the COMARC study did not specifically develop a visual vulner-
ability map EPA has given full recognition to the possible aesthetic impacts
of the various sewerage system proposals throughout our deliberations on
the Three Lakes project. Specific concerns related to the aesthetic impact
issue have been centered around issues such as: sewer service to Area "L";
location of sewage treatment facilities below Lake Granby at the original
proposed site; location of a treatment facility on the northwest shore of
Lake Granby (near BuRec pumps); location of sewage lagoons in the open
meadows area west of the northwest shore of Lake Granby; the location of the
Willow Creek lagoons; sewage collection barges operating on the lakes;
accelerated sedimentation and enrichment of the lakes; etc. Because of our
concern for these matters, we believe the Willow Creek lagoons, coupled with
Grand County's commitment to improved land use regulation, has a solid
aesthetic and visual protection oasis.
As stated in the EIS, EPA will not participate in funding for service
to Area "L" until the NRA issue is resolved. Area "K" has a large amount of
present development and we see no reason why "several nonconforming obtrusive
commercial developments" could not be acquired before, or even after, con-
struction of any sewer system.
Concerning Area "M", we have not been aware of any conflict between
NRA objectives and the proposed sewerage system until receipt of Department
of Interior comments on the draft EIS. Since this area is proposed to be
served by a small neighborhood treatment unit which is a logical component
of the entire system that could be "phased" or built at a later date (as
suggested in the EIS) we would suggest the National Park Service approach
the Three Lakes Water and Sanitation District on this subject. The District
may well not have sufficient funds for this component anyway and could be
receptive to deleting it until the NRA issue is resolved.
It is not correct that EPA has not considered the erosion hazards of
lands outside the specific interceptor route. The erosion control regulations
agreed to by Grand County apply to all private lands in the area, not just
those that will be sewered. Also, the COMARC analysis covered the whole area,
not just the land to be sewered. Though our discussion of the NRA issue is
basically related to the potential for the sewer lines to allow development
in areas the Park Service would prefer to leave undeveloped, the whole thrust
of this project has been oriented to controlling the degradation of the
NRA's basic resource, i.e., the water quality of the Three Lakes.
19. EPA has rejected the use of vacuum lines in the lakes. Vacuum lines
will not be part of the sewerage system.
145
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20. The summary of COMARC's analysis appears 1n the form of numerous large
maps, computer printouts, and an overview of the COMARC process type docu-
ment. These materials do not lend themselves to Inclusion 1n an EIS and
would, 1n EPA's opinion, only add bulk to an already too large set of docu-
ments. These documents can be reviewed at the Department of Development,
Grand County, Hot Sulphur Springs.
COMARC analyzed the wildlife Impacts of the proposed system at each
alternative treatment plant site. The categories of wildlife analyzed are
shown on the attachment (from COMARC's Summary Report and Map Directory
for the Three Lakes project). The conclusions were:
(a) Treatment Plant Site for Alternate No. 3 - (not analyzed because
this system was rejected for other reasons).
(b) Treatment Plant Site for Alternate No. 4 (Willow Creek lagoons) -
Deer general winter range - 33.1 acres lost for this use.
(c) Treatment Plant Site *or Alternate No. 5 (North Shore Plant) -
no Impact.
(d) Treatment Plant Site for Alternate No. 6 (Stlllwater Creek lagoons) •
Deer general winter range - 29.4 acres lost for this use.
21. The Colorado Division of Wildlife reports that the North Fork Colorado
contains Brown, Brook, and some Rainbow trout. They are not, however, con-
ducting creel census work at this time. Also, the North Fork is generally
a dry stream from its confluence with Shadow Mountain Reservoir to the
Red Top Valley Ditch diversion several miles upstream.
No Information exists on the aquatic resources of the Red Top Valley
Ditch nor the "unnamed" tributary. The Ditch could not be considered any
type of valuable fishery because of Its very nature and flow regime. The
"unnamed" tributary is on private land and has not been studied by the
Division of Wildlife.
22. No comment necessary.
23. This statement has been corrected in the EIS (see comment #12).
24. See comment #20.
25. The entire volume of treated effluent will not be utilized for irrigation.
Discharges used for Irrigation will occur between mid-May and mid-August.
However, this three-month period accounts for nearly two-thirds of the annual
wasteloads generated in the study area.
An analysis of the Willow Creek discharge similar to the one done for
the Sun Valley Ranch has been difficult because of a lack of data. The
Colorado Water Quality Control Division (see letter in Appendix A-Fac1l1ty
146
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Plan) has concluded, based on what is known, that the Impact on the Willow
Creek drainage will be minimal primarily due to the intermittent nature of
the stream. They also concluded that the impact on the Colorado River would
be slight due to the dilution factor and the travel time down Willow Creek
before reaching the river.
Some of the major considerations leading to EPA's, and other's,
decision to recommend the Willow Creek lagoon alternative were: (1) it would
end major effluent discharge into the area's principle fishery resource,
i.e., the lakes; (2) would avoid discharge to the Stillwater Creek fishery
and subsequently the lakes; (3) would provide land treatment of effluent
during the high sewage load summer season, and; (4) would discharge into
an intermittent stream with less fisheries value. Though we do not believe
the impact on Willow Creek will be major, there will probably be some long-
term impact. This impact is considered an acceptable trade-off for the
benefits to be gained from this sewerage system. We would also make reference
to the letter from the Colorado Division of Wildlife contained in this
section of the EIS.
In terms of the proposed Sunset Point discharge it should be pointed
out that the data does not exist which definitely points out the benefits
of taking the major discharge (that which would be treated by the Willow
Creek lagoons) out of the lakes. In other words, EPA and others are follow-
ing their professional judgments and experiences in recommending that the
discharge go to Willow Creek. Quite frankly, the water quality standards
of the State of Colorado would allow secondary level treated effluent to
continue to be discharged to the Lakes. As stated, we do not believe this
would be in the best long-term interest of the quality of these bodies of
water.
The Sunset Point discharge would be quite small and would be into a
very large body of receiving water. This dilution factor plus the fact
that the discharge would be properly treated effluent lead us to believe
that the discharge would have little impact. It is also a fact that because
present water quality standards would allow the larger 1.34 MGD plant to
discharge to the lakes the small Sunset Point unit (0.020 MGD) should be
acceptable
26. NHPQ, the District's consultants, believe that with proper detention
time in the lagoons, chlorination should not be necessary. The State Health
Department will review the plans and specifications on this project and,
at that time, judge whether or not they agree with NHPQ's conclusion. If
the State believes chlorination is necessary, they can also require a de-
chlorination step in the treatment process if 1t is found that the chlorine
would harm the fisheries resource.
147
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Abstract
On July 5 and 7» 1977| surface reconnaissance for location and evaluation
of cultural resources was conducted by Gordon and Kranzush - Archaeological
Consultants for the Environmental Protection Agency - Region VIII under Purchase
Order Numbers WO-7-0/(.55~A and WO-7-0455-A-1 in four proposed sewage treatment
facility project areas for the Three Lakes Water and Sanitation District, Grand
Countyf'Colorado. Evidence of cultural activity includes recent debris, one
historic component in a trash pit, prehistoric sites 5 GA162 and 163, and Lo-
cality #2. The significance of these finds and the nature of the impact that
would result from implementation of the proposed actions are assessed in the
section of this report entitled "Tnterpretations of Data and Impact Assessment".
None of the resources located, with the possible exception of 5 GA162, is eligi-
ble for nomination to the National Register of Historic Places.
Professional archaeological monitoring of ground disturbing activities is
recommended for the 5 GA163 and Locality #2 area, and testing of 5 GA162 is
recommended to determine the depth of cultural deposits and assess eligibility
for nomination to the National Register of Historic Places. .These recommendations
and others are discussed in the section of this report entitled "Conclusions and
Recommendations".
148
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undertaken by the Colorado State Forest Service. All
information was supplied on the four U.S.G.S. 7.5' quadrangles
encompassing the study area.
Label # of Area
# Name Cells (Acres)
0 Water 2181 8011
1 Low Hazard 3911 14365
2 Medium Hazard 253 929
3 High Hazard 5109 18766
4 No Data 1058 3886
3.12 Wildlife
Contained on the four U.S.G.S. 7.5' quadrangles covering
the study area, all information was mapped by the Regional
Resources Planning Program (Colorado State University, 1975),
It should be noted that where wildlife habitats overlapped,
unique labels were given to show the composite areas.
Label # of Area
* Name Cells (Acresj
0 Water 2181 8011
1 Deer - general
winter range 438 1609
3 Elk - critical
winter range 1225 4500
4 Elk - calving
grounds 808 2968
6 Raptor - nesting
sites 4 15
22
149
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Label # of Area I of
__# Name Cells (Acres) Site
7 An overlapping
coverage of Elk
critical winter range
'and Elk calving grounds 12 44 .10
8 An overlapping
coverage of Deer winter
range and Elk critical
winter range 3 11 .02
9 A triple overlapping
area of Deer general
winter range and Elk
critical winter range
§ Elk calving grounds 94 345 .75
10 No Data 7747 28455 61.92
3.13 Proposed Wastewater Collection and Treatment Facilities
Provided to Comarc by Nelson, Haley, Patterson and Quirk, Inc.
(NHPQ) at a scale of 1:30,000, this map showed the location
of three proposed alternative wastewater facilities and
associated collector and interceptor lines.
Label # of Area I of
# Name Cells (Acres) Site
0 Water 2181 8011 17.43
1 Proposed Common
Interceptor Lines 120 441 .96
2 Collection Lines -
Neighborhood A 20 73 .16
3 Collection Lines -
Neighborhood B 8 29 .06
4 Collection Lines - 150
Neighborhood C 15 55 .12
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STATE OF COLORADO
Richard D. Lamm, Governor
DEPARTMENT OF NATURAL RESOURCES
DIVISION OF WILDLIFE
Jack R. Grleb. Director
6O6O Broadway
Denver, Colorado 8O216 (825-1192)
November 17, 1977
TO:
FROM:
SUBJECT
Philip H. Schmuck, Director
Colorado Clearinghouse
/
ector
of Wildlife
RECEIVED
NOV 2 51977
DIV. OF PLANNING
imental Impact Statement Review, Three
..akes Wastewater Treatment Facilities
We have reviewed both the Draft Environmental Statement prepared by
the Environmental Protection Agency and the Facilities plan prepared by
the Environmental Consultants which covers their proposal. We just
recently received the Review of the Land Use Laws Related to Water
Quality Protection by White and Burke but have not reviewed this
publication. The primary concerns of this Division, as always, is
how the several proposals may affect or enhance fish and wildlife habitat.
This is a popular recreation area so we favor the alternatives that best
protect water quality and will not accelerate eutrophication in the three
lakes. Grand Lake, Granby and Shadow Mountain Reservoir. Impacts
on wildlife habitat appear to be tolerable as the actual habitat losses will
not be great and migration routes should not be blocked under present
plans. Better land use controls by Grand County should help control both
growth and erosion thus eliminating many of the nonpoint sources of
pollution that eventually find their way to the lakes. Apparently, the
question of water rights has or can be solved. A central system should
help eliminate further, possible pollution from septic tanks or at least
reduce the number of new tanks that will be constructed.
The Willow Creek alternative appears to be the best choice from the fish
and wildlife point of view as the discharge would be on hay meadows and
not into a lake or stream.
Overall, the statement appears to be inclusive and objective. No mention
is made of any possible impacts on the Colorado River below Granby
Reservoir. Apparently no impacts are visualized.
We appreciate being given the opportunity to review and comment on the
statement.
JRGrcs
cc: H. Sherman 151
P. Olson
DEPARTMENT OF NATURAL RESOURCES Harris Sherman. Executive Director . WILDUFE COMM.SS.ON. Thomas Farley, Chairman
Sim Caudill. Vice Chairman • Roger Clark. Secretary . Jean K. Tool, M-«W , ,,, . '
Jay K. Childress, Member • Michael Higbee. Member '•
-------
Response to State Division of Wildlife
No comment necessary.
152
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COLORADO DEPARTMENT OF HEALTH
421O E. 11TH A/ENUE DENVER BO22O PHOME 388-6111 EXT. 323
ANTHONY ROBBINS. M.D..M.P.A. EXECUTIVE DIRECTOR
DATE: November 15, 1977
SUBJECT: NON-STATE ASSISTANCE
REVIEW AND COMMENTS "Pr"l|/p«
TO: Phil Schmuck ^16]S77
Division of Planning '
Dept of Local Affairs DIV. OF FLASHING
TO: NA
PROJECT TITLE: DEIS AND FEIS Wastewater Treatment Facilities for
Three Lakes, Colorado
STATE IDENTIFIER: #77-129
COMMENTS DUE BY: 11/18
Yes[T] No | | Is this project consistent with the goals an
objectives of this agency?
Yes| I No |X I Is there evidence of overlapping of duplica-
tion with other agencies?
Yes| I No |X | Is meeting desired with applicant?
No ) [ A 15-day extension Is requested.
Cornmen ts :
SOC-3, Feb 77
.
Name, Title £ Phone
Ron Simsick, Program Administrator
ATTACHMENT B
153
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Response to Colorado Department of Health
No comment necessary.
154
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GRAND
COUNTY
HERBERT A. RITSCHARD. Chairman
District III, Kremmling 80459
ELWIN E. CRABTREE
District II, Granby 80446
JOHN E. MARTLING
District I, Fraser 80442
BOARD OF COMMISSIONERS
COURT HOUSE. HOT SULPHUR SPRINGS, COLORADO 80451
PHONE: 303-725-3332
S. R. (STAN) BROOME
County Manager
December 9, 1977
Environmental Protection Agency, Region VIII
1860 Lincoln
Denver, Colorado
Dear Sir:
Grand County has reviewed the draft environmental impact statement of
Wastewater Treatment Facilities for Three Lakes.
Grand County supports the selected alternative referenced as the Willow
Creek Lagoon.
Grand County would note that positive action is presently in progress
concerning more effective control of non-point source pollution through
the development of a comprehensive land use plan using innovative planning
methods as pointed out in the draft environmental impact statement. In
addition, the suggestions contained in the White and Burke regulatory
review, which were promulgated in cooperation with EPA, are being used
as guidelines for this effort.
Sincerely,
Herbert A. Ritschard
Chairman
HAR/jh
155
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Response to Grand County
No comment necessary.
156
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REGION XII
NORTH WEST COLORADO COUNCIL OF GOVERNMENTS
Holiday Center Building - Suite 200
P. O. BOX 73f
FRISCO, COLORADO 80443
(303) 468-5445
EAGLE COUNTY
BASALT
EAGLE
GYPSUM
MINTURN
REDCLIFF
VAIL
GRAND COUNTY
FRASER
GRANBY
GRAND LAKE
HOT SULPHUR SPRINGS
KREMMLING
JACKSON COUNTY
WALDEN
PITKIN COUNTY
ASPEN
ROUTT COUNTY
HAYDEN
OAK CREEK
STEAMBOAT SPRINGS
YAM PA
SUMMIT COUNTY
BLUE RIVER
BRECKENRIDGE
DILLON
FRISCO
SILVERTHORNE
(D
(2)
December 9, 1977
Mr. Allan Merson, Regional Administrator
Environmental Protection Agency
1860 Lincoln St., Suite 105
Denver, Colorado 80202
Re: Three Lakes Draft Environmental
Impact Statement
Dear Mr. Merson:
Thank you for the opportunity to review the subject
Environmental Impact Statement. I apologize for our delay
in transmitting comments regarding the proposed project.
As you are aware, the NWCOOG has been involved with
the Three Lakes Area in our role of developing a 208 Water
Quality Management Plan for Planning and Management Region
12. Our primary concern has been with identification and
control of non-point source pollutants arising from land
development and other land use activities tributary to the
lakes. We feel that the DEIS, along with the recomnendations
of the 208 Plan (to be released in January, 1978), will ad-
equately mitigate the effects of these activities associated
with the proposed wastewater treatment facilities. The
efforts of EPA and Grand County in this area are conmendable
and should set an example for cooperation throughout Colorado.
The level of treatment, service area and population pro-
jections developed for the facility are three other concerns
which the 208 Program has regarding facility plans within the
designated area.
Level of Treatment
As noted in the DEIS, the proposed alternative eliminates
the need for discharge of treated effluent to the lakes at
present. No advanced waste treatment requirements are there-
fore proposed for the reconmended alternative. This is com-
patible with the recomnendations of the 208 Areawide Plan.
However, it should be noted that with future water resource
157
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Allan Merson, EPA
December 9, 1977
Page 2
developments (i.e. Windy Gap Project) nutrients from the
wastewater discharge, as well as, other discharges to the
Eraser River drainage could be cycled back to the Three
Lakes, thereby frustrating the District's goal of elimin-
ating waste discharges to the lakes.
The Draft 208 Plan recognizes this future possibility
and would require a permit to be issued by Grand County for
any future water diversion project, specifying how the app-
licant would mitigate the adverse water quality effects of
such a water diversion project.
Population Projections
The design population planned to be serviced by the
proposed facility appears to be in agreement with Grand
County's projections used in the development of desired
growth distributions utilizing the CCMRC System.
Service Area
The service area for the proposed facility appears to
be compatible with Grand County's preliminary land use
planning efforts.
Thank you again for the opportunity to comment on the
proposed facilities.
Sincerely,
Phil Overeynder^
208 Coordinator
P0:vg
158
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Response to Northwest Colorado Council of Governments
1. No comment necessary.
2. We have long recognized that the proposed Windy Gap project could
serve to recycle nutrients back to the lakes. If this project is con-
structed, the Willow Creek lagoon system would have the benefit of land
treatment for the high sewage load summer season thus lessening the poten-
tial impact of "recycling" of nutrients.
159
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Department of Local Affairs
Colorado Division of Planning
Philip H. Schmuck, Director
Richard D. Lamm, Governor
November 22, 1977
Mr. Alan Merson
Regional Administrator
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80202
SUBJECT:
Dear Mr. Merson:
Draft Environmental Impact Statement
Three Lakes Wastewater Treatment Facilities
The Colorado Clearinghouse distributed copies of the above-referenced
environmental impact statement to relevant state agencies. Enclosed
please find the comments of those agencies.
In addition to the written comments enclosed, some agencies made oral
comments to the Clearinghouse indicating that they found merit in the
statement at the top of page 7 of the EIS that "there is no need to
serve everyone in the district with a centralized collection system,
especially those outlying developments where expense and environmental
considerations argue against it." If the district largely confined ser-
vice to presently highly populated areas and refrained from extending
collector lines to undeveloped or low density areas, it would assist in
mitigating growth impacts due to service line extensions. Some flexibility
then seems appropriate in the district's service plans. This would support
the contention that septic systems could continue to be used on a limited
basis in outlying and sparsely populated areas. It would also cut down on
costs of extending collector lines to remote areas with few residents and
correspondingly few tap fees.
Thank you for the opportunity to review this proposal.
Very truly yours,
Charles G. Jordan
Senior Planner
Reviewed:
Philip Jfl Schmuck,' Director
CGJ/vt - Enclosures
<-r"- See attached list
160
1313 Sherman Street, Denver, Colorado 80203 (303) 892-2351
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Mr. Alan Merson
Re: Three Lakes DEIS
November 22, 1977
cc: Office of the Governor
Department of Local Affairs
Department of Natural Resources
Department of Health
Department of Highways
Northwest Colorado Council of Governments
161
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Response to Comments by the
Department of Local Affiars
Colorado Division of Planning
The proposed sewerage system is designed to serve only those areas
within the boundaries of the Three Lakes Water and Sanitation District
which presently are areas of relatively high density development. The
neighborhood areas and associated existing/future PE (population equiva-
lents) are:
Area "A" - South Shore Grand Lake - 173/195 (1976 PE/Year 2000 PE)
Area "B" - North Shore Grand Lake - 50/75
Area "C" - Greater Town of Grand Lake - 8£?5/2300
Area "D" - Greater Columbine Lake - 603/1945
Area "E" - Sun Valley Ranch - 137/160
Area "F" - Shadow Mtn. Reservoir Shoreline - 51/75
Area "G" - West Shadow Mtn. Reservoir - 694/950
Area "H" - No. Fork Colo. R and NPS Hdq. - 370/800
Area "I" - Interlakes Area - 420/930
Area "J" - No. Shore Lake Granby - 534/2550
Area "K" - NW Shore Lake Granby - 332/2410
Area "L" - SW Shore Lake Granby - 220/600
Area "If - Sunset Point - 49/390 (See page VI-7 and VI-8 in Three
Lakes Facility Plan).
As we point out in the EIS, EPA will not approve service to Area "L"
until the National Recreation Area situation can be resolved between the
National Park Service and Grand County. Also, we have urged the Board of
Directors of the Sanitation District to consider phasing the proposed sys-
tem (especially as related to the two small separate neighborhood treat-
ment units) until they have acquired sufficient funding.
162
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There is no Intention of serving sparse or undeveloped areas, though
the general nature of development in the area, i.e. "clusters" of develop-
ment result in the interceptor sewer line traversing areas of relatively
light development. A fairly large amount of these undeveloped areas are,
however, in Federal ownership and thus not subject to development. Pos-
sible development of the areas in private ownership will be subject to
Grand County land use regulation (the sewer lines are compatible with
Grand County land use plans - see comment letter from Grand County). As
we discuss at length in response to Mr. Naseth's letter (comment letter
#2 which follows your letter and this response) Grand County has made
significant strides toward revision and improvement in its land use plann-
ing and control functions.
Septic systems will continue to be used in outlying and sparsely
populated areas after the proposed sewerage system is built. The actual
boundaries of the Three Lakes Water and Sanitation District encompass a great
deal more land area and a considerable amount of existing and possible
development than is proposed to be served by sewers. The cost of serving
these type areas with central sewers tends to preclude this type sewage
collection, unless, of course, some private developer were to generate the
necessary capital to meet the costs.
Two major hurdles that have to be faced in designing a sewerage system
for the Three Lakes area are (1) the need to avoid discharge of effluent
to the lakes and (2) the present pattern of development. The system, as
163
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3
proposed, has attempted to meet these problems by (1) serving the major
clusters of development and (2) placing the treatment plant discharge at
the most logical location in relation to these clusters and, at the same
time, discharging away from the lakes themselves.
164
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COIDRADO
HISTORICAL
SOCIETY
The Colorado Heritage Center 1300 Broadway Denver, Colorado 80203
Office of the State Archaeologist 839-3391
November 28, 1977
Mr. Philip H. Schmuck RECEIVED
Department of Local Affairs .|n.
Colorado Division of Planning NUV t, 8 19/7
520 State Centennial Building
1313 Sherman DIV. OF Fl^'f'V!
Denver, CO 80203
RE: Draft Environmental Impact Statement and the Final Wastewater
Treatment Facilities Plan, the Three Lakes Water and Sanitation
District; and the Cultural Resource Inventory Report, Three
Lakes Water and Sanitation District, submitted as a supple-
mental report with the Final Plan: Archaeological Resources
Dear Mr. Schmuck:
The Office of the State Archaeologist of Colorado has received
and reviewed the Draft Environmental Impact Statement and the Final
Wastewater Treatment Facilities Plan, Three Lakes Water and
Sanitation District; and the Cultural Resource Inventory Report,
Neighborhood Treatment Plant Site "E:, Neighborhood Treatment Plant
Site "M," Lagoon Site, Sewage Interceptor Route, Three Lakes Water
and Sanitation District, requested by U.S. Environmental Protection
Agency—Region VIII. (The State Historical Society's Department of
Historic Preservation will independently comment upon architectural/
historical resources.)
I_. Our comments on the Cultural Resources Inventory Report prepared
and submitted by E. Kinzie Gordon and Kris J. Kranzush are as follows^
The report is excellent in regard to the adequacy of the
"Description of the Study Area," "Inventory Methodology," and "Known
Cultural Resources." However, there are areas of inconsistency that
should be clarified:
(1) Abstract: A reference to sites 5GA164, 5GA165, and "Locality
No. 1" (referred to on p. 11) should be included in the Abstract.
(2) P. 11: Mention is made of sites 5GA164, 5GA165, and "Localit
165
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Mr. Philip H. Schmuck
November 28, 1977
Page 2
No. 1," but it should be stated, as shown on the map in Appendix B,
that these sites are not within the area of direct impact. Also,
will there be any adverse impact on these archaeological resources?
(3) P- 17, par. 1: The recommendation was made to avoid site
5GA164. What are the recommendations for 5GA165 and "Locality No. 1"?
(4) Appendix A, Catalogue and Analysis—Lithic. The same problem
exists: site 5GA164 and 5GA165 should be included in this Appendix.
(5) Glossary: A definition for "Locality"was included in the
Glossary, but why are the "Localities" not considered by the authors
to be sites? Perhaps there can be a clarification in this matter,
but ordinarily a locality would have a site number and form.
C6) There are no Site Inventory Records for sites 5GA164 and
5GA165. If proper safeguards exist, these could have been included in
the report; at any rate, the forms must be sent to the State
Archaeologist.
(According to phone consultation by Gordon and Kranzush, Archae-
ological Consultants, a supplemental report will be submitted directly
to this Office that will clarify these above comments.)
II. The Federal Agency involved in the Draft Environmental Impact
Statement and the Final Wastewater Treatment Facilities Plan has not
adequately considered archaeological resources in the proposed impact
area.
Why did the Federal agency request a cultural resource inventory
and not incorporate the information supplied by Gordon and Kranzush
in the Draft EIS or the Final Plan? None of the archaeological
resources identified and evaluated by Gordon and Kranzush were included
in the reports, nor were the mitigation measures for these resources
considered.
The archaeological resources that are listed on Table IV-7, and
located on Figure IV-16 have not been properly evaluated by the criteria
set forth in 36 CFR 800.10, nor have plans been made for avoidance or
mitigation of Adverse Effect upon these resources according to 36 CFR
800.5 (e) and (f) .
Therefore, the Federal agency has not complied with the Federal
legislation pertaining to cultural resources as set forth in the
National Historic Preservation Act, implemented by 36 CFR 800, and
Executive Order 11593.
166
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Mr. Philip H. Schmuck
November 28, 1977
Page 3
If this Office can be of continued assistance, please contact
EIS Reviewer Betty LeFree.
For the—Starts—Historic
Bruce E.
State ArchaeoJ/cftlLst Colorado
BERCBJL) :ng
cc: Gordon and Kranzush
Nelson, Haley, Patterson and Quirk, Environmental Consultants
167
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Response to State Archaeologist
Though EPA funded a complete cultural resources survey of the Three
Lakes sewerage project (including each principle alternative) we did
not correctly convey this fact in the draft EIS. Because cultural resources
were found EPA also incorrectly failed to explain the steps that will be
taken to protect these resources in compliance with Federal law. A meet-
ing between EPA and the State Archaeologist's office has taken place and
the following paragraphs and attachment explain the results.
EPA will follow the recommendations contained in the cultural survey
done by Gordon and Kranzush -- Archaeological Consultants (see attached
abstract from that report). This will entail requiring the Three Lakes
Water and Sanitation District to have a qualified archaeologist on site
during the initial lagoon construction activity (5GA162 and Locality #2
area.) It will also require further testing of the 5GA162 site.
If subsurface archaeological resources are Identified by encounter
during construction of any part of the project, work will stop until the
resources are properly evaluated in terms of the National Register of
Historic Places eligibility criteria (36 CFR 800.10). Adverse impacts
upon eligible resources will have plans for avoidance or mitigation (36
CFR 800.5(e) and (f). Both considerations will involve consultation with
the State Archaeologist.
168
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Abstract
On July 5 and 7i 1977» surface reconnaissance for location and evaluation
of cultural resources was conducted by Gordon and Kranzush - Archaeological
Consultants for the Environmental Protection Agency - Region VIII under Purchase
Order Numbers WO-7-Q/v55-A and V/0-7-OA.55-A-1 in four proposed sewage treatment
facility project areas for the Three Lakes Water and Sanitation Distiict, Grand
County,'Colorado. Evidence of cultural activity includes recent debris, one
historic component in a trash pit, prehistoric sites 5 GA162 and l63> and Lo-
cality ff2. The significance of these finds and the nature of the impact that
would result from implementation of the proposed actions are assessed in the
section of this report entitled "Interpretations of Data and Impact Assessment".
None of the resources located, with the possible exception of 5 GA162, is eligi-
ble for nomination to the National Register of Historic Places.
Professional archaeological monitoring of ground disturbing activities is
recommended for the 5 GA163 and Locality #2 area, and testing of 5 GA162 is
recommended to determine the depth of cultural deposits and assess eligibility
for nomination to the National Register of Historic Places. .These recommendations
and others are discussed in the section of this report entitled "Conclusions and
Recommendations".
169
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THE STATE HISTORICAL SOCIETY OF COLORADO
Colorado State Museum, 1300 Broadway, Denver, Colorado 80203
October 27, 1977
RECEIVED
Philip H. Schmuck WO'/ g
Director
State Clearinghouse CIV. OF
520 State Centennial Building
1313 Sherman Street
Denver, Colorado 80203
RE: Three Lakes Wastewater Treatment Facilities
Dear Mr. Schmuck:
This office shall comment concerning only architectural
and historical properties that may be located within the
potential environmental impact area of this undertaking;
the office of the State Archaeologist will comment con-
cerning archaeological properties.
It is our understanding that compliance with the environ-
mental impact requirements of Section 201 (2)(C) of the
National Environmental Policy Act and regulations there-
under should include compliance with Section 106 of the
National Historic Preservation Act of 1966, as amended,
and Executive Order 11593. This statement is incomplete
in that it does not contain evidence of such compliance
nor does it contain provisions to insure future compliance
We note that in the Facilities Plan prepared by the firm
of Nelson, Haley, Patterson, and Quirk, numerous histor-
ical properties are identified in the impact area of the
project. It appears, however, that these sites have been
excerpted from the Colorado Inventory of Historic Sites,
the record of an ongoing survey conducted by the state
which is incomplete for this area. Thus, it appears that
the Environmental Protection Agency (EPA) has not ful-
filled its responsibility to identify all properties in-
cluded in or eligible for inclusion in the National Reg-
ister of Historic Places as required by the Advisory
Council on Historic Preservation's regulation 36 CFR
Part 800.4 (a).
170
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Philip H. Schmuck
Page 2
We also note that the EPA has not consulted with the
State Historic Preservation Officer (SHPO) to evalu-
ate the eligibility for inclusion in the National
Register of the few properties that have been identi-
fied. Further, there is no evidence that the EPA has
evaluated the effects upon eligible properties or de-
veloped feasible mitigation for their effects in ac-
cordance with the procedures set forth in 36 CFR Part
800. We advise the EPA that to fulfill its responsibil-
ities for this project as set forth in Section 106 of
the National Historic Preservation Act of 1966, as
amended, it should address these issues prior to making
a decision regarding the proposed undertaking.
If we may be of assistance in this process, please con-
tact Michael C. Quinn at 839-3394 or at the above address.
FOR THE STATE HISTORIC PRESERVATION OFFICER
Hartmann
:, Historic Preservation
171
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Response to State Historic Preservation Officer
EPA funded an archaeological survey of the Three Lakes project area,
including the major alternatives considered by the firm of Gordon and
Kranzush -- Archaeological Consultants. This report was sent only to the
State and Federal agencies with jurisdiction and concern for cultural
resources because of a desire to avoid making public knowledge of the
presence of potentially valuable resources.
EPA has met with the offices of both the State Archaeologist and
the State Historic Preservation Officer in an attempt to clear up this
matter. Though we incorrectly did not properly explain in the draft EIS
the cultural survey work which had been done, the following two letters
explain the results of our recent efforts. These efforts should ensure our
full compliance with State and Federal law on cultural resources.
172
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COIDRADO
HISTORICAL
SOCIETY
The Colorado Heritage Center 1300 Broadway Denver, Colorado 80203
February 22, 1978
Gene Taylor
Environmental Evaluation Branch
Water Division
Environmental Protection Agency
Region VIII
1869 Lincoln Street
Denver, Colorado 80203
RE: Three Lakes Wastewater Treatment Facility
Dear Mr. Taylor:
Thank you for meeting with Michael Quinn of my staff on October 27th
to discuss this project.
After reviewing the project description and the cultural resource
survey, we concur with the Environmental Protection Agency that no
architectural or historical properties will be affected by the
proposal. In making this finding we have considered possible im-
pacts upon the town of Grand Lake, which,in the opinion of the State
Historic Preservation Officer, is eligible for inclusion in the Na-
tional Register. Based upon the information provided, the waste-
water treatment facility will have no effect upon the architectural
and historical attributes of the town.
The Environmental Protection Agency will have no further responsi-
bilities under the National Historic Preservation Act of 1966, as
amended, after retaining documentation of this finding.
FOR THE STATE HISTORIC PRESERVATION OFFICER
oric Preservation
Mayor, Grand Lake
Regional Council of Governments
County Land Use Administrator
Three Lakes Water and Sanitation District (Martha H. Winters)
173
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UNITED STATES DEPARTMENT OF AGRICULTURE
gOjj- CONSERVATION SERVICE
p- 0. Box 17107, Denver, Colorado 80217
November 18, 1977
Mr. John A. Green
Regional Administrator
United States Environmental Protection Agency
1860 Lincoln St.
Denver, Colorado 80203 iv;nt< '-
Dear Mr. Green:
Thank you for sending us a copy of the Draft Environmental Impact Statement
for Wastewater Treatment facilities for Three Lakes, Colorado. We have
reviewed the draft EIS and facilities plan and have the following comments
to offer.
Soils The regional soils map (Fig IV-6) and the interpretations (Figure IV-1
(1) indicate severe limitations for sewage lagoons and shallow excavations for
the Willow Creek lagoon area. In addition, the soils interpretations indicate
high shrink-swell potential and steep slopes (6-15% or greater). In view
of this, we believe the final EIS should show what measures will be taken
to control eroison during and after construction and the measures to over-
come construction limitations. This should include the sewage lagoon as well
as the buildings, roads, sewer lines and related facilities.
Wastewater Application - Page VII-2 - It appears that treated effluent from
(2) the lagoon system will be used to supplement irrigation water on 900 acres
of hay meadows. We suggest the final EIS quantify the amount of effluent
applied per acre per year and evaluate any limiting factors of land application
of effluent; such as soil infiltration and percolation rates and toxic levels
of micro nutrients.
Non-Point Pollution
We compliment you on your discussion and recognition of non-point sources
(3) of pollution as a significant impact on the environment. We would like to
mention the technical assistance available from the Soil Conservation Service,
through the Soil Conservation Districts, to private landowners in planning
and applying conservation practices for control of non-point sources of
pollution. In addition, we can provide technical and financial assistance
to county governments and other units of government to control non-point
sources of pollution.
We Appreciate the opportunity to review and comment on this project.
syi
?ot>4rt G. Halsteyd /,
'State Conservat/onist
174
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-2-
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)
175
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Response to Soil Conservation Service:
1. The specific measures to be taken to control on-site erosion and
shrink-swell problems will be developed during Step II (preparation of
plans and specifications) of the project. Examples of measures that
could be taken would Include disturbance of as little land as possible,
re-vegetation, check dams, etc.. Neither EPA nor the State Health De-
partment will approve a Step II that doesnot adequately address these
problems through a definite work plan.
2. Again, specific soils Information and formulation of an effluent
application program will be accomplished under Step II of the con-
struction grants process. The approval of the specific feasibility of
the system and Its operating plan will be made before proceeding to
Step III (construction).
Based on year 2000 estimates, there will be a peak load of 4 a/ft.
per day of effluent applied to the 900 acres (1.34 mgd effluent for a
120 day irrigation season). This would result 1n about 1/2 ac/ft per
acre per year. Phosporous will be used by the plants or absorbed by
the soil. Nitrates will be applied at a rate of about 33 pounds acre/
year (see response #5 of Department of Interior). Heavy metals should
not be a problem 1n the type effluent Involved.
3. No comment necessary. EPA will certainly bring this comment to
Grand County's attention and encourage its planning department to make
full use of SCS expertise and programs in water pollution control.
176
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DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
REGION VIII
FEDERAL OFFICE BUILD ING
19TH AND STOUT STREETS
DENVER. COLORADO BO294
NOV i 8 1977
PRINCIPAL REGIONALOKFICIAL
Alan Merson
Regional Administrator
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
Dear Mr. Morson*
Thank you for the opportunity to review the layered environmental impact
statement to safeguard the water quality of three Colorado Lakes, Grand
Lake, Shadow Mountain Lake, and Lake Granby.
It appears that the impacts expected to result from this proposed pro-
ject and reasonable alternatives thereto have been adequately addressed.
Sincerely yours,
Wellington E. Webb
Principal Renional Official
cc:
Office of Environmental Affairs
HEW, Washington, DC (1 copy)
Council of Environmental Quality
Washington, DC (2 copies)
NGV3QW
177
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Response to Department of Health, Education,
and Welfare
No comment necessary.
178
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UNITED STATES DEPARTMENT or AGRICULTURE
FOREST SERVICE
11177 West 8th Avenue
P.O. Box 25127
Lake wood, Colorado 80225
8430
November 29, 1977
Alan Merson, Regional Administrator
Environmental Protection Agency
1860 Lincoln Street, Suite 103
Denver, Colorado 80295
Dear Mr. Merson:
Thank you for the opportunity to review the Draft Environ-
mental Impact Statement for the Wastewater Treatment Facilities
for Three Lakes, Colorado. We have no comments.
Sincerely,
S. H. HANKS
Deputy Regional Forester, Resources
179
6200-11 (1/69)
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Response to U.S. Forest Service
No comment necessary.
180
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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
='* .iL.ll. * » REGIONAL OFFICE
t XLCUTIVE TOWER - uos CURTIS STREET
DE NVER, COLORADO 80202
REGION vni November 15, 1977 ,N .L,-UK, . .< ro:
8DE
Mr. Allen Merson
Regional Administrator
Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
Dear Mr. Merson:
This is in response to your request for review of the Draft Environ-
mental Impact Statement (EIS), Wastewater Treatment Facilities for
Three Lakes, Colorado. On the basis of the information presented,
the proposed facility appears acceptable.
We appreciate this opportunity to review the Draft EIS. If we can
be of further assistance, please contact Mr. Walter Kelm of my staff
at 837-3102.
' 'Robert J. Matuschek
r
Assistant Regional Administrator
Community Planning and Development
181
Insuring Offices
Casprr, Wv,.minK. Denver, Colorado - Fargo, North Dakota- Helena. Montana-Salt Lake CiU, Utah-Sioux Falls, South Daku
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Response to Department of Housing and
Urban Development
No comment necessary.
182
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7 October 1977
,Mr. J,-j ry ii'aiuch
Acting !{i--r/. <>ual Counsel
o i A
1 860 Lniooln street
;uite 1U3
OuiiV'T, Colo. 00^5
l.i/,xy pnd Clint .-.l.'.toa
:!ox 18
1'.• :•„ h o r, Colo. ^ 0 1 •} 2
Mr . ua i r>ch,
i. e t-ro sending this letter in ros[>i.>n./.e to the cnvi orn'.'ie
iii^act stateir.cnt (J'.IS) and the sevn^e colli.ctiou and Went",cnt
[l;xn suiunithod to the public as a course of .action to safeguard
the \.ater quality of the Three Lakes Vater and sanitation District,
TIIis j;ro|0.i:.il does not include the alternative of on-site
'') -.'.-jle trc.'a.ti.'cnt by rue of COMBOS I i ng .aon-po Hntijjg organic
\.,.bte tro;>.t:::rnt ^j :j t<;: i.s. oy placing a ooi-ip.i rison of fviot;e t>y.;ic!as
in the pi-o^osi-.l rnd a public Meeting to iufurm the C'jntic.'rned
i ad ividua Is wo bc\i..ve it \onl.d be a i.:nch i.;o.i-e c-i'ii'pl e te (loc^'iK-nt
of all the possibilities onr oocioly Had t^cbiiolo^-y hu s to ui'fcr.
•., e also believe tliat ste^s should be t; kon to change the
\2) ] aw regarding the funding of vaste treatment syst«iiis. irc.-cntly,
cnly vator trpjisportntion collection type Sj ^ten.s are eligible
for funding. ih.is is discriminatory if nothing else.
The facts nve th^.t ^ater trdnsportati on syst^,;.is snly .reduce
(3) i, ore t I'-iblciiis than the orginial •„ aste iitolf. The five Ballon
1'lu.sh t.oilot is a pollution monster. -ith an ever increasing
population und a lir.ited aiiiuunt of water, it bocop.-es evident
r.'iat if ve tire to cojitinue to survive that ve need to conserve
uur M'ln.ible nutvra.1 resource, v.r|.t>.r, sc-cojid only to air in
i: ^.ortance of survival for iill living species.
183
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0;i..site wrvste treatment co:., Costing type systems cost loss.
^<>'iipl ute inclivi.nunl r;ystc;.is can he installed to handle (ill
m Im^i'Mi './;< -;te and hoiriehold .'j.n'ba^o ;md a <;royvatcr i'iltor system
''or 'i.'ji.'i Iliaa 'v 11 00. 00 on n Iliads i ir; <-;i I 1 ;i I, i .on . I'he.sc would be
ii.-.o ti:;;e costs aud v,ould be for per.vianr'nt systems that do not
pollute as there is no use of water.
The pro^o^ed collection and treatment system would cost
'.vt/h i 'ulivJ dual .in the district, wheather served by the system
/PI or .not, between v..6oOO.OO and o 1 5 , 000. 00, not to imntiua add itiooal
pliMibing costs, hookup fees .:nd monthly service charges. Alf-o
oolJ t-ction lines have a, life oxpectency of less than 50 years
f,nd the oxtJ.Mates of MI?Q are that this system would need to be
.increased in sixe as early as 1990 with the projected growth of
the district. This system would pollute more than it vould protect.
The ii'ajor druvbacks of the proposed system are as follows;
(6) 1) Con s 1 rnr tj.on \nj"l.d fniioC erosion ;-
-------
< <..,,e
V,'c uro^ose that instead of lu'.ving the fV.leral. ;jovn niiici
np with 75/£ of the %6.0 milliuji ) i \ i 'r.jons i n to i ested in p-,-o.:orving v.ater,
the i .iv i.roniijoat and lowering taxes, insicct it in ordor to see
aiid nnr]«rst.! 'id tlie advantage.1; of a waterless, non-mechanical
treatment system.
Thank you,
P" /<
-ir-;zy and Vlint i-.lytc
Box 18
Fr:.ser, Colo. S0142
185
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Response to Lizzy and Clint Elston:
1. You are correct. The draft EIS does not contain a specific evalu-
ation of a Three Lakes area sewage treatment alternative based on the
use of the on-site waste treatment composting type systems. EPA, the
Three Lakes Water and Sanitation District, Grand County, and the State
Health Department have however discussed the possibility of the use of
individual type treatment systems for the area. Though these type systems
(septic tank/leach fields) will still be in widespread use in the area,
it 1s the opinion of those agencies mentioned above that a centralized
collection and treatment system for the main areas of concentrated develop-
ment is needed.
It is our understanding (conversation with Leroy Scott, Director, De-
partment of Development, Grand County) that the County requires your proposed
system to have a leach field. Inadequate leach-fields and an area not
suitable for their use is one of the major factors leading to a preference
to centralize sewer areas of concentrated development.
It 1s also our understanding that you have made a presentation of your
proposed system at an open public meeting of the Three Lakes Water and
Sanitation District and that the District has chosen not to support its use.
Though EPA certainly supports innovative use of technology (land treatment
systems, for example) sewerage projects must also be endorsed and partially
funded by the local sponsors. In the Three Lake case, the local sponsor
has voiced opposition to use of your system.
2. The Federal law under which EPA funds waste treatment systems, the
Federal Water Pollution Control Act Amendments, and subsequent regulations
issued by EPA provide for funding of individual type treatment systems when
1t 1s shown that they are cost-effective and operate adequately. The de-
cision for actual funding of individual systems must be made by the local
sponsor and receive subsequent state and federal' approval.
3. The proposed sewerage system for Three Lakes area is not expected to
cause any water shortage problem. Actually, by giving present poorly
treated sewage adequate treatment a net increase in clean water should be
realized. The proposed system also has a land treatment component as an
added advantage.
4. Though we do not have the specifics of the type system you are pro-
posing, we do not believe that any mechanical device can be built, Installed,
and operated as a "permanent" system. All systems, to our knowledge,
require eventual repair and/or replacement, though this may vary consider-
ably in time from one system to the next.
186
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5. It is not clear how the "$6000 to $15,000" cost figure was derived.
The financial analysis of the proposed sewerage system appears in
Chapter VII of the Facility Plan which was mailed out as part of the
draft EIS.
The voters in the Three Lakes Water and Sanitation District have
approved a $1.3 million bond issue to finance the local share of
the sewerage system. This $1.3 million will be financed via a
property tax mill levy and by new tap fees. The exact burden of this
debt per individual property owner will vary according to the value of
his property. The remainder of the funds needed to build the system
will come from funds allocated by the U.S. Congress to pay for public
sewage collection and treatment projects.
Though individual property owners in the Three Lakes area may
individually pay more than the $1100 figure you quote as the cost of
installation of your proposed system, these same property owners
have collectively made the decision that the sewerage system, as pro-
posed, is worth the cost of the project. The Federal share of the cost
would be spread amongst all taxpayers in the nation. Congress has made the
decision that this is an appropriate use of everyone's tax dollar. Given
the fact that the majority of the sewage load at Three Lakes is generated
by summer tourists visiting a National Park and National Recreation
Area, it would seem appropriate that Federal funds are used in this
manner at Three Lakes.
We do not agree that the proposed system would "pollute more than
1t would protect." This could be true if the sewerage system were to
lead to uncontrolled growth. However, Grand County has committed itself
to controlling non-point (erosion and sedimentation) type pollution
that could result from growth.
6. Some sedimentation will undoubtedly result from construction. EPA
will, however, require careful control of construction activity to keep this
pollutant at a minimum.
7. The 33 acres is classified as "general deer winter range" and its loss
is not expected to affect local deer populations to any significant degree
(see comment letter from Colorado Division of Wildlife). By tending to con-
centrate growth the proposed sewerage system may tend to diminish more
dispersed type development with its attendant use of wildlife range.
8. This is correct. The local citizens have, however, elected to assume
this burden in an open and public election.
9. We agree that in relation to a system that uses no water the proposed
system will add human and other waste to clean water. At peak summer capa-
city in the year 2000 the total quantity of water that would be processed
by the system would be 1.34 MGD. The sewage will receive adequate treat-
ment and under applicable State and Federal law and regulations will meet
health and 1n-stream water quality standards.
187
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TO. EPA, the State, Grand County, Three Lakes Water and Sanitation
District, Congress, and many others (see comments) do not consider this
Project a "waste of money." The project will result in definite water
quality benefits and those secondary benefits resulting from preservation
of this quality at Three Lakes.
11. The actual construction of the proposed sewerage system will cause
minimal erosion and will be controlled. The major erosion potential from
the project comes from possible development — an issue previously dis-
cussed as being addressed by Grand County (also see EPA response to
State Division of Planning). Taxes will increase and a service charge
will replace the expense property owners currently incur via use of septic
tanks. Again, we do not believe the project to be a waste of funds nor a
"polluter" of waters.
Federal law and regulation? do not permit EPA to make low interest
loans available to individuals for the financing of waste treatment sys-
tems. The law requires that projects be of a public nature. EPA, along
with the State, may fund individual treatment systems. However, only the
"public" aspects of such systems — such as an inspection program, common
septic tank, etc. are eligible, individual components such as toilets
are not.
EPA appreciates the merit of innovative technology and the possible
cost savings, "no discharge", etc. aspects of individual treatment systems.
We also appreciate the interest of people who are attempting to offer
alternatives to capital intensive projects. We believe, however, that the
merits of the proposed Three Lakes system justify our support and that
the system will help improve the long-term environment of the area.
188
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND?UBTITLE
Final Environmental Impact Statement - Wastewater
Treatment Facilities For Three Lakes Colorado
5. REPORT DATE
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Gene Taylor, 8W-EE, EPA
8. PERFORMING ORGANIZATION REPORT NO.
). PERFORMING ORGANIZATION NAME AND ADDRESS
Environmental Evaluation Branch
Water Division Region VIII EPA
1860 Lincoln St., Denver, Co. 80295
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
Same as above.
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This EIS describes and analyzes the environmental impacts of a proposed regional
sewage collection and treatment system for the Three Lakes Water and Sanitation
District, Colorado. The proposed sewerage system will serve presently unsewered
developed areas, eliminate present sub-standard septic tank and treatment plant
discharge to the lakes, and discharge a properly treated effluent to a stream non-
tributary to the lakes. Growth and non-point issues are being addressed by Grand
County. The project is expected to result in water quality and land use improvement
for the Three Lakes area.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS C. COS AT I Field/Group
EIS, wastewater treatment facilities, non-
point pollution, erosion, National Recrea-
tion Area, land use planning, Park Service
EPA, construction grants.
Three Lakes, Grand Co.,
Colorado, Rocky Mountain
Nat. Park, Shadow Mtn.
Nat. Recreation Area,
Grand Lake, Shadow Mtn.,
Lake Granby.
8. DISTRIBUTION STATEMENT
Distribution unlimited.
19. SECURITY CLASS (ThisReport)
21. NO. OF PAGES
is page)
22. PRICE
EPA Form 2220-1 ("«v. 4-77) PREVIOUS EDITION is OBSOLETE
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EPA Form 2220-1 (Rev. 4-77) (Reverse)
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