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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

                                  10

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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
                                  11

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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.
                                   12

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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.
                                  13

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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

                                  14

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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
                                  15

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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-
                                   16

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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.
                                   17

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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.
                                21

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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
                                   22

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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.
                                  23

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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'
                                   24

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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);
                                  25

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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
                                   26

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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
                                   27

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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.
                                  29

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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
                                  37

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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.
                                   38

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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
                                  41

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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
                                  42

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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
                                   43

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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
                                  44

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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),
                                   64

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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.
                                  96

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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
                                  97

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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.
                                  98

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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
                                  99

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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
                                  100

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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.
                                   101

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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.
                                  102

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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
                                  103

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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:
                                  104

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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.
                                   105

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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.
                                  107

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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.
                                  108

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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.
                                  113

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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

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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"
                              129

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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)
                          130

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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.
                       131

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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.
                           132

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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.
                           133

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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.
                          134

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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,

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                    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.
                                        136

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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
                                         137

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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.
                                         139

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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 '•

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               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 ;-
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                                                              < <..,,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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                                                         INSTRUCTIONS

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        Insert the EPA report number as it appears on the cover of the publication.

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        approval, date of preparation, etc.).

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        Give name(s) in conventional order (John R. Doe, J. Robert Doe, etc.). List author's affiliation if it differs from the performing organi-
        zation.

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   10.  PROGRAM ELEMENT NUMBER
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   11.  CONTRACT/G RANT NUMBE R
        Insert contract or grant number under which report was prepared.

   12.  SPONSORING AGENCY NAME AND ADDRESS
        Include ZIP code.

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        Indicate interim final, etc., and if applicable, dates covered.

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        Insert appropriate code.

   15.  SUPPLEMENTARY NOTES
        Enter information not included elsewhere but useful, such as:  Prepared in cooperation with, Translation of, Presented'at conference of,
        To be published in, Supersedes, Supplements, etc.

   16.  ABSTRACT
        Include a brief (200 words or less) factual summary of the most significant information contained in the report. If the report contains a
        significant bibliography or literature survey, mention it here.

   17.  KEY WORDS AND DOCUMENT ANALYSIS
        (a) DESCRIPTORS - Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terms that identify the major
        concept of the research and are sufficiently specific and precise to be used as index entries for cataloging.

        (b) IDENTIFIERS  AND OPEN-ENDED TERMS - Use identifiers for project names, code names, equipment designators, etc. Use open-
        ended terms written in descriptor form for those subjects for which no descriptor exists.

        (c) COSATI FIELD GROUP - Field and group assignments are to be taken from the 1965 COSATI Subject Category List Since the ma-
        jority of documents are multidisciplinary in nature, the Primary Field/Group assignment(s) will be specific discipline, area of human
        endeavor, or type of physical object. The application(s) will be cross-referenced with secondary Field/Group assignments that will follow
        the primary postmg(s).

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                                   •
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EPA Form 2220-1 (Rev. 4-77) (Reverse)

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