EPA-908/5 -77-005
AUGUST, 1977
  Final Environmental Impact Statement

           Steamboat Springs

    Regional Service Authority

201 Wastewater Facilities Han

       United States Environmental Protection Agency
                 Region VIII Denver, Colorado

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Final Environmental Impact Statement
Steamboat  Springs
Regional Service Authority
201 Wastewater Facilities Plan
United States Environmental Protection Agency
Region VIII, Denver, Colorado
    A. GREEN
 sgional Administrator

 August 26.1977
 Date
Prepared By =
Weiner & Associates,  Denver, Colorado

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SUMMARY  SHEET
Environmental Impact Statement
 (   )   DRAFT

 (X  )   FINAL
Prepared for the U.S. Environmental Protection Agency,  Rocky Mountain-
Prairie Region, Region VIII, Denver, Colorado, through  a contract with
Weiner & Associates, Inc., Denver, Colorado.

A.  Type of Action;   Administrative  ( X )       Legislative   (  )

B.  Brief Description of Proposal

The Region VIII Administrator of the U. S. Environmental Protection
Agency intends to provide federal matching funds for regional waste-
water treatment in the Steamboat Springs region through the authority
of the Water Pollution Control Act  (as amended, 1972).   The purpose
of this final Environmental Impact Statement  (EIS) ,  required of fed-
eral agencies by the National Environmental Policy Act  (NEPA, 1969)
is to notify governmental agencies and the public at large of this
impending project with potential environmental ramifications.

The principal river drainage is the Yampa River which has good chemi-
cal water quality and poor to fair habitat for aquatic  life.  This
latter condition may be due to upstream bank  erosion, nonpoint runoff,
irrigation return flows, sewage effluent and  the removal of natural
streamside vegetation.  This project is intended to  consolidate the
five existing point sources of sewage effluent into  one plant, designed
to achieve stated water quality goals.

C.  Alternatives Considered

The final treatment alternatives combine the  existing point sources
and can be divided into four action and one no-action options.  The
action alternatives involve two sites and two tertiary, or advanced,
treatment choices.  Plant site options include  use of the existing
city lagoon site or a new location two miles  west of the city lagoons.
Tertiary treatment is necessary to control suspended solids as well
as ammonia and chlorine residual.   Two alternatives exist for this
purpose; one involves use of inplant processes  (advanced biological
and dual-media filtration);  while the other applies 40 percent of
the disinfected secondary effluent to a  designated site during summer
months when ammonia levels become toxic  to aquatic life.  The latter
approach uses the land as a natural filter in a controlled program
to achieve tertiary treatment.
                                  11

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A third site, ten miles downvalley, was considered in conjunction
with year-round land treatment.  This alternative was rejected
midway through the planning process because it was feared that it
would encourage growth inconsistent with citizen desires and the
draft County Comprehensive Plan.  In addition, this approach elim-
inates the growth constraints of the waste load allocations of the
discharge permits.

D.  Environmental Impacts

A summertime land treatment program (Alternatives II and IV), allows
the productive use of nutrient laden water which increases crop yield;
does not require large storage reservoirs (a citizen objection); and
retains the growth management aspects of the discharge permits.  It
would involve applying 40 percent of the effluent to the land during
the irrigation season, while the remaining 60 percent and all of the
wintertime flows would be treated in plant.   This plan is designed to
meet the required water quality goals.

The new plant site (Midway) offers gravity flow from almost all devel-
oped areas and offers a land buffer from existing or planned structures.
It is consistent with planning goals and sound land use criteria.  The
present lagoon site is less desirable because it is near existing resi-
dences, in an area slated for more development and is in the 100 year
floodplan.  In addition, this site would require extensive pumping from
downvalley areas.  It was determined that the Midway site in conjunc-
tion with summertime land treatment would help assure the continued
use of land for agricultural purposes and enhance its productivity,
a stated citizen goal.  Finally, the Midway site with land treatment
(Alternative IV) is also found to be the most cost-effective choice.

The plan just decribed is a result of a compromise solution that was
developed on June 22, 1977.  The solution received the unanimous ap-
proval of the Steamboat Springs City Council and the Routt County
Board of County Commissioners.
                                  111

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E.  Distribution

The draft EIS is being provided to the following:

    Local agencies:

       Routt County Regional Planning Commission
       Routt County Board of Commissioners
       Routt County Environmental Health Department
       Steamboat Springs Planning Commission
       Northwest Colorado Council of Governments
       Member Entities:  Steamboat'Springs Regional Services Authority
          City of Steamboat Springs
          Mt. Werner Water and Sanitation District
          Riverside Water and Sanitation District
          West Steamboat Water and Sanitation District
          Fish Creek Water and Sanitation District
          Tree Haus Water and Sanitation District
          Steamboat II Water and Sanitation District
          KOA Campground Development
          Sleepy Bear Development

       Citizen Advisory Committee Members

       Steamboat Springs Public Works Committee

    State agencies:

       State Clearinghouse/Division of Planning
          Colorado Water Pollution Control Division
          Colorado Air Pollution Control Division
          Colorado State Board of Land Commissioners
          Colorado State Land Use Commission
          Colorado Division of Highways
          Colorado Division of Wildlife
          Colorado Department of Natural Resources/Water Resources
            Division
          Colorado Historical Society
          Public Utilities Commission
                                  IV

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    Federal agencies:

       Forest Service  (Routt National Forest & Regional)
       Federal Highway Administration
       U.S. Bureau of Reclamation
       Bureau of Outdoor  Recreation
       U.S. Fish and Wildlife Service
       Bureau of Land Management
       Field representative, Office of the Secretary of Interior
       Soil Conservation  Service  (local and regional offices)
       U.S. Geological Survey
       Economic Development Administration
       U.S. Senators Hart and Haskell
       U.S. Representatives Armstrong, Evans, Johnson, Schroeder,
          Wirth
       Federal Energy Office
       U.S. Public Health Service
       U.S. Department of Housing  and Urban Development

    Others:

       Colorado Open Space Council, Inc.
       Trout Unlimited
       National Wildlife  Federation
       Rocky Mountain Center on Environment
       Wright-Mclaughlin  Engineers
       Denver Post
       Rocky Mountain News
       Steamboat Pilot
       Charles Gathers and Associates
       Special Districts  Association of Colorado
       Steamboat Ski Area
       Colorado Ute Electric Association
       Colorado Municipal League

 G.  Acknowledgements;                    	

EPA wishes to thank those  individuals who devoted considerable time
and knowledge into achieving this plan for a new sewage treatment
system for Steamboat Springs.  The skills necessary to accomplish
this often difficult task  included persons knowledgeable is engineering,
biology,  law,  geology, city, county, state and federal administration,
the art of compromise as well as the knowledge of the goals and desires
of the citizens of Steamboat Springs.  EPA particularly wishes to con-
gratulate the following individuals who were most influential in accom-
plishing this plan:   Mike Uberauga, Jim Bubb and Brae Melton - City
Staff of Steamboat Springs; Don Barrett - City Council President; "Doc"
Utterbach - Chairman of the Routt County Board of Commissioners;'Ken
Wright and Bill Tagg rt of Wright-McLaughlin Engineers; John Fetcher
of Mt. Werner Water and Sanitation District;  Steve Weiner and Ron Pifer
of Weiner and Associates;  and the concerned citizens of Steamboat Springs

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                       TABLE OF CONTENTS
                                                           Page
      SUMMARY SHEET                                         ii

  I.   EXECUTIVE SUMMARY                                      1
           Why Additional Wastewater Treatment Facilities?   3
           Area Water Quality                                3
           Existing Sewage Discharges                        3
           Water Quality Goals                               4
           Proposed Alternatives                             7
           Facilities Plan                                  10
           Evaluation of Proposed Alternatives              11
           Initial Concerns                                 12
           Issues                                           13

 II.   WATER ENVIRONMENT                                     19
           Goals                                            19
           Existing Water Quality and Quantity              24
           Point and Nonpoint Sources                       37

III.   FINANCIAL CONDITION OF THE DISTRICTS                  51
           SSRSA Entities                                   51
           Projection of Revenues                           60
           Existing and Anticipated Legislation
             Affecting Consolidation                        62
           Organizational Alternatives                      67
           Alternative A                                    70
           Alternative B                                    71
           Alternative C                                    72
           Financial Effects of Alternatives                74

 IV.   OTHER EXISTING ENVIRONMENTS                           79
           Physiography                                     79
           Geology                                          79
           Soils                                            80
           Biology                                          81
           Air Quality                                      91
           History and Archaeology                         100
           Population                                      101
           Land Use                                        109
           Socioeconomics                                  114
           Transportation                                  118
           Noise                                           121
           Solid Waste                                     122
           Demographic s                                    122
           Recreation                                      123
           Aesthetics                                      125
           Culture                                         125
           Other Federal Projects                          126
                              VI

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                   TABLE OF CONTENTS (cont'd.)

                                                            Page
   V.  DESCRIPTION OF PROPOSED ALTERNATIVES                 128
            Alternative I - Present Site and In-Plant
              Tertiary Treatment                            129
            Alternative II - Present Site and Summertime
              Land Treatment                                129
            Alternative III - Midway Site and In-Plant
              Tertiary Treatment                            132
            Alternative IV - Midway Site and Summertime
              Land Treatment                                132
            No-Action Alternative                           134
            Sludge Disposal                                 134

  VI.  EVALUATION OF ALTERNATIVES                           136
            Water Quality                                   136
            Geology                                         150
            Soils                                           151
            Biology                                         151
            Air Quality                                     151
            Land Use                                        152
            Costs                                           156

 VII.  RECOMMENDED ACTION                                   159

VIII.  MITIGATION MEASURES                                  161
            Water Quantity                                  161
            Water Quality                                   162
            Soils                                           165
            Biology                                         167
            Air Quality                                     167
            History and Archaeology                         167
            Socio-Economics                                 168
            Interceptor and Force Main Crossings of the
              Yampa River                                   168
            Groundwater Control During Construction         169
            Energy Conservation                             169
            Growth Restrictions                             170

  IX.  UNVOIDABLE ADVERSE EFFECTS                           171

   X.  SHORT-TERM USES AND LONG-TERM PRODUCTIVITY           172

  XI.  IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT            173
       OF RESOURCES

       BIBLIOGRAPHY                                         174

       Appendix A:  Water Quality Standards and Regulations A-l

       Appendix B:  Comments on Draft EIS                   B-l

       Appendix C:  EPA A-95 Responses                      C-l
                            VII

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                             I.   Summary
This is a summary of the final environmental impact statement (EIS)  for
proposed construction of additional wastewater treatment facilities  at
Steamboat Springs, within Routt County,  (Figure 1A),  Colorado.   The  Na-
tional Environmental Policy Act (NEPA,  1969),  requires preparation of
an EIS whenever federal funds or land are considered  for projects  with
potentially significant environmental impacts.  The U. S.  Environmental
Protection Agency (EPA), under the authority of Section 201 of  the Fed-
eral Water Pollution Control Act Amendments of 1972,  is authorized to
grant matching funds for construction costs of designated wastewater
treatment facilities.  This final EIS is the result of this decision
and included circulation of a draft EIS  for comment to other federal,
state, and local government agencies as  well as citizen groups,  indiv-
iduals, and the news media.

The Act, together with state legislation, has  resulted in the establish-
ment of water quality standards for streams and discharge sources.   Dis-
charge permits issued by the Colorado Water Quality Control Division for
the five existing sewage plants in the Steamboat Springs area will re-
quire any new facilities in the area to  control ammonia, suspended solids
and residual chlorine.  In addition, discharge of organic matter (bio-
logical oxygen demand-EOD), fecal coliform (bacteria), pH, grease  and
oil must remain in compliance, thus necessitating cost-effective expan-
sion of present facilities.  To aid municipalities in complying with
the water quality regulations, the Federal Act provides matching funds
for facility construction at a rate of 75 percent. The remaining  25
percent must be paid by local entities,  plus all annual operation  and
maintenance costs.
                                THE EIS ROLE

An impact statement allows the lead federal agency,  in this case  EPA,
to include all environmental considerations into the new facilities
design and to provide opportunity for citizen participation.  This EIS
identifies potential environmental, social, and economic impacts  of
the proposed projects.  It presents issues that were determined during
the preparation of the EIS and 201 Facilities Plans  (design engineer's
report).  Methods used to resolve these issues are explained as well
as a summary of engineering alternatives proposed to achieve agency
requirements.  The proposed alternatives and recommended action are
then evaluated in terms of environmental impacts.
                                 -1-

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    FIGURE 1A
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           Why Additional Wastewater Treatment Facilities?

The following conclusions are based on the detailed engineering report
entitled "Steamboat Springs Wastewater Management Report", June 30,
1977 prepared by Wright-McLaughlin Engineers, Denver, Colorado.

The Yampa River is the principal drainage of the study area shown in
Figure 1.  Sewage discharges as a result of area growth and develop-
ment together with non-point source runoff and irrigation return flows
have partially degraded this river and its tributaries.
                          Area Water Quality

The general water quality of the Yampa River in the study area can be
characterized as fair.  It has occassionally violated the state's stan-
dards for BI streams and has been degraded frequently by siltation.
These factors have contributed to an ecological environment that has
a poor to fair standing crop of bottom insects and a poor standing
crop of game fish.

The total output of pollution from non-point sources has been estimated
by Wright-McLaughlin Engineers (Oct., 1975).  Their prediction indicates
that by 1985 runoff would contribute 3.5 more suspended solids and 0.55
more organic matter (BOD) than the combined effluent output from the
five existing sewage plants within the study area.

Section 201 of the Act previously cited states that Facilities Plans
shall, "...provide control of treatment of all point and non-point
sources of pollution,...".  However no structural alternatives have
been proposed for non-point sources because grant funds are limited
and Section 208 authorizes specific study of these sources which are
yet to be completed.   Therefore, it is felt that proposal of struct-
ural options would be premature.  As a result, the Facilities Plan
describes only non-structural (policy) recommendations to control non-
point sources of pollution.  Point sources (sewage effluent) are to
be controlled by the construction of a wastewater treatment facility.
                       Existing Sewage Discharges

Study May 1 shows the five point sources currently discharging treated
sewage effluent into the Yampa.  These sources are summarized as follows!

       Source                System Type         Entities Served

       Mt. Werner            aerated lagoon      Mt. Werner Water and
                                                 Sanitation District,
                                                 Tree Haus District


1-The Northwest Colorado Council of Governments 208 Areawide Wastewater
 Management Plan is expected to be completed by May, 1978.
                                   -3-

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      Source             System Type        Entities Served

      City of Steamboat
      Springs            aerated lagoon     City of Steamboat Springs,
                                            Fish Creek Water and  Sanitation
                                            District, West Steamboat Water
                                            and Sanitation District,
                                            Riverside Water and Sanitation
                                            District, and Mt. Werner Bypass

      KOA                package plant      KOA Campground—private system

      Sleepy Bear        package plant      Sleepy Bear  Mobile  Home Park—
                                            private system

      Steamboat  II       package plant      Steamboat II Water  and
                                            Sanitation District
                         Water Quality Goals

In 1974, the Colorado Department of Health released  the  "Water Quality
Management Plan for the Green River Basin" which included the Yampa River
Basin and recommended plant discharge limits known as waste load alloca-
tions.  These recommendations were incorporated into Discharge Permits
now administered by the State.  Table I compares the 1977 permit require-
ments and ultimate design criteria approved by EPA and the Colorado De-
partment of Health to present point source discharges.  All five sources
are in violation of these standards; however, a better record of compli-
ance could be achieved if better management could be exercised over the
existing operations.  If existing line inflow and infiltration problems
are reduced, the exisiting facilities still would be inadequate to handle
the required treatment.

Compliance with water quality discharge standards will require additional
factilities for organic matter (Biological Oxygen Demand-BOD)  and sus-
pended solids.  EPA has also urged the SSRSA and Wright-McLaughlin to
develop design limits for ammonia and residual chlorine.   These latter
two controls are based on their respective toxicity to fresh water
aquatic life as recommended in Quality Criteria For Water (EPA,  1976).
Discharge Permits will be updated in the future to include these para-
meters (See Chaper II) where water quality of the receiving streams
indicates they are necessary.

Treatment capacity will be enlarged in phases consistent  with  actual
population growth and reduction achieved in inflow and infiltration.
The population projections developed for this EIS were used  by Wright-
McLaughlin to estimate construction phases over a 20-year planning
period in order to determine necessary plant site areas and  to conduct
a cost-benefit analysis of these alternatives.
                            -4-

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                              Table 1

                      SSRSA Plant Discharges
BOD,
Suspended
Solids

Fecal
Coliform
Residual
Chlorine

Ammonia
(NH3-N)

pH

Flow
  1975
Dischargel

313 to
664 Ib/day
11 to
120 mg/1

500 to
280,000
per 100 ml
0.08 to
18.0 mg/1

7.1 to 8.8

1.71 to
2.24 mgd
1977 Permit
  Limits^

238 Ibs/day
    or
85% removal

85 % removal
1983 Design
 Criteria3

238 Ibs/day
    or
10 mg/1

10 mg/1
Variable,         Variable,
maintain stream   maintain stream
concentration     concentration
below 1000/100 ml below 1000/100 ml
                 Unknown
Unknown
6.0 to 9.0
less than .02 mg/1


Seasonal
(5 to 9 mg/1)

6.5 to 8.5

1.62 mgd?
(1985)
1Based on data from Table VII except for suspended solids, which
 comes from Table IX.

Effective July 1, 1977.

^Approved by EPA and the Colorado Department of Health

 Reflects reduction in Inflow and Infiltration
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                        Proposed Alternatives

Chapter V describes the proposed treatment alternatives recommended by
Wright-McLaughlin in the Facilities Plan.  All treatment alternatives
combine the existing five point source into one plant for treatment.
These alternatives can be divided into four action, one sub-alternative
and one no-action option.  The action alternatives involve two sites
and two tertiary, or advanced, treatment choices.

An outfall presently links the Mt. Werner and Steamboat Springs plants.
However, all alternatives require that an additional line be construc-
ted between the city proper and its lagoons.  This would parallel the
existing Steamboat Springs outfall thus providing needed additional
capacity.  The Mt. Werner plant will be used for flow leveling also
in conjunction with all proposed alternatives.

The proposed alternatives are summarized as follows:

Alternative I includes all primary, secondary and tertiary treatment
in-plant at the existing Steamboat Springs sewage lagoons.  Sewage
would have to be pumped from the Steamboat II, Sleepy Bear, KOA, and
Riverside residential areas.

Alternative II employs the same site to treat the wastewater to sec-
ondary levels and then applies the disinfected effluent to the land
during the summer.  The remainder of the year the effluent would be
treated to tertiary levels at the existing site and discharged to
the Yampa River.  This process will control ammonia during summer
months when levels become toxic to stream aquatic life due to high
water temperature and low flow.  Operations during the non-irrigation
period would involve all in-plant processes, including multi-media
filtration to control BOD and suspended solids.

Alternative III, like Alternative I, utilizes only in-plant processes
at the Midway site shown in Figure 2.  Facilities at this site would
be built in phases in order to utilize the existing facilities.  A
new outfall would join the Steamboat Springs lagoons with Midway,
ultimately retiring the existing lagoons around 1987.  A slight a-
mount of pumping would be required from Steamboat II, KOA and Sleepy
Bear.

Alternative IV is the summertime land treatment variation similiar to
Alternative II with the plant located at Midway.  Construction would
be phased in a fashion similiar to Alternative III.  However under
this alternative only 40 percent of the summer-time effluent would
be applied to the land with the remainder of the effluent treated to
tertiary levels at the Midway site.
                                 -7-

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                                                           Figure 2
                                                     PROPOSED AREA FOR LAND
                                                     TREATMENT & PLANT SITES

                                                     Suitable Soil
                                                              VALLEY BOTTOM
                                                              UPPER TERRACE

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Area of proposed Midway Plant and land treatment sites
(looking east, ski area in background)
                         -9-

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Finally, there is the no-action alternative which would leave the
five point sources as is, thus, not providing for future growth and
allow continued violation of water quality standards.

Until recently, the locations under consideration also included a
western site just east of the confluence of the Elk and Yampa Rivers.
This site offered gravity flow from all portions of the study area
except those subdivisions north of the airport which would have to
be pumped for all alternatives.  It also offered compatability with
a land treatment program for accumulated secondary effluent from
year-round flow  (classical land treatment).  This concept would require
winter effluent storage in constructed reservoirs and land application
during summer months.  The western site was subsequently rejected
because it was feared that it would readily facilitate growth incon-
sistent with citizen desires and the unadopted Comprehensive Plan.
In addition, a year-round flow, land treatment program eliminates
the constraints of the Discharge Permits.  These permits specify
allowable effluent concentrations which can be discharged to a
receiving body of water.  The specified limits consider the loading
capability of the river in pounds per day  (waste load allocation)
and, through a given treatment technology, can be translated back
to a design flow, hence service area population.  In this sense,
Steamboat Springs officials and EPA feel that Discharge Permits
are tangible growth management tools.

A classical land treatment program, without direct discharge to the
river, would open up the area's allocation.  Theoretically, a pro-
posed development inconsistant with land use goals, could construct
its own sewage system and use the available allocations.  The costs
of such a system, designed to meet standards, would make such an
event unlikely; however, the potential exists.

                          Facilities Plan
This EIS does not repeat all technical information presented in the
Facilities Plans prepared by the design engineer, Wright-MeLaughlin
Engineers of Denver.  The reader may wish to review the plan con-
current with this EIS.  A Facilities Plan, as required by the Act,
sets out preliminary engineering criteria, alternatives and recommen-
dations, analysis of sewer line inflow and infiltration problems,
and presents a cost-effective analysis of the alternatives proposed
to meet applicable standards.

Discussion of environmental, social, and economic issues differentiates
between those identified initially but resolved during the planning
and EIS processes; those that remained unresolved in the draft EIS;
and those remaining in this final EIS.  Discussion of issues is
presented according to their relationship to wastewater treatment.
                                   -10-

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                Evaluation of Proposed Alternatives

Representatives of the EPA, State Health Department, City of Steamboat
Springs, Routt County, Wright-McLaughlin, Weiner & Associates, and two
citizens committees met often to discuss these alternatives.  Opinion
varied dramatically, as some favored purely gravity flow systems,
while others saw growth management capability in a gravity flow/forced
main system.  Both extremes have sound reasons for treatment plant
location.  Opinion also varied on tertiary methods with some
questioning the feasibility of land treatment in a sub-alpine climate.

Treatment Options

A partial summertime land treatment program, (Alternative II and IV),
allows the productive use of nutrient laden water which increases crop
yield; does not require large storage reservoirs (another citizen
objection); and retains the growth management aspects of the Discharge
Permits.   Irrigation, in this sense, would be construed as controlled
discharge of effluent by surface spreading to support plant growth and
to treat wastewater.  Thus, instead of removing various constituents like
nitrogen and phosphorus, they would be beneficially utilized by the
crops.  The land application technique uses the land and its associated
biosystem as a living filter medium.  Treatment is accomplished by a
combination of physical, chemical and biological means, as the applied
wastewater seeps into the soil.  Many of the impurities that are en-
trapped in the soil are eventually used by the higher plants as a
growth component and the wastewater receives the equivalent to tertiary
treatment.

The success of such a program is highly dependent upon effluent
application rates, proper management, and appropriate site conditions.
Much of the area shown in Figure 2 provides acceptable soil conditions
compatible with a proposed application rate of 29 inches per year.
The growing season in the proposed area is 90 - 100 days which is
compatible with a summertime land treatment program.  Therefore climate
is not an obstacle to this tertiary process.  Although in-plant processes
are environmentally acceptable, a properly designed and managed summer-
time land treatment program has numerous advantages; therefore, EPA
recommends the approach of Alternatives II and IV for the Steamboat
Springs study area. It should also be noted that all action alternatives
would improve the water quality and therefore are considered to be ben-
eficial to the several endangered species of fish in the lower Yampa
River Basin.	
1 Permits specify pounds per day with no credit given for summer
  when there is no direct discharge.
                                  -11-

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Plant Site Options

Plant site selection is a major decision affecting land use in the
study area.  At the existing site, adjacent new plant construction
would be in the 100-year flood plain.  Besides the flood hazard to new
facilities which requires flood proofing, such construction would
restrict the flood flow and slightly raise the flood height upstream,
potentially effecting nearby structures.  The present site is in an
area that is already developed to a limited extent and, on 1995 land-
use maps, is slated for heavier development.  Should the land immediately
surrounding the existing site turn out to be densely populated, as
planned, problems are likely to develop.  The history of sewer plants
in populated areas is not very good since people have an almost
instinctive reaction against such facilities.  Also, there are the
practical concerns for noise and odor.

The Midway Site is proposed in an area that the draft Comprehensive
Plan and citizens alike agree should remain agricultural.  This site
would convert a relatively small parcel of agricultural land  (approximately
20 acres); however, its close proximity to a summertime land treatment
site makes this a desirable location.  In addition, this site will
be located outside the 100-year flood plain, unlike the present lagoons,
and would only require a small amount of pumping from Steamboat II,
KOA and Sleepy Bear.

In summary, the present lagoons should be used for the short-term to
utilize their potential, but the new Midway Site is preferable in the
long run.  It would allow a partial land treatment program to occur
nearby and would help assure the continued use of land for agricultural
purposes, a stated citizen goal.

                         Initial Concerns
This EIS effort began with the development of an "issues paper" which
identified environmental factors to be investigated for their relation-
ship to the projects being considered.  Those preliminary issues
included in the following topics:

    0 Surface water and groundwater quality;

    0 Impact of area point and non-point discharges and future
      demand for  sewage treatment service;

    o Secondary impacts, if any, including growth encouragement
      and its impact on air quality, noise, traffic, land use,
      public sentiment, etc.;
                                   -12-

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    0 Land use and environmental impacts if new plant sites and
      interceptor sewers are needed;

    0 Impact on historical/archaeological sites;

    0 Odor and noise;

    0 Sludge disposal;

    o Economic impact on districts; and

    0 Flood plains and other geologic factors.

Preservation and enhancement of surface and groundwater quality is the
expressed goal of the Federal Water Pollution Control Act.  The intent
of Section 201 of the Act is to control point and non-point sources
and this control remains the principal issue of the EIS.

                              Issues
The draft EIS, published in June 1976 identified the following issues
to be resolved in this final statement:

Financial Condition of the Districts

Six organized water and sanitation districts exist in the 201 study area.
The City of Steamboat Springs provides all sewage treatment for four of
these districts and partial for one more (Mt. Werner) while the Steam-
boat II district and the private entities (Sleepy Bear and KOA) have
their own "package" plants.  Several districts of the SSRSA have exist-
ing bond indebtedness which have repayment schedules that call for in-
creasingly larger payments with time, known as ballooned payments.  This
assumed a growth rate which has not occurred so that projected revenues
are not being realized.  As a result, these districts are in poor financial
condition hardpressed to meet current debt obligations and little hope
of contributing their proportional share of 201 capital costs.  The draft
EIS left the unresolved question "Who is going to pay the local share
of capital costs?"

In order to answer this question a study was prepared during the Fall
of 1976 which investigated the legal and financial options that would
assure sound local funding.  This report was issued in December 1976
and is repeated in Chapter III.  Three financial alternatives were found
including:

   A)  The city assumes all debt obligations through general obligation
      bonds and recovers the out-of-city share through increased
      service fees;
                                  -13-

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   B) A County Wastewater System where the county assumes the out-
      of-city share of the debt and contracts with the city for
      treatment; and

   C) Formation of an umbrella Metropolitan Sewage Disposal District
      which would transfer control and responsibility of the regional
      treatment system to a regional district board who would issue
      revenue bonds.

In a series of joint meetings it was decided that alternate B, County
Wastewater System would be implemented with the creation of a special
advisory board of directors.  Formation of this contractual arrangement
between the city and county has not formally taken place, but must be
completed prior to approval of Step III grant funds by EPA and the
State of Colorado.

Cost of Program

Of the four alternatives previously described, the city and other
members of the SSRSA narrowed the choice of alternatives to two,
including the Midway Site with extended aeration  (EA) and mixed ad-
vanced wastewater treatment (MAWT) (summer land treatment) and the
existing City Lagoon Site with extended aeration and in-plant advanced
biological treatment (ABT).  Total costs of these alternatives are
estimated by Wright-McLaughlin and Steamboat Springs engineering staff
as follows:

                                  Midway (EA-MAWT)     Steamboat (EA-ABT)

Phase I (to 1985)

 Capital Cost*                        4,167,500             4,769,710
 Operation and Maintenance (8 yrs)    1,200,000             1,668,800
      Subtotal                        5,367,500             6,438,510
Phase II  (1985-1997)
 Capital Cost                         1,905,160               575,450
 Operation and Maintenance            2,178,500             2,584,800
      Subtotal                        4,083,660             3,160,250
20-Year Total Costs                   9,451,160             9,598,760


* 75 percent EPA funded
                                  -14-

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The estimated costs are extremely close and no appreciable distinction
can be made between the cost of these alternatives.  It can be con-
cluded that in order to comply with water quality standards and provide
capacity for projected growtlr-, area residents must incur a local share
debt of approximately $1.125 million.  Also, since total costs of the
treatment alternatives are nearly identical, the ultimate selection
could be based on other criteria.

The Selected Treatment Technology and Plant Site

The draft EIS recommended the Midway Site and EA-MAWT technology.  Over
the last year extensive effort has been made to select a specific plant
and land treatment site in the Midway area.  At first discussion centered
on purchasing land for the plant and leasing a treatment site of approxi-
mately 180 acres.  However, it became apparent that the best way to con-
trol a summer land application program was through direct control of
the land.  The draft EIS also pointed out the existance of a zoned trailer
park site that represented an incompatible land use along the southern
side of the Yampa, west of the city.  After considerable investigation
and field tests, it was determined that purchase of the trailer park
site (Meadow Industries property) would not only eliminate this un-
desirable land use, but also provide an acceptable site for the regional
plant and land treatment program.

The only draw-back is that the Meadow Industries site may not be large
enough to properly handle application of projected effluent volumes.
Therefore, additional land may be necessary to be used in conjunction
with the Meadow Industry-Midway site.  Another river crossing and asso-
ciated costs hinder use of the nearby city golf course while neighboring
property owners  (to the Meadow property) are reluctant to sell land
parcels for this use.  As a result, the facilities planning effort was
faced with an obstacle.  Further detailed investigations found that
assets of retaining the Meadow site in agricultural production via
purchase for the land treatment program could be accomplished without
needing additional land.  Application rates can be varied according to
underlying soils and topographic features however projected effluent
volumes are estimated to exceed the land's capacity for surface drainage.
It was determined that it is cost effective  (see Chapter Vl-Costs) to
provide in-plant treatment capability to be used according to a 40-60
split where 60 percent of the effluent would receive nitrification
treatment in-plant and then discharged directly to the Yampa, while the
40 percent would be an ideal loading for land application.  This
compromise solution allows uniform flow to the land treatment system
and provides in-plant backup capability as sized.
   A population forecast was prepared as part of this EIS and used
   for facility planning.
                                  -15-

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Other Considerations

Inflow and infiltration (I/I) is a significant problem particularly
in the older part of the city.  Volume One of the Facilities Plan
found that I/I repair and a new interceptor to the city plant was
cost effective and should be begun as soon as possible.  For this
reason EPA circulated on March 10, 1977, a negative declaration in-
dicating that an EIS was not required for this portion of the 201
project allowing repairs and construction to proceed.  These measures
are currently being implemented as proposed.

The Facility Plan outlines measures to be used to control urban
runoff which is a significant problem.  The Plan's recommendations
are very worthwhile and should greatly improve water quality if im-
plemented.  However, little effort along these lines have been in-
stituted to date, a situation that must change to achieve prescribed
water quality goals.
Several citizens and elected officials raised concerns as to possible
future residential development along the proposed line between the present
lagoon and the proposed Midway Site on the Meadow Industries property.
EPA is tasked with the responsibility under PL 92-500 of reviewing
the adverse secondary impact of projects supported with federal funds.
The proposed secondary effluent transmission line or interceptor connect-
ing the existing lagoon to the proposed Midway Site could induce resi-
dential development which, if extensive, could create the following
adverse effects:

   1)  Overload the tertiary plant with raw sewage jeopardizing plant
       operations designed to meet permit limitations.

   2)  Result in large scale residential development which could:

       a)  encrouch upon the 100 year flood plain which would create
           a higher flood hazard;
       b)  change portions of the area from agricultural land to
           residential development thereby reducing the agricultural
           productivity of the area;
       c)  increase non-point pollutant runoff from urbanized areas
           located close to the river;
       d)  encrouch upon the few small wetlands in the valley which
           are valuable wildlife habitats.

EPA is interested in reducing such potential adverse effects and
regards it as essential that the amount of raw sewage flowing to the
Midway Site not exceed the design of the plant.  The other potential
adverse effects are best mitigated by local land use planning.
                                  -16-

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On August 9, 1977 a public referendum was htfeld on a $1.5 million bond
issue.  These funds were intended for use as follows:

      - $800,000 for potable water distribution system improvements.
      - $400,000 for a new Fish Creek flow line which is the principal
        source of Steamboat Springs drinking water.
      - $300,000 for the local share of sewer line inflow and infiltra-
        tion (I&I)  repairs and a new interceptor between the Mt. Werner
        plant and the present city lagoons.  In addition, funds would
        be used for Step 2 design.

Other items on the ballot included an increase in the city sales tax
and water meters which helped lead to the defeat of this bond issue.
However, the City Council determined that the I and I repairs and the
new interceptor were too important to risk forfiture of federal match-
ing funds.  As a result, on August 11, 1977, council allocated suffi-
cient funds from the contingency budget so that these related 201
efforts could proceed without interruption.
Mitigating Measures

Mitigating measures which will be required by EPA in order to reduce
the primary and secondary impacts of this project include:

   1) A revegetation plan for the interceptor line corridor between
      the present city lagoon site and the new Meadow property site.

   2) Compliance with the recommendations of the archaeological
      survey currently being conducted.

   3) Compliance with 404 permit conditions for interceptor stream
      crossings.

   4) Special provisions for protecting public health as required
      by state and local agencies for application of effluent and
      disposal of sludge.

   5) The Step II final design should demonstrate energy conservation
      measures to be incorporated into the design.

   6) At the request of, and in conjunction with Routt County; a
      restriction shall be imposed on Steamboat Springs limiting
      taps on the new Midway interceptor to existing sanitation
      districts (Steamboat II and Riverside) and the Sleepy Bear
      and KOA developments as currently zoned.  Exempt from this
      provision are all existing residences as of the date of the
      Step II grant.
                                  -17-

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Other Options

The Mt. Werner Water and Sanitation District proposed that a sub-
alternate be included with the dual MAWT/ABT system at Midway.  This
modification would expand secondary treatment and disinfection systems
at the Mt. Werner lagoon and pump approximately 175 acre-feet of
treated effluent to the nearby LTV golf course  (see Study Map 2).  It
was argued that this will augment stream flow in Fish Creek by re-
quiring less diversion for golf course irrigation and effectively
re-use nutrients in the effluent.  This sub-alternate was approved
by the Steamboat Springs City Council for inclusion with the 201 plan.
Howeverf EPA after careful consideration has concluded that this would
not be a cost-effective measure, is not necessary to meet the discharge
permit conditions and provided unproven benefits for maintaining
minimum stream flow in Fish Creek.

Future Actions
EPA expects to complete the Step II grant to Steamboat Springs by
September 30, 1977, in order to commit Fiscal Year 76 funds.  All
responses to this EIS must be received by EPA no later than September
27, 1977, in order to be considered prior to this grant approval.  EPA
hopes the interested individuals will remain involved in expressing
their views to EPA, the Colorado Health Department, and especially
to Steamboat Springs as this project moves through design and on to
construction.  Design and specifications will be completed by an engineering
firm under the direction of the engineering staff of Steamboat Springs.
EPA trusts Steamboat Springs will continue to involve citizens and other
government agencies during this design process to allow for the fullest
possible discussion of alternatives.  EPA suggests that the city hold
a  series of informational meetings for the public to discuss the
design  and construction stages of the project as these items are
developed.
                                    -18-

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                           Water  Environment
                               Goals
In this section agency and citizen water quality aspirations are
summarized into policies and translated into needed facility additions.
The facilities additions are referred to as structural and non-structural
alternatives and are developed to implement the policies.   The discussion
begins with a review of the expressed citizen goals and agency regulations
and is followed by a description of the design engineer's  recommended
design criteria.

The 201 facilities planning for Steamboat Springs is fortunate to
have participation from an active and inquisitive citizenry manifested
in the Citizen's Advisory Committee (CAC).   The goals of this committee
were published in the January 23, 1975 Steamboat Pilot and they were
unusually succinct and specific (Table Il»-l).  The Pilot also published
a lengthy questionnaire on numerous water-related topics (WME, Volume I,
pp. 11122-33).  Responses to this questionnaire indicated  that the
problem of Yampa River quality/flow and water/sewer systems was the
third most important priority behind the county's problems of managed
growth and improvements in the local economy.   Additional  interest
was indicated for the development of an areawide wastewater treatment
system, a raw water storage and treatment system, and consolidation
of the nine districts that handle the area's sewage effluent.

The members of the CAC served as "watchdogs" during the entire 201
Step 1 process, meeting at least monthly over the last year and a
half.  The work effort of the project engineer—Wright-McLaughlin,
as well as that of the environmental consultant—Weiner &  Associates,
was continuously reviewed by the CAC for its achievements  toward
their expressed goals.

The Colorado Department of Health, the US Environmental Protection
Agency (EPA), and Routt County are currently the principal regulatory
agencies associated with water quality in the Steamboat Springs area.
The State of Colorado has exercised its option under the Water Pollu-
tion Control Act of 1972 as Amended (PL 29-500), and it has assumed
the primary responsibility for administering the National  Pollutant
Discharge Elimination System (NPDES).   This system allows  wastewater
permits to be issued by the Health Department's Water Quality Control
Division and it  prescribes allowable discharge levels for wastewater
effluents.  Another arm of the Health Department, the Water Quality
Control Commission, helps administer the available federal funds for
planning and constructing wastewater facilities, in conjunction with
the EPA.   This commission establishes priorities for allocating
these funds within the State of Colorado.
                                -19-

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                                                                             TABLE  II-l
                                                               STEAMBOAT SPRINGS REGIONAL SERVICES  AUTHORITY

                                                              WASTEWATER MANAGEMENT FACILITIES PLANNING STUDY
                                                                    WATER-ORIENTED GOALS AND POLICIES
                                                                 BY STEAMBOAT CITIZENS ADVISORY COMMITTEE
     Our goal  is an enjoyable Yampa  river  -  enjoyable  from  its headwaters to
the county line.  We believe that  the  stream banks and water should be
protected from further degradation and that  restoration and  improvement of the
river should be undertaken so that it  becomes a  flourishing  environment for
fishing, and swimming, and as a wildlife habitat.  A green  Yampa Valley will
also serve to shape our urban area by  helping to  control urban sprawl.

1.  The Yampa River and its tributaries should be fishable  and swimmable, suitable
    for body contact anywhere in Routt County,  and the water should be less
    polluted when  it leaves the study  area than when  it enters.

2.  Wastewater management systems  shall be designed  to meet  the 1985  federal water
    quality goals  "that the discharge  of pollutants  into navigable water be
    eliminated by  1985. '  This goal  is interpreted to mean  that water discharged
    to  the Yampa be essentially of the same  high  quality as  the natural Yampa
    R i ver water

3.  One of the alternatives to be  investigated should  be land  treatment.   If at
    all possible,  nutrient-laden wastewater  should be  utilized for agricultural
    and reclamation purposes rather than being discharged  into the stream.

4.  An  advanced  level of waste treatment is  necessary  to provide a realiable and
    consistently high quality of effluent  discharged  to the  Yampa River

5.  All alternatives  investigated  must enhance the agricultural industry of Routt
    County and  the SSRSA study area to provide a  diverse economy for  the stability
    of  the region.

6.  Urban storm  runoff and urban snowmelt  carry many harmful pollutants to the
    stream.  Alternatives must consider the  possible storage and treatment of
    runoff to achieve the clean water  goals  articulated by Congress,   to mitigate
    local flooding and to keep wastes  out  of the  stream.   Investigate the
    detrimental  effects of the mineral  and thermal pollution that the natural
    springs contribute to the Yampa.

7.  The implementation  of  this  study shall not  interfere with the established
    minimum flow in the  Yampa  River, and if  possible the minimum flow should
    be increased.
8.  Flood plain management should include flood plain regulations, acquisition of
    flood plain lands for recreation, fish and wildlife.  The value of structural
    vs. non-structural management as well as relocation aspects deserve study.
    In so far as possible, flood plain management should enhance the stream's
    natural  eco-systems,

9.  The program should be designed to provide controlled public access to the
    Yampa.  Enhancement of the natural beauty of the River should be encouraged.

10.  The type and extent of treatment facilities shall be coordinated with public
     agency planning efforts and Master Plans;  ideally providing green and pro-
     ductive open lands.

II.  Existing utilities (water, sewer, roads) in existing developments should  be
     rehabilitated to modern levels  to provide a better standard of living and
     to  encourage growth within Steamboat Springs and other existing water and
     sanitation districts, furthering the theme of Urban Conservaiion.

12.  The means of curtailing winter  bleeding and other  infiltration problems should
     be studied to provide the best  economic practice in terms of water resources
     and wastewater treatment.

13   The environmental  resource should be protected; resources should be  managed
     in cooperation with all other systems and goals.

14.  Agricultural, industrial, and other positive endeavors which broaden the
     economic base and  best compliment our resources should be encouraged.

15.  Wastewater plans should be laid  to positively aid  in water resource  management.

16.  This study stall be cognizant of costs, and the greatest benefit to  cost  re-
     lationship shall be of prime concern.

17.  Consolidation and  unification of the various water and sanitation districts
     should be studied  in consideration of financial and organizational  .-alues.

18.  The  treatment facilities  shall  be designed and constructed  in phases to
     accomodate expansion  in increments according to population and/or needs.
NJ
o
                                                                                                   Source:  Wright-McLaughlin  Engineers,  Oct.  1975

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Another function of the Water Quality Control Commission has been to
set up water quality standards for the state's streams.  This role
has resulted in establishing four categories:  A-^, A2, B^, and B2
(Table I of Appendix A).  Streams with the A ratings are those that
exhibit a high quality so they can be used for normal raw water
purposes, including primary contact recreation (swimming, skiing,
etc.); streams with B classifications are those that have a current
and future use for non-contact recreation (primarily fishing, etc.).
The numerical designation A, or B^ refers to the designation for a
cold water fishery and A2 or B2 refers to a warm water fishery.
Major streams in the state have been placed into one of these four
categories; and each one represents a minimum water quality that must
be maintained at all times, except during drought periods when flow
drops below the seven-day, 10-year average.   In the project area,
the YSmpa River and all of its tributaries are currently classified
as B-^ class streams—which is the cold water fishery designation.
A summary of its water quality standards are given in Table I  of
Appendix A, along with the standards for the other three classes.

An important corollary to maintaining a certain stream classification
is the control of its point sources of discharge.  The Water Quality
Control Commission has also established standards for this and they
are displayed in Table II of Appendix A.  These standards represent
the basis of existing permits and most permits conform to them.
Routt County has also adopted similar standards,  shown in Table lit
of Appendix A, and they are more stringent than the existing discharge
permits   (Table IV of Appendix A).  This departure from state standards
has not been tested by a legal confrontation, yet it may not occur if
the state's 1977 permit more closely reflects the county's standards.

In addition to the state and county discharge standards, the Federal
Water Pollution Control Act (as Amended) requires that by July 1, 1977,
all sewage treatment plants must provide a minimum of secondary treatment
to all wastewater plant effluent.  Essentially, "secondary treatment"
requires a minimum of 85 per cent removal of the organic constituents
(biological oxygen demand — BOD) and suspended solids.  A Best Practical
Waste Treatment Technology  (BPWTT) must also be applied to these
effluents before July 1, 1983.  This BPWTT may consist of alternatives
employing treatment and discharge to navigable waters, land application
techniques, or direct reuse.  The form it takes should be the most cost
effective alternative that provides the treatment necessary to attain
the 1983 water quality goal.  This goal provides for the protection
and propagation of fish, shellfish, and wildlife and also provides
for recreation in and on the water  (fishable/swimmable goal).

When streams are assigned a particular water quality classification
(A^ or B^ etc.,) and are regulated for effluent discharges, they are
also classified as either effluent limited or water quality limited.
                                  -21-

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The effluent limited class are those that meet the present water
quality standards and will continue to meet them in the future if
adequate "secondary treatment" is provided.  The water quality limited
class consists of those segments where water quality does not now
meet the applicable standards and/or is not expected to do so, even
after compliance with the secondary effluent limitations.

Further order is imposed on the streams, by the development of an
over-all river basin plan.  This plan is required by section 303  (e)
of PL-92-500 and is intended to establish goals and priorities for
the Steamboat Springs area the applicable plan has been completed
and is entitled the "Water Quality Management Plan for the Green River
Basin"  (McCall-Ellingson & Morrill, Inc. April 1974).  Based on com-
puter model simulations conducted under the study, the SSRSA area
is assigned maximum BOD allocations.  The BOD allocation for the
SSRSA area totals 240 Ibs. per day, of which 238 pounds are allocated
to the districts studied in this report and 2 pounds are allocated to
Bear Pole Ranch.  The study also designated the Yampa River as water
quality limited for ammonia, based on the EPA's toxicity criteria.
Consequently, the study recommended nitrification controls for the
basin's wastewater treatment plants.  This recommendation, in conjunc-
tion with the BOD allocations, has been accepted by the Colorado
Water Quality Control Commission.

Pursuant to the ammonia recommendation, Wright-McLaughlin Engineers
have proposed a variable ammonia allocation for the SSRSA  (June, 1977).
It is based on the toxicity of ammonia to aquatic life, projected peak
sewage  flows in 1985 and 2010, and the assimilative capacity of the
Yampa during 7-day, 10-year low flows.  Calculations with these para-
meters provide allowable discharges of ammonia-nitrogen varying from
2.8 to  9.0 mg/l for 1983 criteria and 0.5 to 9.0 mg/& for 1985 criteria
 (Wright-McLaughlin, June, 1977).  However, only 1983 criteria are
deemed  applicable to this project and resultant allowable discharges
have been modified further to accomodate the compromise program.  These
accomodations are shown in Table II-2 for 1985 projected flows and they
vary between a lower limit of 43 pounds per day or five mg per &, which-
ever is greater and an upper limit of nine mg per £ _

Other major effluent criteria also are shown in Table II-2  yet a more
complete list of these recommended standards is shown in Table V of
Appendix A.  This list delineates detailed guidelines for effluent
discharges that would conform to 1978 and 1983 criteria.  It has been
developed by Wright-McLaughlin Engineers and provides the basic environ-
mental  framework for this 201 project.  This plan has been formally
 approved by  the  Colorado Water Quality Control Division and pro-
 vides  a sound basis for achieving the 1983 goal of fishable/swimm-
 able water quality.  This goal can be achieved, provided additional
                                     -22-

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                              TABLE 11-2

                   1983 EFFLUENT DESIGN CRITERIA
Parameter
Concentration
                 Rationale
BODr
238 pounds/day
      or
10 mg/&
SS
    - N
10 mg/ I

July 1 -
Oct. 15

Other
Months
5mg/£ or
43 lb/day2

9mg/£
                   5 mg/?,
Cl Residuals
0.028 mg/£
Fecal Coliforms
Variable so river
concentration is less
than 1000 colonies per
100 ml
303 Basin Plan allocation

>85% removal from influent

>85% removal from influent

303 Basin Plan recommends
nitrification; Wright
McLaughlin Engineers
recommends these allocations
based on EPA's toxicity
limits, 1985 projected
sewage flows and 7-day,
10-year low flows.

Wright-McLaughlin's
recommendation; with
1985 projected flows
and 7-day, 10-year low
flows, the resultant
river concentration
would be less than 1 mg/£
the upper limit for non-
polluted streams.

Wright-McLaughlin's
recommendation, based
on EPA's toxicity limits
projected 1985 sewage
flows and 7-day, 10-year
low flows.

EPA standards
-'-Computed by EPA on a monthly basis.

^Whichever is more.
                                      -23-

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programs are implemented to control agricultural and urban non-point
runoff.  The need  for  such programs is  further  explained  in  this chapter,
while specific programs are recommended in  Chapter VIII,  Mitigation
Measures.

                 Existing Water  Quality and Quantity

The waters of the  project area can be divided into  two main  categories:
surface waters and groundwaters.   Both  types are used  for domestic and
agricultural purposes  and must be  protected to  insure  their  continued
value.  The surface waters are direct receivers of  the secondary effluent
from the existing  plants; the groundwaters  are  indirect receivers.  Both
waters are in contact  with each  other although  the  quantity  and quality
of surface waters  are  generally  more  variable.  The text that follows
highlights the existing information on  these environments.

Surface Water

The important surface  waters of  the project are running waters, rep-
resented by the  Yampa  River and  some  of its tributaries (Study Map 1).
The headwaters of  the  Yampa River  are in Garfield County, about five
miles  east of Trappers Lake.  From here it  flows north to Steamboat
Springs, then west to  Dinosaur National Monument where it joins the
Green  River.  As it flows through  the study area, it picks up Walton,
Burgess  and Fish Creeks  from the east and Spring, Butcherknife, Soda and
Slate  Creeks  from the  north.  None of these creeks  are major tributaries,
yet  they are  important to the quality and quantity  of  the Yampa River
in the study  area.  The  text that  follows highlights the existing infor-
mation on  these  waterways and it is divided into a  discussion on water
 flow and water  quality.

Water  Flow;   Most information on the  study  area's water flow has been
 collected  on  the Yampa River by  the United  States Geological Survey
 (USGS).   Their  permanent gaging  station, located at Steamboat Springs,
 Colorado,  has been operative since 1904. The first 67 years of its
 operation  produced an  average flow of 469 cubic feet per second (cfs).
 Its maximum instantaneous  flow occurred on  June 14, 1921 with a value
 of 6,820 cfs;  the minimum daily  flow  occurred on September 8, 1934
 with a value  of 4 cfs.  This  flow  accumulated from  a drainage basin
 of 604 square miles.

 Values for the  last reported year  of  operation appear  in Figure 3.
 During this period the maximum  instantaneous flow was  5,790  cfs
 (April 26)  and  the minimum  daily flow was 58 cfs  (September  23).   Only
 the minimum flow differed radically  from the extreme values  of the
 historical records.

 The low flow values for  the Yampa  are especially important to design
 engineers  since they are interested  in  the  river's  ability to dilute
                                           -24-

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i
NJ
         O
            3,000
            2,500
            2,000
            1,500
            ,000
             500
                         NOV.     DEC.    JAM     FEB.     MAR.     APRIL    MAY    JUNE    JULY    AUG.    SEPT
                            FLOW PATTERN OF YAMPA RIVER AT STEAMBOAT SPRINGS


                                          FIGURE 3

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sewage effluent.  For these purposes, the Colorado Water Quality
Control Division recommends a design period that estimates a seven-
day average of low flows, occurring once in 10 years.  These estimates
were made by McCall-Ellingson and Morrill, Inc. in their Green River
Basin Study  (1974), and they developed  a value of 27 cfs for the Yampa
at Steamboat Springs.  This value was computed on an annual basis,
according to USGS standards.  Another analysis was provided by Wright-
McLaughlin Engineers in their 201 Facilities  Plan  (1975),  it was com-
puted on a monthly basis.  They estimated values of 67 cfs for January,
440 for May, 60 for August and 33 for September.  Their  September  value
of 33 was very close to the 27 cfs estimated  by McCall-Ellingson and
Morrill, Inc.

The flow rates for the Yampa's tributaries in the study  are not well
documented.  However, Dr. Robert Pennak observed that Walton, Fish and
Soda Creeks  contribute substantial flows in July  (Wright-McLaughlin
Engineers, October 1975).  In September of that same year, the USGS
recorded flows of 1.2 cfs for Walton Creek, 1.6 cfs for  Fish Creek,
0.5 cfs for  Spring Creek, 0.8 cfs for Butcherknife Creek and 1.6 cfs
for Soda Creek  (Table II-8).  These values were recorded when the  Yampa
was flowing  about 100 cfs.  They also found that Slate Creek was dry
during this  same period.

The Corps of Engineers did some additional studies on these streams
and calculated their drainage areas and peak  flood flows (Department
of the Army, Corps of Engineers, February 1976).  The drainage areas
are shown  in Table II-3,  including the  overall one for the Yampa River.
All drainage areas include regions that drain into a given river or
 stream,  above the location cited in the table.  Based on this informa-
 tion,  Walton, Fish and Soda Creeks would contribute the  most local
 tributary  flow, while the others would  contribute lesser amounts.   The
peak  flood flows  are  shown in Table II-4, which also includes estimations
 for the  Yampa River.  The 100-year flood would occur with  an average
 frequency  of one  in one  hundred years and the 500-year flood is shown
 in Study Map 1.   If the  reader desires  to know coverage  of the 500-
 year  flood,  contact the  Sacramento Office of  the Corps of  Engineers or
 the City of Steamboat Springs.

                                TABLE II-3

                              DRAINAGE  AREAS

                                   Area
     River  or Stream              (sq. miles)                Location

     Yampa  River                    604           USGS  gaging station
     Soda Creek                        20           Corporate limit
     Butcherknife  Creek                4           Corporate limit
     Spring Creek                      8           Corporate limit
     Fish Creek                        25           Upper gaging station
     Walton Creek                      42           Gaging  station
     Burgess Creek                    4           Near  Storm Meadows Dr.
                                      -26-

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I
NJ
River or Stream



Yampa River



Soda Creek



Butcherknife Creek



Spring Creek



Fish Creek



Walton Creek



Burgess Creek
       TABLE II-4



      FLOOD FLOWS






Locations



USGS gaging station



Corporate limit



Corporate limit



Corporate limit



Upper gaging station


Gaging station



Near Storm Meadows Dr.
                                                                           Peak Flow  (cfs)


                                                                       100-yr.	500-yr.
8,000
1,300
320
650
1,800
2,700
360
20,000
2,900
1,300
2,400
4,600
5,600
1,400

-------
Water Quality:  The quality of the Yampa River is well known at
Milner, Colorado, and at the confluence with Oak Creek.  The Milner
station is about 11 miles downstream  from  Steamboat  Springs and the
Oak Creek station is about seven miles upstream.  The data from these
stations have been collected by the Colorado Health  Department
(Colo. HD) and are displayed in Tables II-5 and II-6.  This infor-
mation is compared with the Colorado  standards for B-^ streams.  Addi-
tional data has recently been collected by the USGS  and  Routt County
as part of a regional study on coal development and  a 208  study
(USGS open-file reports 76-367 and 76-368).  Their preliminary data
is displayed in Table II-8, part of which  has been used  to further
analyze and evaluate the Yampa, using two  operational water-quality
models  (Bauer, ejh al_., 1976, in review).

The health department's analysis shows that the Yampa River has histori-
cally violated standards for B-^ streams.   The Oak Creek  station reports
violations of dissolved oxygen on two occasions, and the Milner station
reports it on four occasions.   The Milner station also  shows viola-
tions in  temperature, pH and fecal coliforms.  The temperature and pH
violations appear to be of natural origin  but the violations of fecal
coliforms are caused by organic pollution  (BOD).  The low  levels  of
dissolved oxygen are probably also caused  by excessive organic pollution
although  this has not been determined with certainty.

Other  guidelines for stream quality come from the EPA's  research  report,
Water  Quality Criteria 1972 and Quality Criteria for Water  (1976), which
provide recommendations for the maintenance of a healthy aquatic  en-
vironment.  These guidelines indicate that the Yampa possesses good
chemical  water quality in the vicinity of  the project area.   This
assessment  is based partially on general water quality data of Tables
 II-5  and  II-6, plus trace element data of  Table II-7.  Other water
quality information on pesticides, collected by the  USGS near Steamboat
 Springs,  indicates potential concentrations are beyond levels of  detec-
 tion.   While  information on radioactivity  shows that alpha and beta
emissions occur  at natural levels and could not be considered a hazard
 (Milt Lammering, EPA, personal communication).
 1These violations occurred prior to 1972;  their values  are  considered
  questionable by the Colorado Water Quality Control  Division.
 o
  The earlier evaluation in the draft EIS had indentified suspended
  solids, lead and zinc as potential factors for degrading water  quality.
  The suspended solids were dropped from consideration due to inaccurate
  data interpretation; lead was dropped since the hard waters of  the
  Yampa Riyex do not promote the toxic condition that was identified
  earlier -using a soft water designation; and zinc is still  being eval-
  uated to determine its true toxic potential.
                                      -28-

-------
                                  TABLE  I1-5





              WATER QUALITY OF YAMPA RIVER AT MILNER, COLORADO




Sarapler: Colorado Dcpt.  of Health           Sample period:  3/26/68 to 5/7/75

Value Min .
Water Temp. °F 32
Turbidity 2 . 7
JTU
Conductivity 54
umhos/cm
Dissolved Oxygen 5 . 0
mg/1 (7/22/69)
BOD 5-day 0.5
mg/1
pH 7.2
(6.7.72)
TDS 68
mg/1
Suspended Solids 0
mg/1
NH3-N 0
mg/1
NO2-N 0
mg/1
NO3-N 0
mg/1
PO4 0
mg/1
Cyanide
mg/1
Total Hardness
as CaC03 24
mg/1
Calcium as CaCO., 16
mg/1
Magnesium 2
mg/1
Sodium 1
mg/1
Chloride 0.1
mg/1
Date of Colorado B.
Maximum Stream
Max. Value standards
72 7/22/69 68
169.0 4/6/72 No increase
>10
910 6/15/70
12.5 >6.0

4.0 4/16/68

9.2 7/22/69 6.0-9.0

398 2/18/69

163 4/22/75

0.5 3/4/75

0.03 1/24/72

1.15 1/14/75

1.4 6/15/70

0

236 2/18/69

120 4/3/74

28 2/18/69

45 2/18/69

1.3 2/18/69

Late of Colorado E
Maximum Stream
Value Min. Max. Value Standards

Sulfate 5 128 2/18/69
mg/1
Fluoride 0.1 4.0 6/5/68
rag/1
Arsenic o
mg/1
Boron 0 0.12 10/4/71
HKJ/1
Cadmium o
mg/1
Chromium (+6 ) 0
mg/1
Copper o
mg/1
Iron 1.6 1/11/73
mg/1
Lead 0 0.044 5/7/75
mg/1
Manganese 0 0.1 1/11/73
mg/1
Molybdenum 0 0.04 4/16/74
mg/1
Silver 0 0.019 5/7/75
mg/1
Zinc 0 0.36 4/16/74
mg/1

Selenium 0 0.005 6/5/68
mg/1

Total Coliforms 33 23,000 11/26/68
per 100 ml

Fecal Coliforms 2 3300 3/26/68 < 1000
per 100 ml

Mercury 0 0.0002 1/24/72
mg/1


-------
                                   TABLE I1-6





                  WATER QUALITY OF YAMPA RIVER ABOVE OAK CREEK




Sampler: Colorado Dopt. of Health            Sample Period:  11/17/70 to 5/5/75
Value
Water Temp. °F

Turbidity
JTU

Conductivi ty
umhos/cm

Dissolved Oxygen
mg/1

BOD 5-day
mg/1

pH


NHj-N
1 mg/1
U)
O N02-N
1 mg/1

N03-N
mg/1

P04
mg/1

Cyanide
mg/1

Total Hardness
as CaCO3
mg/1
Calcium as CaCO3
mg/1
Magnesium
mg/1
Sodium
rag/1
SAR

Chloride
mg/1

Sul fate
mg/1
Min.
32

4


75

5.0
(11/1/71)

1.0


7.1
(6/7/72)

0


0


0


0


0



86

59

6

3

0.2

4


10

Date of Colorado BI
Maximum Stream
Max. Value Standards
65 7/24/72 68

98 12/1/70 No increase
>10

476 2/3/71

12.2 >6.0


9.0 1/15/75


8.9 8/14/74 6.0-9.0


0.16 5/7/73


0.037 9/25/73


1.22 1/15/75


0.4 2/3/71


0.6 1/6/72



233 2/3/71

159 2/3/71

19 1/11/71

18 2/3/71

0.6 2/3/71

12 ll/Jb/70


84 4/3/74

Value Min.
Fluoride 0.1
mg/1

Arsenic
mg/1
Boron 0
mg/1

Cadmium
mg/1

Chromium (+6 )
mg/1

Copper 0
mg/1

Iron 0.02
mg/1

Lead 0
mg/1

Manganese
mg/1

Molybdenum 0
mg/1

Silver
mg/1

Zinc 0
mg/1
Selenium 0
mg/l
Total Coliforms 2
per 100 ml
Fecal Coliforms 1
per 100 ml
Mercury 0
mg/1

TDS @ 180 °C 85
mg/1

Suspended Solids 218
mg/1
Date of Colorado 1
Maximum Stream
Max. Value Standards
0.8 11/25/70


0

0.12 10/4/71


0


0


0.06 11/25/70


2.0 5/5/75


0.12 11/25/70


0


0.01 5/5/75


0


0.55 5/7/73

0.002 11/12/74

30,000 2/3/71

300 2/3/71 <1000

0.0005 11/17/70 0.002


341 2/3/71


518 1/15/75

-------
                                   TAB^E  I1—6





                   WATER QUALITY OF YAMPA RIVEK ABOVE OAK CREEK





So-Tipler: Colorado  Dept. of Health            Sample Period:   11/17/70 to 5/5/75


Value Min.
Water Temp. °F 32

Turbidity 4
JTU

Conductivity 75
umhos/cm

Dissolved Oxygen 5.0
mg/1 (11/1/71)

BOD 5-day 1.0
mg/1

pH 7.1
(6/7/72)

NH3-N 0
mg/1

N02-N 0
mg/1

NO3-N 0
mg/1

PO4 0
mg/1

Cyanide 0
mg/1

Total Hardness
as CaCO3 86
mg/1
Calcium as CaCOj 59
mg/1
Magnesium 6
mg/1
Sodium 3
mg/1
SAR 0.2

Chloride 4
mg/1

Sulfate 10
mg/1

Date of Colorado B-^
Maximum Stream
Max. Value Standards
65 7/24/72 68

98 12/1/70 No increase
>10

476 2/3/71


12.2 >6.0


9.0 1/15/75


8.9 8/14/74 6.0-9.0


0.16 5/7/73


0.037 9/25/73


1.22 1/15/75


0.4 2/3/71


0.6 1/6/72



233 2/3/71

159 2/3/71

19 1/11/71

18 2/3/71

0.6 2/3/71

12 ll/2b/70


84 -4/3/74




V alue Min .
Fluoride 0.1
mg/1

Arsenic
mg/1

Boron 0
mg/1

Cadmium
mg/1

Chromium (+6)
mg/1

Copper 0
mg/1

Iron 0.02
mg/1

Lead 0
mg/1

Manganese
mg/1

Molybdenum 0
mg/1

Sliver
mg/1

zinc 0
mg/1
Selenium 0
mg/1
Total Coliforms 2
per 100 ml
Fecal Coliforms 1
per 100 ml
Mercury 0
mg/1

TDS @ 180 °C 85
mg/1

Suspended Solids 0
mg/1
Date of
Maximum
Max. Value
0.8 11/25/70


0


0.12 10/4/71


0


0


0.06 11/25/70


2.0 5/5/75


0.12 11/25/70


0


0.01 5/5/75


0


0.55 5/7/73

0.002 11/12/74

30,000 2/3/71

300 2/3/71

0.0005 11/17/70


341 2/3/71


315 1/15/75

                                                                                                        Colorado B
                                                                                                           0.002

-------
                            TABLE I1-7

                 DISSOLVED  TRACE ELEMENTS IN THE
               YAMPA RIVER  NEAR STEAMBOAT SPRINGS1
Parameter
Arsenic
Cadmium
Cobalt
Copper
Iron
Lead
Manganese
Nickel
Vanadium
Zinc
Antimony
Selenium
Number
of
Samples
4
5
5
5
5
5
5
5
5
5
4
5
Mean
(mg/£)
0.0003
0.0004
0.0002
0.002
0.066
0.0008
0.024
0.0008
0.0017
0.004
n.d.
n.d.
Maximum
(mg/£)
0.001
0.001
0.001
0.005
0.110
0.002
0.050
0.002
0.0026
0.020
n.d.
n.d.
Minimum
(mg/£)
n.d.2
n.d.
n.d.
0.001
0.020
0
0.010
0
0.0004
0
n.d.
n.d.
Collected by USGS between 8/25/75 and 8/30/76, values subject to
 further verification.
"Not detectable.
                                      -32-

-------
Phosphate and nitrates in the Yampa River vary considerably between
Oak Creek and Milner.  Although both of these compounds can cause algal
nuisances, the nuisance levels have not been determined for the Yampa
River ecosystem.  At Oak Creek phosphate-phosphorus ranged between
zero and 0.1 mg/Ji, and at Milner, between zero and 0.4 mg/£.  The nitrate-
nitrogen ranged between zero and 1.22 mg/& at Oak Creek and between zero
and 1.15 mg/£ at Milner.

The data collected by the USGS and Routt County is displayed in Table II-8:
it is preliminary information that is subject to further verification.
It includes water quality values for the Yampa River between Agate Creek
and the Elk River, plus values for tributaries and effluent discharges.
The sample locations are shown on Study Map 1, with the "Y" desig-
nations referring to Yampa River sites, the "T" designations to tribu-
taries and the "E" designations to sewage effluents.  The range of
values for each parameter are reported as minimum and maximum; when only
one value was collected, it was reported as maximum.  The data were
collected over a 24-hour period.

The Yampa River sites showed values that were within the state's
standards for B-^ streams, with the exception of site Y8, the most
downstream site.  It had a pH value of 9.1, which is outside the
accepted range of 6.0 - 9.0.  The values for phosphate-phosphorus
ranged from zero to 0.74 mg/£; the values for total phosphorus ranged
from zero to 0.99 mg/&.  The values for nitrate-nitrogen varied between
zero and 0.17 mg/£.

The conductivity values for the Yampa River are indicative of its
concentrations of total dissolved solids.  These concentrations usually
range between 54 percent and 96 percent of the value for conductivity
(Hem, 1970).  Consequently, it is noteworthy that the conductivity
values average around 280 for stations Yl through Y3 and around 370
for the remaining stations  (Study Map 1).  This observation implies
that inflow near the city of Steamboat Springs is responsible for
increasing total dissolved solids in the Yampa River, perhaps by as
much as one-third.  This inflow comes mainly from the hot sulfur
springs east of town, which contribute an estimated 250 gallons per
minute at 1450 micromhos per centimeter and the cold springs west of
town, which contribute an estimated 50 gallons per minute at 7500
micromhos per centimeter (R.E. Moran, 1976, USGS, oral communication).

The tributaries of the Yampa were all within the standards for B-^
streams.  Their conductivity values were lower than the Yampa River
sites, which indicates they contain fewer dissolved solids.
                                       -33-

-------
                                                                               TAhlf 11-6


                                                                  HAT UK QUALITY CF YAMl'A  HTVEK HASJU1


                                                                        Sei-tcii-Uir 23, 24,  1975

Station
Number
Yl

Tl

Y2

El

T2

T3

Y3

T4
i
IjJ
I T5

Y4

E2

Y5

E3

E4

Y6

E5

Y7

Y8

Flow Samj-'lu
<_i"S Value
98 Min.
Max.
1.2 Min.
Max.
Min.
Max.
0.8 to 1.6 Min.
Max.
1.6 Min.
Max.
0.5 Min.
Max.
Ill Min.
Max.
0.8 Min.
Max.

1.6 Min.
Max.
97 Min.
Max.
1.7 Min.
Max.
99 Min.
Max.
0.01 Min.
Max.
0.01 to 0.03 Min.
Max.
104 Min.
Max.
0.12 Min.
Max.
94 Min.
Max.
104 Min.
Max.

Temp .
6.5
11.5
7.0
17.0
11.0
12.5
7.0
23.0
4.0
14.0
6.5
13.0
6.5
13.5
6.0
8.5

4.5
11.5
7.0
13.5
10.0
17.0
7.0
14.5
8.0
17.0
8.0
16.0
6.5
14.0
8.0
22.0
7.0
14.0
7.5
14.0

umhos/cm
280
290
50
75

275
310
420

50

50
260
288
105
195

180
220
350
375
320
410
360
380
160
800
850
1200
370
380
700
900
360
380
270
380

pH
8.4
8.8
7.8
8.9
8.6
8.8
7.3
8.7
7.8
8.3
7.6
8.0
8.3
9.0
7.4
8.0

6.4
7.4
7.1
8.1
7.2
8.7
7.2
8.7
7.3
8.8
7.2
7.9
7.2
8.9
7.1
7.6
7.8
8.9
8.2
9.1
Dissolved
mg/1
7.0
9.8
7.1
9.6
7.8
9.5
5.8
17.6
7.4
9.2
7.6
8.5
7.2
9.3

9.6

8.0
10.8
7.9
10.2
5.0
16.0
7.8
13.2
5.6
12.4
1.0
4.4
7.4
11.6
1.0
6.2
7.2
11.4
7.0
10.7
NO (N) -NO, (U)
mg/1

0.01

0

0.01
0.04
0.06

0

0
0.01
0.02
0.02
0.04


0.04
0
0.03
0.34
0.43
0.09
0.17

24
2.4
4.7
0.03
0.05
4.5
4/7
0.01
0.05
0.01
0.02
•'H -i!
3
mg/1

0

0

0
16.0
18.0

0

0
0
0.07

0


0
0
0.03
7.7
8.4
1.4
2.1

0.16
2.4
4.7
0
0.07
0
0.08
0
0.08
0
0.03
Jrganic N
IT.CJ '1

0.19

0.15

0._>3
4.0
19.0

0.08

0.08
0.25
0.65
0.14
0.55


U.14
0.30
0.84
1.4
6.2
1.2
1.8

4.3
0.3
7.3
0.31
0.67
4.4
5.1
0.38
'1.6
0.31
1.4
P04-P
mg/1

0.02

0.01

0.04
7.2
7.4

0.01

0.01
0.03
0.12
0.01
0.03


0.01
0.01
0.11
2.7
2.8
0.65
0.74

14
3.6
11
0.06
0.14
8.6
9.1
0.02
0.10
0.04
0.14
Total P
mg/1

0.04

0.02

0.04
8.7
9.6

0.01

0.01
0.05
0.19
0.02
0.05


0.02
0.05
0.16
3.4
3.9
0.89
0.99


8.7
28
0.10
0.18
10
11
0.09
0.24
0.10
0.16
Total Fecal
Coliforms Coliforms
per 100 ml per IC1:1 nl

60 31

6 2



2.2 x 106 0.28 x It6

16 1

33 9

820 74

3200 D


90 34

1000 86

21,000 1000

4,900 463
500
700

270,000 20,;::
380 88
3,500 373

1.1 x 106 58,030

330 130
92 f-_
BOD
5 -day
mg/1
0.8
1.4

0.4


53
55

0.4

0.8
1.6
4.8

0.9


0.6
1.4
4.0
7.4
16.0
3.2
7.2
10
17
29
71
1.5
2.9
14
45
1.3
2.7
1.3
3.8
1  This  data is preliminary information provided by the  USGS;  it is subject  to  further veri'ficati on by their technical  staff.


2 Station Y5 is no  lor.gc- con.-.idcred representative  of tho cror:s-s-ction of r-.Tir-^cr. flow,  duo to the  influence
  of  the Steorfooat  springs '-.^x-tigo  ou-f^ll  (n.r. Bjijer,  ct al.,  1970,  ir. review).

-------
Groundwater

Most of the groundwaters in the project area are found in rock layers
mentioned in the Geology section.  These layers are termed Morrison and
Dakota formations, Mancos Shale, Browns Park formation and alluvium.
Small quantities of additional groundwaters may be found in the granite
east of Steamboat Springs.  Much of this environment has been assessed
by R.E. Brogden and T.E. Giles of the USGS (Reconnaissance of groundwater
resources in a part of the Yampa River basin between Craig and Steam-
boat Springs, Moffat and Routt Counties, Colorado, publication in progress)

Only a few wells have been drilled into the Morrison and Dakota forma-
tions near Steamboat Springs.  Water in the Morrison often contains
high levels of hydrogen sulfide.  This compound causes water to have
a bad taste or bad smell.  Water conditions in the Dakota formation are
largely unknown, but it should be productive and potable since the
Dakota is an important aquifer elsewhere in the state.

Some wells have been drilled into the area's Mancos Shale and Browns
Park formations.  Those in the Mancos Shale are located near the Steam-
boat Springs airport, where production is usually less than five gallons
per minute  (gpm).  Their water quality is usually poor due to excessive
hydrogen sulfide.  Wells in the Browns Park formation are quite variable
in both production and quality.  Their yields very from h to 350 gpm;
their quality is best near areas of active surface recharge.

The alluvium is the formation that could receive the most impact from
land treatment.  It is highly variable in its rock composition and in
its well yields.  Some wells produce a few gpm while others produce
from 150 to 200 gpm.  The recharge of these wells is good along the
Yampa River, where its rate is dependent on quantity of the surface
runoff and on rates of irrigation.

The water table in the alluvium is best known by the USGS.  They have
mapped its general contours from their local knowledge of stratigraphy
and well water levels (Study Map 1).  These contours are not absolute,
however, since the spring runoff would cause them to rise and summer
dry spells, to decline.

Water quality of wells in the alluvium is generally excellent.  Studies
by Wright-McLaughlin Engineers corroborate this, yet they have found
some wells to be high in total hardness  (October 1975).  The USGS also
found high levels of hardness  (Table II-9).  These values are considered
high since they exceed the USGS standard of 120 mg/£  (Hem, 1970).  High
hardness values also imply high concentrations of calcium and magnesium.
                               -35-

-------
                                                                                         TA3LE II-9


                                                                      GROUNDWATER QUALITY NtAJ-  .-.TE^-IdOAT SPRINGS
 I
OJ
CTl



Collection Date
Depth to Surface

Water Temp. °C

pH
Total Hardness
as CaCO-j
mg/1

Calcium
mg/1

Magnesium
mg/1

Sodium
mg/1

Potassium
mg/1

Total Alkalinity
as CaC03
mg/1

Bicarbonate
mg/1

Chloride
mg/1

Sulfate
mg/1

Fluoride
mg/1

N02 + N03 as f
mg/1

^4
mg/1

Well #1

8/28/75
25'

12.0

7.5

150


43


10


22


2.5



123


150


8.6


66


0.3


0.02


0.03

EPA
Well #2 well »3 Drinking
Water
8/15/75 8/20/75 Standards
25' 55'

17.0 14.0

6.8 7.4

88 61


27 17


4.9 4.5 125


7.9 6.4


1.3 1.7



94 75


115 91


0.5 2 250


8.1 1.7 250


0.1 0.1 1.1-1.8


0.52 0.11 10
(NO3-N)

0.12 0.13




Collection D;
Silica
mg/1

Arsenic
mg/1
Cadmium
mg/1

Iron
mg/1

Lead
mg/1

Manganese
mg/1

Mercury
mg/1

Molybdenum
mg/1

Nickel
mg/1

Selenium
mg/1

Vanadium
mg/1

Zinc
mg/1

Conductivity
umhos/cm

TDS
mg/1

SAR
                                                                                                                       Well  #1     Well #2


                                                                                                                       8/28/75     8/15/75

                                                                                                                         17           18



                                                                                                                         0.001        0
                                                                                                                          0.54
                                                                                                                          0.0004
                                                                                                                                    127
Well #3


8/20/75

  26
                                                                                                                                                  0.14
EPA
Drinking
Water
Standards
                 0.1



                 0.01


                 0.3



                 0.05



                 0.05
                                                                                                                                                                 0.01

-------
Except for iron and manganese, concentrations of trace metals in these
waters are generally low enough to be within the proposed EPA drinking
water standards.  Nitrate levels are also acceptable.   This condition
indicates that groundwaters in the Yampa River alluvium could accept
some limited irrigation loading from trace metals and nitrates.

This latter parameter is critical since nitrates are known to leach
readily into groundwater.  Once they reach this environment, their
residency time could be hundreds or thousands of years.  Consequently,
if the land treatment alternative is chosen, without using underdrains,
application rates must be designed so that all applied nitrates can
be absorbed by the plants or gasified into the atmosphere.  Calculations
used to determine application rates should account for all nitrogenous
compounds, including ammonia and nitrite.  These latter two should be
considered since soil bacteria can convert them to nitrates and make them
available to plants or to the groundwater.
                     Point  and  Nonpoint  Sources
 The purpose  of this  section  is  to  describe discharges into the Yampa
 River,  originating from the  present  sewage treatment systems and other
 significant  sources.   The  first discussion covers discharges from the
 following  sources:   Steamboat Springs, Mt. Werner District, Steamboat
 II District,  Bear Pole Ranch, Mineral Springs at Steamboat Springs,
 KOA Campground,  Sleepy Bear  Park,  SSRSA Urban Runoff and mineral springs.
 Those discharges from the  sewage treatment facilities are then analyzed
 for their  compliance with  present  and future permits.  The next discussion
 features water management  and  the  problem of handling inflow/
 infiltration within  the collection system.  Finally, the overall SSRSA
 summer  and winter material balance is discussed and evaluated in the
 context of existing  information.

 City of Steamboat Springs

 The Steamboat Springs Plant  basically serves the old city of Steamboat
 Springs.   It  also serves the Riverside district, the Fish Creek district,
 the Tree Haus District,  and  any excess flows greater than 120,000
 gallons per  day (gpd)  from the  Mt. Werner plant, via an interceptor
 constructed  in 1974.   The  original facility was completed in 1967 and
 basically  consisted  of a two-stage aerated lagoon system.  Between
 1973 and 1974,  a significant expansion to the original plant was
 engineered and constructed.  The design flow for this new system
 was 1.65 million gallons per day (MGD) with peak flows of 2.08 MGD.
                               -37-

-------
This new system consists of an aerated  lagoon that  is followed by  clari-
fication chamber, equipped with a sludge return  system to the first
aeration basin.  The clarification chamber  is then  followed by a 3.8-
day-polishing pond, before discharge to the Yampa River.  Chlorination
for pathogen control is not accomplished in a conventional contact unit
but instead the chlorine solution is added  at any one of three inlet
points to the final polishing pond.  Data collected by the  USGS  and  the
Colorado Department of Health, presented respectively in Tables II-8
and 11-10; show that Steamboat Springs  chlorination has not been con-
sistently effective in controlling fecal coliforms.

Sludge disposal requirements for this type  of treatment unit are
minimal.  Sludge is slowly collected on the bottom  of the ponds and
then removed once every three or four years.  In the past this sludge
has been  spread on surrounding agricultural land.

The Steamboat Springs Plant has a nominal design capacity of 1.65  MGD
with peak flow capacities of just under 2.1 MGD.  Flow rates exceeding
these design rates occur at the plant due to high infiltration and
inflow rates averaging between 0.9-1.8  MGD.  Thus,  the overall hydraulic
loading on the plant is affected dramatically by these sources.  A
schematic diagram of the Steamboat Springs  facility is given in
Figure 4.   All sanitary sewage flows to the plant are by gravity except
for flow  from the small Riverside District.

Mt. Werner Water and Sanitation District

The Mt. Werner District was initially formed in  1965; construction of a
collection  system began in 1967 and the original sewage plant installation
was in 1968.  The Mt. Werner facility is an aerated lagoon-polishing pond
system and  is  located on the north bank of  the Yampa River, just south
of the  D&RGW RR tracks.   Practically all sanitary  sewage flows to this
plant by  gravity.  The design capacity  of the plant is 100,000 gpd.
The Mt. Werner system also serves the Tree  Haus  Water and Sanitation
District.

As development in the Mt. Werner area continued  during the early 1970s,
the system  became overloaded.  Thus, an interceptor was constructed
in 1973 to  divert and convey all flows  greater than 120,000 gpd to
the City  of Steamboat Springs plant.

The present treatment plant consists of an  aerated  lagoon followed in
series by a polishing pond.  No pretreatment is  provided.  The aerated
section of  the plant  lagoon has a detention time of 22 days at design
rates.  The effluent  from that section  then flows to a plain polishing
pond  that provides approximately another 37-day  detention time, prior
to discharge.  Flow rates to the lagoon in  the spring of 1974 ran  as
high  as 500,000  gpd with infiltration flows as high as 300,000 gpd.
During the  peak  Christmas tourist season of 1974-75, average flows
                                   -38-

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           TABLE  11-10
     COLORADO DEPARTMENT OF HEALTH

   WATER POLLUTION  CONTROL DIVISION
RECENT PLANT EFFLUENT WATER QUALITY TESTS
Date Time
Sampled Sampled
WASTE DISCHARGE STDS
STEAMBOAT SPRINGS
H/20/74 °90°
3/ 5/75
1700
MOUNT WERNER
2/28/74 J°-jO
5/22/74 °900
3/17/75 °900
3' "° 1500
KOA CAMPGROUND
"^ 1 rt / 1 £ /-T ^ 0950
^ 10/16/73 jij^
1
6/18/74 °«0
SLEEPY BEAR
5/ 8/74 083°
12/17/74 °'|5
STEAMBOAT 1 1
11/20/74 ?$
3/17/75 ?j!!**
pH
(Std.
Uni ts)
6-9
7.4
7.7

7.3
8.3
7.6

—
6.8

7.3
7.7

7.7
7 6
Dissolved Residual
Oxygen Chlorine
2.0 (min) 0.1-0.5
10.2
3.2

1.2 0
9.0
3.6 0.0

8.2
2.5 0.2

2.2
2.2 0.0

4.8 0.2
5-7 0.4
Settleable
Turbidi ty Sol ids
(JTU) mq/1
30 (max) 0.5 (max)
10 0.1
15 0. 1

6.4 'O.I
11.0 '0. 1
-

26.0 0.7
23

3.2 <0.1
3.6 <0.1

8.1 0.1
38 18
Suspended
Sol ids
30 (max)
36
14

26
31
--

120
78

14
11

24
19
Fecal
Col i form
per 100/1
**5000
2200
22,000

2200
880
22,000

2400
220,000

220,000
5000

2400
380
SOD
mq/l
30 (nax)
28
27***

21
29
--

36.5
46

16
30

12
66
Oi 1 5-
Color Grease Temp.
(Units) mq/1 F
30 (max) 10.0 (max)
30 39
25 43

5 4
40
39

50 5.3
10

8
30 50

10 45
5 -- 44
Total Uolai
Ammonia Phos. Sol it
mq/ 1 mq/ 1 mq/ 1
6.84 77
15 4.1



—





.7 8.8 116

4.6 II. 1 151
4.1 5.5
                                                                           COO
                                                                                        Total    Type  of  Kjeldah
                                                                                 Flow   Sol ids   Sample   Ni trogen
                                                                                          281
                                                                                  2.7
                                                                            50
                                                                           142
                                                                                   .226
                                                                                   .0015
                                                                                          611
                                                                                          657
                                                                                                                                                                      8

                                                                                                                                                                      6
                                                                                                           20
Appli cab Ie i f was tewater is  disinfected w-th chlorine
Receiving waters classified  B-]  have a maximum limitation of 1000/IQOml
Results in 615 Ibs.   BOD load   which exceeds permit allocation

Compliance with Colorado Standards  for  the  Discharge of Wastes shall  normal
be  based on 6-hour compos i te samples.   If  grab  samples are taken,  no pa rame
I imi tat ion shaI 1 be exceeded by more  than  50% of  the  ! i->; ta' on.
  -ameter

-------
                                               Sludge Return
>
/

=*
/
\

                       Pretreatment
                                       Aerated Pond
o
i
Intermediate
Clarifier
Polishing Pond
and Chlorination
                                                                                            Yampa
                                                                                            River
STEAMBOAT SPRINGS TREATMENT PLANT
      SCHEMATIC  FLOW DIAGRAM

-------
of 400,000 gpd were noted with peak flows as high as 956,000 gpd.
A process flow schematic of the Mt. Werner lagoon is given in
Figure 5.

The bypass of excess flows to the City of Steamboat Springs plant
has been one of the keys to a reasonably successful operation of the
Mt. Werner facility.  The treatment levels achieved at this plant
since the bypass have been generally good.  A summary of effluent
testing by the Colorado Water Quality Division is given in Table 11-10.
A comparison with the regulations shows the plant to periodically be
in violations of its suspended solids and BOD limitations.  Adequate
disinfection has also been lacking as the plant fairly consistently
violates this standard.  Consequently, these facilities will not be
able to meet the 1977  standards for suspended solids,  BOD5  and
NH3.

Steamboat II Water and Sanitation District

The Steamboat II District sewage treatment plant is situated on the
northwest side of the study area on a 3.6-acre site, located between
the D & RG railroad tracks and the Yampa River.  The collected sewage
from the Steamboat II development flows by gravity to the plant site—
where it must be lifted into the plant.  It has design capacity of 75,000
gpd and consists of three small package units, each having a capacity
of 25,000 gpd.  The first module was put into service in 1971; the
second and third units, between 1973 and 1974.  Extended aeration is
the basic process employed in these units and the three units operate
in parallel.  The sewage flow is sent directly to one of the three aera-
tion basins and then on to the clarifier section.  No pretreatment of
grit removal is provided.  The flow is then collected and sent to the
polishing pond, chlorinated and discharged.  The plant's aeration
capability and sludge removal is not good between the various parallel
units because of inadequate piping.

The effluent water quality from the Steamboat II plant has periodically
been in violation of the current discharge permit.  A summary of effluent
water quality testing by the Colorado Water Quality Control Division and
the USGS is given in Tables II-8  and  11-10; additional data documenting
past plant performance is available in the 201 Facilities Volume One
report.  The suspended solids, BOD, and fecal coliform parameter
standards have often been violated in the past.  If a program for
upgrading this system is not initiated, the effluent wastewater quality
will continue to be in non-compliance with Colorado State regulations.
With proper operator attention, a plant of this type can provide adequate
secondary treatment.  However, it is not readily amendable to incorpora-
tion into a long range regional sewage treatment facility with advanced
treatment requirements.  Smaller plants like this one require more
money to process a given amount of sewage than a larger one does; plus
a network of smaller plants require more people to operate them than one
larger plant does.
                                     -41-

-------
                                   Steamboat Springs Plant

                                   (For  flows greater than 120,000 gpm)
  Pretreatment and
  Diversion to Steamboat
  Springs
Aerated  Pond
Plain Polishing
Pond
Chlorina-
tion
                                                                                   Yampa
                                                                                   River
NJ
I
             FIGURE 5
   r,  WFWEP TREATMENT PLANT
   SCHEMATIC FLOW  DIAGRAM

-------
KOA Park Treatment Plant

The KOA park treatment plant is a package plant, with an extended aeration
basin followed by a polishing pond.  This unit provides treatment only
for the KOA Campground and a sanitary dump station, which results in
highly variable loads.  The unit was installed in 1974 and the pond
was added in 1974; design capacity is 15,000 gpd.  Pretreatment is not
provided at this facility and the final polishing pond is utilized as
a chlorine contact chamber.  Effluent data gathered by the Colorado
Department of Health and the USGS indicates that the KOA plant is in
consistent violation of the State Discharge Standards.  A summary of
this data is included in Tables II-8 and 11-10.   Inspection evidence indicates
that at times the sludge return is anaerobic and that overall plant
operability is poor.  With proper operation attention, a plant of this
type can provide adequate secondary treatment for flows within design
limitations.  The system is not, however, amenable to incorporation
into a regional facility requiring advanced treatment processes, for
the same reasons mentioned for Steamboat II.

Sleepy Bear Trailer Park

The Sleepy Bear Plant provides treatment services for the Sleepy Bear
Trailer Park, which is located 0.2 miles downstream of the KOA plant.
Its process is an extended aeration-activated sludge type, with design
flow of 15,000 gallons per day.  It is essentially the same type of
unit as the KOA plant previously described.  No polishing pond has
been added, however.  Chlorination consists of adding hypochlorite
tablets to the clarifier weir trough.

As shown in Tables H-8 and 11-10,  effluent monitoring data (1974-1975)
indicate that in the past the plant has generally been in compliance
with the suspended solids and BOD parameter limitations as governed
by the State Discharge Standards.  Disinfection treatment levels have
not been adequate, however, and the plant has been in violation for
this parameter.  Again, this type of plant can provide adequate secondary
treatment under the proper operating conditions but it is not amenable to
incorporation into a regional wastewater facility requiring advanced
treatment.

Bear Pole Ranch & Stephens Perry Mansfield School

The Bear Pole Ranch is located in Strawberry Park, about two and one-
half miles northeast of the Steamboat Springs sewage lagoons, and has
a maximum peak population of about 130 persons.  The extended aeration
facilities for the ranch were constructed in 1972 and then modified
in 1975.  The rated capacity of the system is 15,000 gpd although
flows to the facility are usually less.  The system consists of five
underground aeration vaults and a sixth vault for chlorination-disinfec-
tion.  A polishing pond provides a S's-day detention time, then further
treats the effluent before discharge to a nearby irrigation ditch.
                                     -43-

-------
The polishing is susceptible to algae accumulations and subsequently,
suspended solids problems occur during certain times of the year.
The facility appears to be operating efficiently although no water
quality testing has been done since the  1975 improvements.

The Stephens/Perry Mansfield School is also located in Strawberry
Park on the west side of the valley.  This school  is open only  for
the summer with programs in art and recreation.  The maximum population
is approximately 200 residents.  Currently, their  sewage facilities
consist of about 25 separate septic systems that appear to be operating
properly.  However, some groundwater pollution probably does result
from the leaching fields.

The current sewage facilities at both the Bear Pole Ranch and the
Stephens/Perry Mansfield School are currently operating in a reason-
ably satisfactory manner.  Because of their remote location, it is not
advisable to attempt to tie these facilities into  the proposed  SSRSA
treatment system.  In the future, a land treatment irrigation advanced
waste treatment scheme might be advisable.

SSRSA Urban Runoff

There is no question that the various point source discharges listed
above contribute significant pollutant loadings on the Yampa River.
In addition to these, however, studies performed by Wright-McLaughlin
Engineers indicate that non-point sources also contribute substantial
loadings to the area waterways.  As might be expected, runoff from
rainfall and snowmelt does become contaminated to  varying degrees with
pollutants from urban activities as it makes its way across rooftops,
gutters, pavement, and lawns.  Traffic,  air pollution, animals, and
humans  and general urban activities continually provide a source of
pollutants to be picked up during the next runoff  event; the primary
pollutants are similar to those found in normal sanitary sewage although
perhaps in more dilute concentrations.   Stormwater or snowmelt  runoff
is particularly damaging to certain segments of the receiving stream
quality because it generally occurs in large volumes and thus produces
a shock loading effect.

Wright-McLaughlin Engineers  (October 1975) have carried out extensive
investigations into the quality and quantity of these runoff flows.
Their  investigations  involved both field sampling  and computer  modelling,
using  the Corp of Engineers "Storm" model.  To facilitate this  effort
the SSRSA was divided up into various segments according to residential,
commercial,  and industrial uses.  To put the results into a reasonable
perspective, it is useful to compare the total runoff contribution on
an annual basis to that of the previously mentioned point sources.
These  comparisons are given in Table 11-11.
                                     -44-

-------
                            TABLE 11-11

                  COMPARATIVE POLLUTANT LOADINGS
                  Urban Runoff vs. Point Source

                                                 BOD          SS
                                               (Ibs/yr)      (Ibs/yr)
Point Source
(Based on 1983 Proposed Allocations)           86,870       86,870

Non-Point Source                               48,180      302,585
(1985 Results—"Storm" Model
—Total SSRA urban area)

Ratio (Non-Point/Point Source—                  55.4%        348%
Steamboat Springs only)
From Table 11-11, it can be seen that the 1985 predictions indicate
that almost 3.5 times as many suspended solids will be directed to the
Yampa via storm runoff than by point source discharge.  Likewise,
about one-half as much BOD would be discharged via non-point source
flows.  Consequently, to maintain a responsible cost-effective approach
to the Yampa basin water quality and to maintain the desired water goals,
at least minimal control and treatment of non-point source urban runoff
should be initiated.  Otherwise, the areawide allocation program with
its extensive treatment requirements cannot help but lose some of its
significance.

Mineral Springs at Steamboat Springs

Mineral springs are apparent at various points along both banks of the
Yampa River; the discharge comes from an upturned outcrop of the Dakota
Protection Agency estimates (1971) the salt loading on the Yampa River
from this source is about 24 tons per day.  This flow is also high in
fluorides.  The conductivity for these flows is 1450 micromhos per
centimeter for the hot springs east of town and 7500 for the cold springs
west of town (R.E. Moran, 1976, USGS, oral communication).

Summary—Compliance with Current and Future Legal Limitations

As noted in the previous discussions, most of the SSRSA treatment
facilities are periodically in non-compliance with their current waste-
water discharge permits.  As discussed earlier in the Water Quality
Goals section,  the Green River Basin Plan developed and assigned discharge
allocation for the biochemical oxygen demand.  These allocations are
scheduled to take effect on July 1, 1977 although some of these allocations
                                  -45-

-------
have already been written into current permits with implementation
dates prior to July 1977.  Compliance with these requirements is shown
in Table 11-12 for SSRSA facilities.  This table shows that the current
BOD limitations are only complied with at Steamboat Springs and Mt.
Werner, and occasionally at Sleepy Bear.  When the load allocations are
implemented in future permits, none of the existing facilities are
expected to comply.  For suspended solids, only Steamboat II and Sleepy
Bear regularly comply with the existing permits and only Sleepy Bear
would be expected to comply with future permit limitations after July
1977.  None of the existing systems perform well with regard to coliform
discharges and none of them would be expected to meet future ammonia
discharges without additional removal equipment.

Water Management

Both the City of Steamboat Springs  (including the Fish Creek Water and
Sanitation District) and Mt. Werner divert water from Fish Creek for their
potable water source.  The City also has a 1800 acre-feet reservoir near
the Continental Divide from which it also draws water for domestic uses.
Steamboat II, on the other hand, draws its supply from a well on the
Yampa  River floodplain.  Principal uses for this water would include
water  for normal domestic uses and also for irrigation during the
summer months.

An entire regional water system essentially acts as an interrelated
supply and treatment system.  Water quantities used must be treated,
so the key to a sound and successful water management program does
not solely rely on capital intensive water system improvements.  For
instance, because water consumption has been found to be a function
of cost  and general public awareness a more active "water conservation"
awareness is  usually facilitated by metered water systems, as contrasted
to a flat rate billing system.  The Steamboat Springs water system is
currently not metered although proposals to initiate such a system have
been suggested.  Winter bleeding is a fairly common practice in the
older sections of  the City where freezing lines are a problem during
the winter.

A second water system management technique is related to the control
of undesired  infiltration/inflows  (I/I) into the sewage collection
systems  to the various treatment plants.  If such flows can be minimized,
less wastewater need be  treated before discharge and overall treatment
efficiency is improved.  For  example, average annual sewage flow
for SSRSA  in  1975  was estimated to be 0.56 MGD with I/I flows
averaging between  0.71 and 2.36 MGD.  Obviously I/I flows are often
quite significant  in this system.

The sources of I/I are cracked or broken pipe, improperly grouted
connections,  poor  insulations, leaking manholes and roof drains.  The
main sources  in the SSRSA area are infiltration into sewer lines and
                                  -46-

-------
                                                       TABLE 11-12
vj
I
                                 SUMMARY—COMPLIANCE OF SSRSA TREATMENT FACILITIES
                                    WITH CURRENT AND FUTURE PERMIT CONDITIONS
                                                       Parameter
Treatment Facility
Steamboat Springs
Mt. Werner
Steamboat II
KOA
BOD5
Current
Future
Current
Future
Current
Future
Current
Future
Yes
No
Yes
No
No
No
No
No
Suspended Solids
No —
(periodically)
No
No —
(periodically )
No
Yes
No
(possibly)
No
No
                Sleepy Bear
Current   No—         Yes
      (periodically)
Future    No           Yes
                                      (Fecal Coliforms)
Disinfection
No
No
No
No
No
No
No
No
NH3
No
No
No
No
No
No
No
No
No


No
No


No

-------
manholes, plus inflow from winter bleeding.   Winter bleeding occurs when
water users allow water to continuously  flow through  their pipes to prevent
them from freezing during the winter.  McCall,  Ellingson  and Morril esti-
mated this amount to be 0.57 mgd during  the  months of December through April.
Dismuke  & Dismuke, Consulting Engineers,  and Wright-McLaughlin Engineers
investigated the  infiltration during those months and found it
contributes 0.66 mgd, for a total 1.23 mgd during the winter periods.
These values increase even more during the spring runoff  when I/I
flows can peak to 3.715 mgd and average  at 2.36 mgd.   An  estimate
of  all these flows is given for the  entire SSRSA study in Table 11-13
it  does  not include the winter bleeding  of 0.57 mgd.
                             TABLE  11-13

                      1975  I&l  FLOWS  (1,000 gpd)*

 Basin           Basin  Name              May Peak    May Base   Winter Infiltration

   1.        Steamboat  II                   125          50           10
   2.        Sleepy Bear/KOA               neg         neg          neg
   3.        Dear Mtn./Elk River            na          na           na
   4.        Riverside                       25          10           10
 5,6.        West Steamboat/Fairview        60          50           20
   7.        Steamboat                    2,645       1,870          500
   8.        Willett Heights                15          10          neg
   9.        Fish Creek                     30          20          neg
  10.        Tree Haus                       30          15          neg
 11,12,13.  Mt.  Werner &  Interceptor       785         335          120

            Total SSRSA                 3,715       2,360          660*

            *Plus 570  winter bleeding equals a total winter I/I of 1,230
             neg means a  negligible amount
             na means  not applicable

 In order to arrest the problem of winter bleeding, the Public Works
 Department of Steamboat  Springs is working on two programs.  One replaces
 some of the older lines  to reduce leaks and to place them below the frost
 line.  Another program installs metering devices to encourage water
 conservation.  Their programs are intended to reduce winter bleeding
 as much as 50 percent.

 The most important locations for I/I are the older areas of Steamboat
 Springs and Mt. Werner Water and Sanitation Districts.  Corrective
 measures are deemed cost effective in these areas and should be under-
 taken.  Wright-McLaughlin proposes that Steamboat's older lines be
 replaced with new ones paralleling the older ones.  The older ones
 would remain as underdrains and would discharge into the Yampa River
                                 -4R-

-------
drainage.  Such a system would cost approximately  $423,000,  including
25 percent for contingencies.  The Mt. Werner improvement would cost
less  ($33,000) + 25% contingencies and would consist mainly of grouting
existing pipe, replacing it and providing liners.

These improvements are designed to reduce peak I/I flow in May by
1.64 mgd, reaching a level of 2.075 mgd.  The May base would be
reduced to 1.269 mgd, a loss of 1.1 mgd.  Reductions for the winter
would amount to 0.46 mgd, bringing the level down to 0.2 mgd.  This
latter value is especially important to future treatment since highest
wastewater flows would occur during the winter.  A summary of these
improvements is shown in Table 11-14.  This table shows a 55 percent
annual reduction in I/I  (208 million gallons), excludina winter bleed-
ing,  and an overall reduction of 51 percent  (234 million gallons).
It would cost an estimated 14.3C per 1000 gallons, clearly cost
varying from 34.8 to 38.8* per 1000 gallons  (Wright-McLaughlin Egineers,
June 1977).
                            TABLE 11-14

                Estimated Present and Future I&I Flows
                             (1000 gpd)
                    PRESENT ESTIMATE
                     Sewer  I&I
      PROJECTION AFTER IMPROVEMENTS
               Sewer I&I

MONTH
January
February
March
April
May
June
July
August
September
October
November
December
% of
May Peak
18
18
22
36
64
45
32
21
20
20
19
18
Avg.
Flow
660
660
820
1340
2360
1670
1190
780
740
740
710
660
Winter
Bleeding
570
570
570
570
-
-
-
-
-
-
-
570

Total
1230
1230
1390
1910
2360
1670
1190
780
740
740
710
1230
% of
May Peak
10
10
18
29
61
45
28
16
14
12
11
10
Avg.
Flow
200
200
370
600
1260
930
580
330
290
250
230
200
Winter
Bleeding
400
400
400
400
-
-
-
-
-
-
-
400

Total
600
600
770
1000
1260
930
580
330
290
250
230
600
Annual Flow             375 MG   87 MG

(MG means million gallons)
462 MG
167 MG
61 MG   228 MG
                                   -49-

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Water Material Balance

The flow of domestic water into the Steamboat Springs system does not
equal or balance the amount flowing out of the system.  Wright-McLaughlin
Engineers have determined that 0.68 mgd of domestic water flows through
the city's wastewater treatment plant  (April 1976), while city officials
contend that about 1.6 mgd of domestic water is supplied to the system.
These figures suggest that 57.5 percent of the incoming water is lost
from the system although usual losses vary between 20 and 40 percent
 (Metcalf and Eddy, 1972).  The reasons for this disparity are unknown
and would require additional study to elucidate.
                                  -50-

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        I.   Financial Condition of the Districts
In the draft EIS the issue of local financing was discussed in light
of the troubled financial condition of some of the special districts.
At the time of the draft EIS it was not clear how the local share of
capital costs was to be obtained or what entity(s)  would administer
required debt financing.  This issue resulted in a special study as
part of this EIS to define administrative and financing options avail-
able to the community.  This special study was prepared consistent with
"Municipal Wastewater Treatment Works Construction Grants Program:
Supplement No. 2", November 1976 which deals with local government
costs of wastewater treatment works.  This  chapter reprints this
special financial study presented to the community in December 1976.
The City of Steamboat Springs after consideration of the following
report, Is preceding according to Alternative A;  Contract Agency
which is discussed in the latter portion of this chapter.  In effect,
the city will assume the local portion of capital costs recovering the
"outside-city" share through increased service fees to these customers.
It is also likely that Routt County will create a County Wastewater
System which would enable the county to assume bond responsibility
for out-of-city areas thus lowering the city's bond indebtedness.  This
approach  (Alternative B) is also discussed in this chapter.

The Steamboat Springs wastewater management planning area contains the
City of Steamboat Springs, six special districts (Mount Werner, Fish
Creek, Tree Haus, West Steamboat, Riverside, and Steamboat II) and three
private businesses operating their own systems (Sleepy Bear, KOA
Campground, and Bear Pole Ranch).  Steamboat II, Sleepy Bear, and KOA
Campground operate their own package treatment plants discharging into
the Yampa River, the Mount Werner operates a limited capacity (0.12 mgd)
treatment plant.  Most of the Mount Werner sewage and all sewage from
the other special districts is treated, under agreement, by the City of
Steamboat Springs Sewage Treatment Facilities.  The Bear Pole Ranch,
located north of Steamboat Springs, operates its own package treatment
plant discharging into Butcherknife Creek, a tributary of the Yampa.

Despite considerable financial investment in wastewater treatment
facilities over the past several years, to an extent that threatens
bankruptcy to some ill-planned districts  (see below), none of the
facilities in the planning area meets Colorado effluent standards that
existed prior to July 1, 1975, for reasons of undercapacity, infiltra-
tion and improper operation.  (Wright-McLaughlin Engineers, October 1975)

                          SSRSA Entities

Three of the entities in the planning area will not be included in the
financial analysis which follows, since they are not special quasi-
municipal districts as described in Title 32 of Colorado Revised
Statutes.  Some pertinent comments on these entities follow:
                                  -51-

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Sleepy Bear

The Sleepy Bear Park Sewage Treatment Plant is privately owned and
serves a 53-unit mobile home park.  The plant does not meet  current
state effluent standards and is not adaptable to  long-term use in the
future consolidated system.

KQA Campground

The KOA Campground treatment plant, built in 1974, is privately  owned
and serves 21 permanent and 40 transient mobile home spaces.  The plant,
which has a current depreciated value of $16,842, does not meet  current
state effluent standards and has no long-range value for incorporation
into the future consolidated system.

Bear Pole Ranch

The Bear Pole Ranch wastewater treatment facilities, built in 1972 and
remodeled in 1975, serve a year-round ranch/camp  with a peak maximum
population of 130.  Although it does not meet current state  effluent
standards for suspended solids  (due to algae) it  is operating below
capacity and is recommended to continue operation with supplementary
land treatment of effluent, under  the ultimate master wastewater plan.
 (Ibid., pp. V-14, V-15).

Financial Condition of the Special Districts and  City

The  six special sanitation  (actually, all are combined water and
sanitation) districts in the study area vary considerably as to  finan-
cial  health.  The relative strength of the  larger districts  lends  stabil-
ity  to  the regional area, considered as a whole.  Yet some of the  dis-
tricts  are in hazardous condition  with relatively high mill  levies,
uncollectible debts,  escalating  (i.e.,  "ballooning") debt service  payments
on present bonded indebtedness  (see Table III-l) , and physically deterior-
ating facilities.  Worse,  the sewage collection and treatment systems  for
which they incurred this debt, many constructed within the last  five years,
 need major repair or  complete replacement under the master regional
wastewater plan.  The special districts in  the worst financial  condition —
one  of them  has  already defaulted  on its outstanding bonds — are
 classical  examples of the  dangers  of speculative  resort  subdivisions,
 created by optimistic resort land  developers and  sold to gullible  buyers.
 Success of such ventures appears to require an ever-expanding boom
 economy with a  steady supply of  new buyers  from outside  the  area,  or care-
 ful  state  and local  controls over  the planning of such developments.  Neither
 condition  has  existed in most resort boom areas of Colorado  during the 1970's,

A brief description of each of  the six  special districts, as well  as the
 City of Steamboat  Springs,  taken  from the latest  available  financial
 reports,  follows:
                                    -52-

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                             TABLE  III-l
Consolidated Schedule of Payments of Principal and Interest on Bonded
Indebtedness, City of Steamboat Springs and Six Nearby Water and
                Sanitation Districts (as of August 1976)
Year
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
TOTAL



Ln
U)
1


Steamboat3
Springs

$352,397
346,570
337,603
345,181
340,707
327,133
332,371
346,955
299,999
294,501
293,915
262,637
257,107
251,332
250,194
253,322
260,392
255,788
255,264
223,650
$5,887,018
a Includes
b Includes
c Includes
d Includes
e Includes
f October
g Includes
Mt. Wernerb Fish Creek° Tree Haus

$260,

885
255,073
263,
269,
267,
297,
317,
329,
331,
321,
237,
221,
205,
229,
162,
65,
61,
57,
53,
—
$4,207,
five bond
June 1974
686
360
911
873
153
785
033
160
118
340
575
538
326
000
250
500
750

316 $1,
issues.
refunding
three bond issues.
two bond
issues, of

$50,086
56,649
54,763
58,733
60,415
63,865
67,015
64,765
57,515
60,595
58,355
61,080
63,480
65,510
67,210
68,580
74,620
-
-
-
053,236
All 1976

$49,638
49,263
48,888
48,514
78,140
75,514
77,888
79,890
76,514
78,139
79,263
75,000
75,600
75,800
75,600
-
-
-
-
—
$1,043,651
Westd
Steamboat

$16
51
45
44
45
51
50
54
52
56
54
57
54
62
58
60
57
53
34
32
$993

,725
,522
,000
,650
,100
,488
,325
,163
,612
,063
,062
,063
,625
,188
,938
,688
,100
,513
,950
,475
,250
Riverside

$14,275^
23,200
27,850
27,150
26,450
25,750
30,050
29,000
27,950
26,900
30,850
29,450
28,050
26,750
30,250
28,500
26,750
-
-
—
$459,175
Steamboat II Total
$18
51
60
59
61
59
57
59
62
59
57
58
59
61
66
48





$901
,023f
,856
,914
,146
,251
,229
,194
,973
,426
,674
,690
,055
,798
,103
,770
,375
-
-
-
-
—
,477
?18,023
795,862
843,191
836,936
854,839
877,952
898,817
934,775
966,984
905,297
895,048
811,618
766,368
745,540
777,888
692,893
476,090
480,112
366,801
343,964
256,125
14,545,123
payments are included
issue and September 1974
G.O. issue. All
1976 payments
are
included.

Both 9/1/76 payments are included.
6/1/74
and 9/1/76. The
1976 payment is included
three bond issues
1975 payment and all
December
1976 payments (to date)
1, 1976 payment.
Excludes payment
are in default.
made June
1, 1976.





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Mt. Werner Water and Sanitation District

This is the largest and financially  soundest  of the  six districts.   It
has $2,575,000 in bonded indebtedness  (following a refunding issue).
The schedule of payments avoids unusual peaks,  is current,  and the
present annual payments of  $260,885  appear  to be comfortably affordable
under the district's current income  structure.   The  recent  trend in
assessed valuation and levy is:
                                   Property       Nominal
          Year      Valuation      Tax Levy       Tax Revenue*
           1973
           1974
           1975
           1976
$ 9,976,660
 14,151,710
 14,133,210
 18,392,270
 .012
 .012
 .012
 .012
$119,720
 157,820
 169,598
 220,707
 The main  source of revenue  for the district  is  water and sewer
 service fees,  amounting  to  $238,414  in  1975.  The  financial  impact of
 future wastewater facility  improvements  is not  yet known.

 Fish  Creek  Water and  Sanitation  District

 The district has, as  of  1976,  $605,000  in bond  principal (and another
 $448,000  in scheduled interest) outstanding.  Payments increase  from  $50,086
 in 1976 to  $74,620 by the last payment  in 1992.  In addition, the
 district  has $35,696  in  notes due and payable,  although  payments are
 current only on the bonded  debt.  Ability to meet  obligations depends
 largely on  continued  growth of the district.

 In September 1974, the district adopted  a policy of  charging  tap  fees
 and readiness  to serve fees  against undeveloped property within the
 district  which has water and sewer facilities available.  On  December  31,
 1975, there were some $28,000 of such fees accrued and carried as
 accounts  receivable,  although an aggressive collection policy has
 reduced receivables by half  since 1974.  The property tax levy rose
 markedly  in recent years, but dipped following the major increase  in
 1976  valuation.  The  1975 valuation had  dropped from 1974 because  of a
 reduction in assessed valuation of the district's largest commercial
 property.
           Year
 Valuation
Tax Levy
Nominal
Tax Revenue

 $9,794
 28,275
 24,704
 27,784
 1 Nominal tax revenue  as  shown  in  the  Routt  County  Abstract  of Assessment
 and Levies,  rather than actual  tax revenue shown  in the  financial
 statements of the  district.   Tax delinquencies  and  collection fees
 account for some of the difference.
1973
1974
1975
1976
$ 979,350
1,131,000
914,950
1,724,620
.010
.025
,027
.01611

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Tree Haus Water and Sanitation District

This district has $575,000 in outstanding bonds, payable at $5,000 in
principal  (plus about $45,000 in interest) annually through 1979.
Beginning in 1980, the payments balloon to between $75,000 and $80,000
annually through 1990.  The developer of Tree Haus in 1972 entered into
a "Guaranty of Payment of Tap Fees," but has met a large portion of this
agreement by transferring title to the pumphouse and sewer easement to
the district and by assigning notes to the district, amounting to $121,783
on December 31, 1975.  Payments of interest is current on the notes, yet
the district does not enjoy the liquidity which cash payment of tap
fees would provide.  The district's trend in valuation and tax levy is:

                                     Property       Nominal
          Year       Valuation       Tax Levy       Tax Revenue

          1973       $213,440          .020          $4,269
          1974        275,920          .020           5,518
          1975        324,790          .01529         4,996
          1976        950,590          .00644         6,122
West Steamboat Water and Sanitation District

This is a relatively new district, which began on October 16, 1973.  The
district issued $210,000 in bonds in 1974 to fund the construction of a
sewer system south of the Yampa and obtained a grant of $122,000 from
Northwest Colorado Council of Governments to construct sewer lines north
of the Yampa, to accommodate existing development.  Tap fees from sewer
connections, although still uncertain, are expected to cover the first
bond payment of $16,725, due in 1976.  The bond payments rise to
$32,325 on this issue by the final payment in 1993.  In July 1976, the
district also authorized a $275,000 bond issue  ($570,334 in principal
and scheduled interest )  for water line construction.   The future financial health
of this young district is heavily dependent on continuation of the expected
rate'of growth.  The trend in valuation and tax levy is:

                                     Property        Nominal
          Year       Valuation       Tax Levy        Tax Revenue

          1973               (Not in Existence)
          1974       $671,470          .008            $ 5,372
          1975        862,340          .015             12,935
          1976      1,334,830          .029             38,710

Steamboat II Water and Sanitation District

Steamboat II is in the worst financial position of any of the six special
districts in the immediate vicinity of Steamboat Springs, as a
result of optimistic overbuilding of sewer lines in undeveloped filings.
This overcommitment was compounded by the conversion of $44,500 in tap
fees due to the district by its developer, who is unable to satisfy
the district's judgment against him.  As a result, Steamboat II is in
default on several recent (1975-76) bond payments of its three
                                 -55-

-------
outstanding issues.  Default was postponed from 1974 only because
Steamboat II issued a third bond issue of $59,000 which, after deduction
of a $5,900 underwriting fee, allowed the district to meet  its
$51,194 annual payments on earlier bond issues.

The current assets of Steamboat II consist primarily of accounts
receivable totalling $53,557  (as of December 31, 1975), largely from
standby fees from owners of undeveloped lets.  The district is actively
pursuing foreclosure of tax liens against major debtors.

Although the developer of Steamboat II is in such financial difficulty
that the district's accountant does not accrue the judgment against him
as an account receivable, the district in 1976 acquired some personal
property of the developer as a partial settlement.  Subsequently, the
district deposited funds sufficient to cover the defaulted  1975 bond
payments.   (The 1976 payments, however, remain in default.)

Despite its bleak financial history. Steamboat II has some hope of re-
covery.  This depends on someone developing Filing No. 2,  which has a
substantial sewer line investment already in the ground, but provides
no tap fee or service fee income to the district.   To encourage develop-
ment of this filing, Steamboat II has instituted readiness to serve fees
and reduced its property tax levy (in 1975)  to 10 mills, at the cost
of raising tap fees to $1,600 and service charges to the unusually high
level of $45/month.  In 1976, the district increased its levy to 40 mills,
subject to State approval.  Steamboat II offers medium price housing,
which is scarce in the Steamboat Springs area, and there is a reasonable
possibility of future development which could restore financial health
to the district, despite bond payments which balloon from $538,490 in
1975  (in default) to $1,465,000 in 1995.

 The  trend  in valuation and  levy is:

           Year       Valuation        Levy      Nominal Tax  Revenue

           1973         $473,030        .010            $ 4,730
           1974         487,430        .030            14,623
           1975         538,490        .010             5,385
           1976         915,560        .040            36,622

 Riverside  Water and  Sanitation  District

 Although  solvent,  this district is  in difficult financial  circumstances
 due  to a bonded indebtedness  burden which was  assumed based on growth
 projections which  have not  materialized.  Riverside has a  debt payment
 schedule which  jumps  significantly  in 1978 and subsequent  years,  and
 the  district  already is  experiencing  difficulty in meeting present
 payments.   The  debt  was  incurred based on an  expectation of outside-
 district  tap  fees  from commercial development  along  the main highway.
 This development now seems  doubtful,  and the  in-district undeveloped
 land is limited in quantity and currently experiencing  only very  limited
                                 -56-

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building.  The  district has  raised service charges but holds its mill
levy  at  20 mills  to encourage  lot development.  A significant upturn
in tap fee and  service fee income seems necessary if the district is
to continue  to  meet its bond payments.  The trend in valuation and
assessments  is:

                                    Property Tax      Nominal
          Year       Valuation       ^Levy	        Revenue

          1973         $141,270         .020            $2,825
          1974         156,660         .020             3,133
          1975         178,550         .020             3,571
          1976         331,230        .020             6,625

Summary  of Conditions of  Facilities

The six  special water and sanitation districts currently own
wastewater collection facilities that exhibit a high rate of inflow
and infiltration  and thus require substantial maintenance.  Except for
Mt. Werner's small  (0.12  mgd)  treatment plant which does not meet
current  effluent  standards,  none of the special districts own treatment
facilities which  are considered to have long-term value in the consoli-
dated regional  plan.  Thus,  each district will need either:   (a) to
spend additional  funds to improve its own wastewater collection
facilities and  pay more to have its sewage processed in an upgraded
treatment plant;  or  (b) to merge with other districts into a consoli-
dated sanitation  district, paying a share of the costs of constructing
and operating the consolidated district's facilities.  In either case,
a substantial additional  financial burden will be placed on the already-
burdened special  districts.  At present, the districts together owe
$4,748,000 in principal and  nearly $10 million in interest over the next
19 years (see Table III-l).

City  of  Steamboat Springs

The City's financial condition is sound.  Outstanding bonded indebtedness,
as of December  31, 1975,  is  $3,232,000, subdivided as follows:

      General Obligation Various Purpose Bonds      $2,285,000
      Sales Tax  Revenue Bonds                         390,000
      General Obligation Water  Bonds                   300,000
      General Obligation Sewer  Bonds                   225,000
      Sewer Improvement Revenue Bonds                   42,000
                                                   $3,242,000

Readiness to  Serve Fees

Three of the  districts in the  Steamboat Springs service area (Fish Creek,
Steamboat II, and Tree Haus)  now charge readiness to serve fees to
owners of undeveloped property in the district.  Current (August 1976)
fees charged  are as follows:
                                 -57-

-------
     Fish Creek:  $18.13/month for single family lots onlya  (This is
                  half of the service charge for developed lots.)
     Steamboat II:  $28/month per lot.
     Tree Haus:  $13/month per lot except for developer-owned lots.

Under Colorado law (C.R.S. 32.4.133,11)  a readiness to serve fee can
be assessed only under certain circumstances.  Among the provisions
is a requirement that the district must have a debt-to-valuation ratio
of 1:3 to higher.  By comparing the current debt amortization schedule
(Table III-l) and the projected property valuation (Table III-2) for
these three districts, it appears that the ratio of debt to valuation
will fall below 1:3 by the years shown (unless additional debt is incurred)

     Fish Creek:  About 1983
     Steamboat II:  About 1985
     Tree Haus:  About 1985
                                -58-

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                                         TABLE III-2
                                  PROJECTED PROPERTY VALUATION
                                       (in 1976 dollars)

Year   Prig. Town   Mt. Werner   Fish Creek   West Steamboat Steamboat II  Tree Haus
                                                                                        Riverside   TOTAL
1975
1976*
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
8,649,290
12,000,000
12,425,000
12,850,000
13,275,000
13,700,000
14,020,000
14,340,000
14,660,000
14,980,000
15,300,000
15,520,000
15,740,000
15,960,000
16,180,000
16,400,000
16,620,000
16,840,000
17,060,000
17,280,000
17,500,000
14,121,110
16,100,000
17,125,000
18,150,000
19,175,000
20,200,000
20,860,000
21,520,000
22,180,000
22,840,000
23,500,000
24,000,000
24,500,000
25,000,000
25,500,000
26,000,000
26,340,000
26,680,000
27,020,000
27,360,000
27,700,000
892,790
1,600,000
1,627,500
1,655,000
1,682,500
1,710,000
1,751,000
1,792,000
1,833,000
1,874,000
1,915,000
1,954,000
1,993,000
2,032,000
2,071,000
2,110,000
2,149,000
2,188,000
2,227,000
2,266,000
2,305,000
862,340
980,000
1,069,000
1,158,000
1,247,000
1,425,000
1,560,000
1,695,000
1,830,000
1,965,000
2,100,000
2,165,000
2,230,000
2,295,000
2,360,000
2,750,000
2,830,000
2,910,000
2,990,000
3,070,000
3,150,000
538,490
800,000
822,500
845,000
867,500
890,000
922,000
954,000
986,000
1,018,000
1,050,000
1,090,000
1,130,000
1,170,000
1,120,000
1,250,000
1,293,000
1,336,000
1,379,000
1,422,000
1,465,000
324,790
640,000
712,500
785,000
857,500
930,000
988,000
1,046,000
1,104,000
1,162,000
1,220,000
1,268,000
1,316,000
1,364,000
1,412,000
1,460,000
1,498,000
1,536,000
1,574,000
1,612,000
1,650,000
178,550
330,000
335,000
340,000
345,000
350,000
353,000
356,000
359,000
362,000
365,000
364,000
373,000
377,000
381,000
385,000
388,000
391,000
394,000
397,000
400,000
25,567,360
32,450,000
34,116,500
35,783,000
37,449,500
39,205,900
40,454,000
41,703,000
42,952,000
44,201,000
45,450,000
46,366,000
47,282,000
48,198,000
49,114,000
50,355,000
51,118,000
51,881,000
52,644,000
53,407,000
54,170,000
1975 Mill
Levy
**
.012
.027
.015
.010
.020
.010

* This Table was prepared prior to issuance of 1976 certification of property valuations.
certification resulted in values higher than shown by  16.9  percent.
                                                                                           Actual
** Steamboat Springs has a .015 mill levy which generated $354,948 in 1975.
is not assessed for sewage treatment facilities.
                                                                             A specific mill levy

-------
                       Projection of Revenues
As a prerequisite to any plan for consolidation of the governmental
entities concerned with sanitation services in the Steamboat Springs
area, it is necessary to determine their prospective revenues from
which operating expenses and bonded indebtedness can be paid.

Ad valorem tax revenues are a function of assessed property valuation
and the tax levy established by the district directors or city council.
Revenues are subject to the limitation, established in 1975 by H.B. 1139,
restricting districts from increasing their tax levies to raise more
than 107 percent of the previous year's revenue, unless permission is
obtained from the Colorado Division of Local Government or the district
voters in a special election

Because ability to pay is closely related to property valuation, a
projection of valuation was made for the City of Steamboat Springs
and each of the six special districts in the study area.  The methodology
was as follows:

         (a) Interviews were conducted with city officials, district
            directors, attorneys, developers and other interested
            parties to gain their informed judgment as to how fast
            each entity would develop.  The consensus of these build-up
            estimates was compared with historic trends, and a judgmental
            projection was made in terms of units developed per year over
            the next 20 years.

         (b) Preliminary 1976 property valuations, following a 1976
            reassessment, were obtained from the Routt County Assessor.
             (The final valuations, following certification, are shown on
            pages 4 to 7, above.  For the entire study area, the 1976
            valuation is $37,934,050, or 16.9 percent more than shown
            in Table II.

         (c) Projected property valuations from 1976 to 1995 were calculated,
            based on growth projections for each entity.  These projections,
            which are in 1976 dollars without an inflation factor, are
            shown in Table III-2 and graphed in Figure 1.

In  addition to ad valorem tax revenues, other sources of revenue to
entities include tap fees, service fees, and readiness to serve fees.
These revenues are subject to discretionary determination by the
directors or councilpersons, and thus are not predicted here.  Readi-
ness-to-serve fees, which are controlled by statute, were discussed
on page  7.
                                   -60-

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$ l
             1970
1975
                                         -61-

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     Existing and Anticipated Legislation Affecting Consolidation


Existing legislation in Colorado permits special districts to  consolidate
(C.R.S. 32-1-133(1)) and subsequently for other districts to merge with
the consolidated district  (C.R.S. 32-1-119).  Statutes also permit the
creation of a county wastewater system  (C.R.S. 30-20-401 to 30-20-422).
Another statute authorizes creation of a metropolitan sewage disposal
district (C.R.S. 32-4-506(1)) to serve two or more municipalities.
However, the metropolitan sewage disposal district is the only form of
special sanitation district which can exist in the same area as an
existing special sanitation district  (C.R.S. 32-3-103).

Still another possibility, never tested in Colorado, is the formation
of a contracted wastewater management agency  (C.R.S. 29-1-202  to 29-1-
203).  A final possibility is creation of a regional service authority
 (Colorado Constitution, Article XIV,  §17, effective Jan. 1, 1972)
which is authorized by the Constitution to exist in a single county;
however, the enabling legislation  (C.R.S. 32-7-104(2) (a)) currently
requires R.S.A.'s to include all the territory of a minimum of two
counties.  Finally, there are some recent statutes, and statutes
expected to be introduced in the 1977 legislative session, which impact
on the proposed consolidation of sanitation entities in the Steamboat
Springs area.  Each of these topics is discussed at greater length in
the  following sections.

Consolidation of Districts

Colorado Revised Statutes 32-1-113(2) establishes the procedure for
consolidating two or more existing districts.  The procedure requires
passage of resolutions, a public hearing, and an election by persons
affected.  Subsequent to consolidation, other districts can merge with
the  consolidated district as described in C.R.S. 32-1-119.  The bonded
indebtedness of each district, at the time it becomes a part of the
consolidated district, remains an obligation of the persons owning
property within its boundaries  (C.R.S. 32-1-117).  Thus there  can be
a variable property tax levy within the consolidated district,
depending on which predecessor district area the property is in.

County Wastewater Systeir. -1-

As part of the powers granted counties under Colorado statutes (C.R.S.
 30-20-401 to 30-20-422), a county may create a water system or sanita-
tion system, or both.  In addition to the specific powers and  restric-
tions  contained in this discussion, the County Commissioners are given
other powers incidental to the operation of the system.  The governing
body is the Board of County Commissioners.
  1  This  subsection  and the  following three subsections are adapted,
with permission,  from Lyon, Collins & Co., Inventory of Potential  and
Existing Water Quality Planning and Management Agencies, Pueblo Area
Council  of  Governments,Denver,December  1975.'"
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The County Commissioners may operate the water and sanitation system
from service charges only.  They may not use funds derived from an ad
valorem tax levy.  There are no restrictions on the amount of debt
which may be issued.  However, only revenue bonds are authorized under
the statute.  Expenditures and budget controls are exercised by the
Board of County Commissioners.  The authority to plan, regulate and
enforce regulations pertaining to a wastewater system is inherent
within the statute.

General land use planning and building construction regulation are
already exercised by the County Commissioners.

County Improvement District

The County is also authorized to create, upon petition of a majority
of the electors owning not less than a majority of the assessed
valuation in the affected area, an improvement district.  The powers
granted to such a district include provision of sewer and storm
drainage collection systems.  Specifically excluded from the district
powers is the provision of wastewater treatment.

The District may be created by resolution and the governing body is
the Board of County Commissioners.  Both revenue and general obligation
bonds are authorized and the District is granted the power of ad
valorem taxation.  The sum of all debt may not exceed 25 percent of the
assessed valuation of the District.

It appears that the utilization of the county improvement districts
would not be possible unless it is utilized in conjunction with the
above described county wastewater system powers or under contract
with another government such as a city or a special district which has
a sewage treatment facility.

Metropolitan Sewage Disposal Districts

C.R.S. 32-3-103 specifies that no special sanitation district can be
formed within any area served by an existing sanitation district.  There
is one exception to this prohibition against "umbrella" or superimposed
sanitation districts — C.R.S. 32-4-501, which authorizes metropolitan
sewage disposal districts to serve two or more governmental entities
having sanitation functions.

Only one metropolitan sewage disposal district is in existence in the
State — that is the Denver Metropolitan Sewage Disposal District No. 1,
covering a portion of the Denver metropolitan area.  A similar District
could be created in other portions of the state.

A metropolitan sewage disposal district is a special district type of
government and like all other special districts its powers and duties
are defined and limited by State statute  (C.R.S.  32-4-501).  The
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primary power and duty of the district is the collection and treatment
of sewage.

Unlike other special districts, a metropolitan sewage disposal district
can only be formed by action of two or more municipalities which do
not need to be contiguous.  C.R.S. 32-4-501 to 32-4-547, which authorize
metropolitan sewage disposal districts, broadly define municipality as
"...a city, a city and county, an incorporated town, a sanitation
district, or a water and sanitation district,..."  Full power of pro-
vision of sewer services to the residents of a municipality is retained
in the municipality's government, and the district is assigned the task
of the interception, earring and treating the sewage from the municipal-
ities.

Creation of the district does not require an election.  An ordinance
may be initiated by one governing body and adopted by the other governing
bodies specified in the ordinance.

The governing body is a board of directors appointed by the executive
of each municipality with approval of the governing body of the munici-
pality.  Each municipality is entitled to one representative per 25,000
population or fraction thereof.  However, any municipality which has
50 percent or more of the total population of the metropolitan district
shall have 50 percent of board membership.

The governing body has the authority to delegate certain of its operating
powers to an executive committee.

The powers and duties of metropolitan sewage disposal districts are
summarized on Table III~3, below.

The district may levy an ad valorem tax not to exceed 3/4 of a mill
 (total, not annually) in its first five years of existence.  After that
time, the power to levy taxes is not granted.

The sewage disposal district has broad powers to establish service
charges to the municipalities.  These charges are in turn passed on to
the residents of the municipality.  The statute specifically authorizes
the utilization of ad valorem taxes by member municipalities to pay the
charges levied by the metropolitan district.

The metropolitan district may issue bonds,  following an authorizing
election.  Although these bonds are revenue bonds, they are considered
"indirect  general obligation bonds" since the district has the power to
mandate member cities or districts to levy ad valorem taxes to pay the
service charges from which the bond payments are made.  Bond counsel
have  successfully proposed several safeguards to assure the security
of holders of metro district bonds.
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                                       Table III-3

                        SUMMARY OF POWERS & DUTIES AUTHORIZED
                      TO METROPOLITAN SEWAGE DISPOSAL DISTRICTS
                                                                             Not
                                                            Authorized   Authorized
A.  Operations

    1.  Construction and operation of a sanitary
        sewage collection and treatment system.                   X
    2.  Construction and operation of a storm
        drainage system.                                                     X
    3.  Construction of sanitation or storm drainage
        facilities through special benefit districts.                         X

B.  Regulatory

    1.  Adopt rules and regulations governing the system.         X
    2.  Requirement for habitations to connect to the
        system.                                                  X
    3.  Control over connections to the system.                   X
    4.  Control over type wastewater discharges.                 X
    5.  Prohibition of specified harmful wastes.                 X
    6.  Regulation of land use through zoning.                               X
    7.  Regulation of construction through building
        codes.                                                               X

C.  Revenues & Finance

    1.  Property taxes and other general types for
        sanitation purposes.                                     X2
    2.  Monthly service charges for sanitation services.         X
    3.  Charges for connection to system.                        X
    4.  Charges for availability of service to vacant
        land.                                                    X
    5.  Extra charges for treatment of industrial type
        wastes.                                                  X

D.  Debt Financing

    1.  General obligation bonds for wastewater
        purposes.                                                            X
    2.  Revenue bonds for wastewater purposes.                   X
1  Authorized for a collection and treatment system which intercepts a municipal
system - but not a system serving residents and businesses directly.
2  Limited to 3/4 mill (total) for the first five years only.
3  Charges for service are levied to the municipality.


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Expenditure and budget controls are exercised by the board of directors

The metro sewage disposal district has the authority to plan its own
activities and future expansion.  However, it does not have the power
to plan for land usage or to enforce building codes.  This authority
is retained  in the member municipalities.  The district has authority
to regulate and enforce regulations dealing with the sanitation system.

Contracted Agency^

The Colorado voters in 1970 adpoted an amendment to Article XIV of
the Constitution allowing contracting between all types of governmental
agencies.  The subsequent enabling statute reads, in part, as follows:

             1.  Governments may cooperate or contract with one
                 another to provide any function, service, or
                 facility lawfully authorized to each of the
                 cooperating or contracting units, including the
                 sharing of costs, the imposition of taxes,
                 or the incurring of debt, only if such coop-
                 eration or contracts are authorized by each party
                 thereto with the approval of its legislative body
                 or other authority having the power to so approve.

             2.  Any such contract shall set forth fully the
                 purposes, powers, rights, obligations, and the
                 responsibilities, financial and otherwise,
                 of the contracting parties.
             4.  Any such contract may provide for the joint
                 exercise of the function, service, or facil-
                 ity, including the establishment of a sepa-
                 rate legal entity to do so.   (29-1-305, C.R.S.
                 1973, as amended).

 The  key  to  such  an approach is the agreement between the existing
 governmental agencies.  The powers, duties, governing board and other
 particulars would have to be specified in the agreement.

 Despite  its apparent legality, the provision of a contracted agency
 approach permitting imposition of taxes by one agency on property of
 another  has never been tested in Colorado.  Further, it founders on the
 unwillingness  of bond attorneys to issue bonds backed by a contractual
 agreement among  districts; they would require a vote of the property
 owners.  Thus, the contracted agency is not considered to be a feasible
 alternative for  the Steamboat Springs area, unless one agency assumes
 the  entire  bonded debt.
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Regional Service Authority

The voters of the State approved in 1970 Article XIV, § 17 of the
Colorado Constitution, allowing for the creation of Regional Service
Authority  (RSA).  RSA's have the functions approved by the electorate
at the election creating the RSA and those functions added at any
subsequent elections.  One of the powers which could be provided by
an RSA is wastewater management and planning.

The 1970 Constitutional Amendment allows RSA's to be formed within the
boundaries of one county.  However, the subsequent enabling legislation
enacted by the state legislature requires that an RSA be comprised of
an area encompassing at least two counties.  This provision would have
to be changed before an RSA would become legislatively feasible in
the Steamboat Springs study area.

Applicability of Federal Bankruptcy Law

One statute recently adopted by the Colorado legislature will have
a significant impact on the future of special districts in the
Steamboat Springs locality.  This is S.B. 44 (50th Gen. Assy.);
"Concerning the Authorization of Certain Special Districts to Avail
Themselves of Federal Bankruptcy Laws."  S.B. 44, which became law in
1976  (C.R.S. 32-1-1001 to 32-1-1006), permits water and sanitation
districts to file bankruptcy petitions and, with district approval,
to issue new bonds having lower interest rates and extended payment
periods.  Such bonds would replace existing bonded debt.

Prior to the passage of S.B. 44, districts had to obtain state consent
before they could enter into bankruptcy., procedure.  Under the new law,
a district may file under Chapter IX of the Federal Bankruptcy law if
it can prove mathematically that it would be unable to pay bonded
indebtedness even with a 100 mill tax levy.  To successfully refinance
under Chapter IX, a district must obtain approval of at least half its
bondholders, who must represent two-thirds of the value of the bonded
debt.  A plan of recovery, showing future district viability, is required.

                    Organizational Alternatives

In considering the organizational alternatives, or management plan,
whereby the sanitation entities can be consolidated, the essential
requirement is legality.  Even if legality is assured, there remain
questions of political and administrative feasibility.

Questions of financial equity also must be faced in planning for
consolidation.  If the entities are consolidated, certain existing
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facilities can be incorporated into the master facilities plan but
other facilities will be abandoned.  Should the costs of constructing
the new facilities be shared equally?  Or if the law permits, should
an effort be made to adjust the costs according to the value and
condition of the facilities which each separate entity brings to the
consolidation?

Another question of financial equity revolves around how the operating
and maintaining costs of the consolidated sanitation entity should be
allocated.  For example, if one district has collection lines which
are in poor condition, with high infiltration and inflow, should a
higher share of maintenance costs be allocated than with a district
having few maintenance problems?  Should an extra share of operating
costs be allocated to areas of the district which may require pumping
of effluent, while others utilize gravity?  It should be noted that
consolidations are often politically difficult to arrange, and the
representatives of the individual entities may find it necessary to
overlook strict accounting advantages in order to smooth the ultimate
agreement.

It may, in fact, be necessary for certain financially healthy districts
to agree to subsidize districts in weaker financial condition, in
order to induce them to join the consolidated district.  This may be
done from a sense of community, as it may be the only alternative to
bankruptcy or prohibitively high property taxes for certain districts.
It may also be the only way to obtain a federal government grant for
regional wastewater treatment.  If so, the residents of the financially
healthy districts may need to agree to some indirect subsidy of the
weaker districts  (e.g., jointly sharing the financial task of a bond
issue, or agreeing to share equally in total district operating and
maintaining costs).

Some of these aspects are discussed at greater length below.

The  following alternative mechanisms for organizational consolidation
are  not considered feasible, for the reason specified:

Regional  Service Authority

The  enabling legislation requires that an RSA be comprised of an area
encompassing at least two counties.  This is clearly impractical for
the  Steamboat Springs area, and there is not present likelihood that
this restrictive legislation will be changed.

County  Improvement District

The  function of wastewater treatment is specifically excluded by
statute from the powers of county improvement districts.
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Metropolitan Sanitation District

Under the 1947 statute (C.R.S. 32-3-101 et seq.), no new special
district having sanitation functions can legally be formed to serve
territory already in an existing sanitation district.  The exception
is a metropolitan sewage disposal district, authorized by the later
statute  (C.R.S. 32-4-501 et seq.).

A New Regional Water and Sanitation District

It is conceivable that a regional water and sanitation district could
be formed under C.R.S. 32-4-103, providing all existing districts
having similar functions were first to be dissolved as provided by
C.R.S. 32-4-133.  Because present districts in the Steamboat Springs
area have bonded debt, dissolution is impractical if not impossible.

A Consolidated Water and Sanitation District

The existing water and sanitation districts could consolidate under
the provisions of C.R.S. 32-1-113(1).  However, the delays which would
be required for districts to consolidate their existing debt make this
option undesirable, and there is substantial likelihood of unwillingness
on the part of some existing districts to give up control of their
power to levy taxes to the board of directors of a new and unfamiliar
district.   (By contrast, if a stable metropolitan sewage disposal
district were formed and operated successfully, the existing districts
might ultimately be more willing to consider consolidation.)

The more feasible alternative mechanisms for consolidation of sani-
tation entities are:

A.  Contract Agency.   The city will take leadership in issuing bonds
    for  financing and operating the regional sanitation system, serving
    other entities through contracts.

B.  County Wastewater System.   This system would provide sewage
    collection and treatment for all out-of-city areas, and contracting
    with the City of Steamboat Springs for construction and operation
    of the regional treatment facility.

C.  Creation of an "umbrella" Regional Sewer Service District.   This
    district would include the entire study area, and would necessarily
    take the form of a metropolitan sewage disposal district, since
    any  other form of umbrella sanitation district is prohibited from
    organization within the boundaries of an existing sanitation district.
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                           Alternative A
                          CONTRACT AGENCY
1.  All six special water and sanitation districts would remain in
    existence to be responsible for repayment of current debt; operation
    and maintenance of potable water systems (distribution mains, and
    in some cases water supply and treatment facilities); and estab-
    lishment of property tax levies and service charge rates.

2.  KOA and Sleepy Bear would organize, together or separately,
    special water and sanitation districts containing their property and
    possibly other adjacent areas which may require service in the future.

3.  City of Steamboat Springs obtains EPA grants and issues bonds
    (revenue or general obligation) to raise the local share for
    construction of regional sewage treatment plant and connecting
    interceptor lines.

4.  City operates new regional treatment facility, processing sewage
    from the city and all special districts outside city limits
    through contract.

5.  City levies sewage treatment charges to all users.  In-city
    users will be billed individually.  Out-of-city users may be
    individually billed or the district billed on a volume basis.
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                           Alternative B

          COUNTY WASTEWATER SYSTEM CONTRACTING WITH CITY
1.  Routt County creates, by resolution, a sewage collection and
    treatment district which assumes sewage collection and
    treatment responsibility for all areas outside city limits
    (i.e., Riverside, West Steamboat, KOA, Sleepy Bear, Tree Haus,
    and Steamboat II).

    la.  Routt County may also assume potable water supply respon-
         sibility for the above entities, and the responsibility
         for bond redemption.  In this subalternative, the special
         districts would be dissolved and the County would assume
         their present functions.

2.  Routt County issues revenue bonds to pay for a portion of the local
    share of the cost of the regional sewage treatment plant and general
    obligation (or revenue) bonds to pay for interceptor lines connecting
    the above-named areas to the major outfall line.  (NOTE: Only
    property in the above-named areas would be obligated to pay for
    G.O. bond repayment.)

3.  City issues bonds to pay for other portions of local share.

    3a.  City may assume potable water supply responsibility for
         Fish Creek and Mt. Werner, and responsibility for bond
         redemption.  In this case, the special districts would
         be dissolved.

4.  Routt County would negotiate a contract with the City of Steam-
    boat Springs for construction and operation of a regional
    sewage treatment facility.  The contract would specify the
    relative shares of the construction cost (local share only)
    and the future sewage treatment charges for out-of-city
    customers.

5.  Routt County levies a property tax on the sewage collection and
    treatment district and determines service charges for out-of-city
    customers.

    5a.  If Routt County also assumes potable water supply and debt
         retirement functions, it might assess differential tax
         levies and service charges in various parts of the
         district, as appropriate.

6.  City levies property tax on sewage collection and treatment
    works and determines service charges for city customers.
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                          Alternative C

             CREATION OF REGIONAL SERVICE DISTRICT
            (METROPOLITAN SEWAGE DISPOSAL DISTRICT)
1.   The City of Steamboat Springs and other entities would adopt by
    resolution an ordinance creating a metropolitan sewage disposal
    district.  The area of the district would include the City of
    Steamboat Springs, the six special districts  (Mt. Werner, Fish
    Creek, Tree Haus,  Riverside, West Steamboat, and Steamboat II),
    and the KOA and Sleepy Bear properties, after they took legal
    steps to participate.

2.   A board of directors would be appointed to govern the metropolitan
    district.  Each special district would appoint one director.  The
    executive of the City of Steamboat Springs would appoint, with
    approval of the city council, half of the total number of
    directors.

3.  The district would take steps (i.e., arrange a "joint and several
    obligation contract") to maximize bond security and would hold an
    election to authorize issuance of revenue bonds to pay the local
    share of the construction cost of regional facilities.

4.  The metropolitan district would become the grantee for the EPA
    design and construction grants and would construct a regional
    sewer treatment facility and interceptor lines.

5.  The metropolitan district directors could levy a small (up to
    3/4 mill for the first 5 years)  property tax on the property
    within the district and would set service fees for sewer service.
    The district would be responsible for debt service of the new bond
    issue, and would mandate the levying of ad valorem taxes by
    member entities, to assure payment of service fees from which bonds
    would be repaid.

6.  The metropolitan district would assume operation and maintenance
    responsibility of all elements of existing sewer systems except
    collection lines.  Some existing facilities would be abandoned.
    The district also would operate and maintain the newly-constructed
    facilities.

    6a.  The new metropolitan district may contract with city for
         operation and maintenance of regional system.

7.  The City of Steamboat Springs and each of the six or seven special
    districts would continue to be responsible for potable water
    service, maintenance, and expansion of service collection
    systems, and service of existing debts.
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8.  In the future, the special districts might choose to dissolve and
    their collector sewer maintenance and debt service responsibilities
    could be assumed by the metropolitan district.  Their water service
    responsibilities might be assumed by a co-existing water district.
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                 Financial Effects of Alternatives
The financial effects of the three feasible organizational alternatives
described in the previous section are forecasted and analyzed below.
To assist in the analysis of the three cases, a payment schedule has
been developed which will repay the anticipated costs of constructing
Phase I  (in 1977) and Phase II  (in 1985) of the proposed regional
sewage treatment plant and necessary connecting interceptors.

It was assumed in this analysis that the existing bonded indebtedness
of each entity would be paid off by revenue from the property lying
within the present boundaries of each entity  (as the law requires).
Although it is possible that some entities may be required to take
action pursuant to Chapter IX of the Bankruptcy Act, or alternatively
that some healthier districts may indirectly subsidize the debt of
weaker entities, neither alternative has been included in the forecasted
payment schedule.  Similarly, no reliance was made on possible grants
from the Colorado Division of Local Government, to assist needy entities
in wastewater treatment construction.

Because of the considerable existing bonded debt, the payment
schedule for the 201 project has deliberately placed the greater
burden in the last half of the 20-year repayment period, to allow
weaker entities to recover their financial health during the 1977-1985
period.  The payment schedule has been provided through the courtesy
of Stern Brothers & Co., who followed our specifications in calculating
future property valuation and in assuming a quite conservative interest
rate on  the new bonds.  The assumption used by Stern Brothers & Co.
are as follows:

     1.  That once a maximum debt level is reached, an attempt would
         be made to level off the debt service.

     2.  That an interest rate of 8% on the bonds is sufficiently
         conservative.  At this time a rate should be below 8%.

     3.  That the cost of Phase II would be substantially higher by
         1985.  Again, being conservative, we have programmed in a
         $3,000,000 bond issue.

The letter of September 20, 1976 from Stern Brothers & Co., with attached
debt repayment schedules, is included as Appendix A.

Table IH-4, which follows, shows the prospective tax levy for each of the
entities, by multi-year intervals, required to repay existing debt and
to carry a proportionate share of the new bonded debt.  This table has
been calculated by dividing scheduled payments on existing debt  (Table III-l)
by forecasted valuation  (Table III-2) and adding the prospective mill levy
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for new debt as calculated by Stern brothers & Co.  It should be noted
that this table assumes that new debt capital recovery is handled by
property taxes; thus the annual service charge would include only
operation and maintenance costs  (see Table III-5).

It should be noted that the mill levies shown in Table III-4 are considered
conservatively as the maximum levies possible.  This is because the
forecasted valuations in Table III-2 understated the 1976 (and subsequent)
valuations by 16.9 percent, and because Stern Bros, used a conservative
8 percent interest rate on bonds.  As a result, the mill levies shown
in Table III-4 should accomodate any likely inflationary increase in
construction cost of the regional sewage treatment facilities.

                              TABLE III-4

       ESTIMATED PROPERTY TAX LEVY TO REPAY EXISTING AND NEW BONDED
       DEBT, FOR CITY OF STEAMBOAT SPRINGS AND DISTRICTS IN STUDY AREA,
                    IN MILLS BY MULTI-YEAR INTERVALS

                                           (Year)
Entity              1977     1980     1985     1990      1995

Old City            29.1     27.1     23.4     15.4      12.8
Mt. Werner          16.1     15.1     18.4     16.4      12.8
Fish Creek          36.1     37.1     36.4     42.4      12.8
Tree Haus1          70.1     86.1     68.4     62.4      12.8
West Steamboat      49.1     34.1     31.4     31.4      12.8
Steamboat II        75.1     69.1     59.4     49.4      12.8
Riverside           70.1     77.1     78.4     88.1      12.8

Alternative A, Contracted Agency

The City of Steamboat Springs would obtain EPA grants and issue bonds
 (general obligation or revenue) to pay the local share of construction
of the 201 project.  In turn, each out-of-city user  (directly or through
their district) would be billed for a service fee.  This fee would pay
operation and maintenance costs for the new facilities2 plus a capital
recovery charge to repay a proportionate share of the new bonded
indebtedness assumed by the city.   The city would assume the full
risk of bond retirement and would be dependent on the continued receipt
of service fees from outside-the-city users to help repay the bonded
debt.

The following Table III-5 shows projected service charges for outside city
customers at multi-year intervals.
    The mill  levy projections for Tree Haus do not consider the revenues
received from developer's notes.  Such note interest is the major source
of debt service revenue, thus 1976 tax levies are only 6.44 mills.
 2  As determined by Wright-McLaughlin in Vol. 2, Steamboat Springs Facilities
Plan.
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                              TABLE IH-5

       TOTAL SEWER SERVICE CHARGES (ANNUAL PER DWELLING UNIT)
         FOR CUSTOMERS OUTSIDE CITY OF STEAMBOAT SPRINGS

                    New Debt
    Year         Capital Recovery      Oper. & Maint.      Total

    1977            $12.29                $29.62           $41.91
    1980             33.64                 30.88            64.52
    1985             63.20                 35.23            98.43
    1990            152.92                 34.21           187.13
    1995            188.22                 33.18           221.40

The inside-city customers  (including Mt. Werner and Fish Creek) would
pay a comparable amount for sewage service.  The O & M portion must be
uniform  on all users, in- and out-of-city.  The City may opt to recover
the capital recovery portion from in-city users by either the uniform
service charge  (as in the above table) or through ad valorem taxes.
 (Ref. Section 204b  (1) of the Federal Water Pollution Control Act of
1972.)

Each of the existing special districts would remain in existence, with
the following functions:

 (a) To raise revenue through ad valorem taxes, perhaps supplemented
    by service  fee surcharges and/or readiness to serve fees, to retire the
    prior bonded indebtedness.

 (b) To monitor  their contract with the City of Steamboat Springs, i.e.,
    to assure performance under the contract.

 (c) Perhaps to bill individual out-of-city users, paying a single
    invoice to  the city each month.  Alternatively, the City could
    contract to handle billing of individuals.

Administratively, Alternative A gives lead authority for financing,
construction, operation and maintenance of the regional program to the
City of Steamboat Springs.  This situation may not be politically
favored by all  entities which would be served by the system under
contract.  Under Alternative A, Mt. Werner and Fish Creek would not be
subject to double taxation; however, they would have less authority
than at present.  Ultimately, they could choose to dissolve and transfer
their remaining responsibilities  (i.e., taxing to retire prior debt)
to the City.  Once their debt is retired, the City could initiate a
dissolution election, pursuant to the Colorado Statute on Special
District Dissolution  (C.R.S. 32-4-133).
1  Eg_ual rate based on C per 1000 gal. of influent flow.
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Alternative B, County Wastewater System

Under Alternative B, the City of Steamboat Springs would issue bonds
 (G.O. or revenue) on its portion of the construction cost.  Routt
County would issue revenue bonds on its portion of the treatment plant
cost, and G.O. or revenue bonds on its portion of the interceptor
lines.  If G.O. bonds are chosen, they would be secured only by out-of-
city property to be served.   (County property outside the wastewater
system service area would not be taxed nor charged for service.)

The costs for in-city users would be essentially identical to those in
Alternative A.  The costs for out-of-city users would probably be
somewhat higher than in Alternative A because of the statutory require-
ment to issue revenue bonds, rather than G.O. bonds, on the treatment
plant portion.^-  This could require a premium of 1 to 1 1/2 percent
on interest, based on current conditions.  Also, under Alternative B,
the County could recover the capital cost portion of costs from ad
valorem taxes rather than a uniform service fee (as in Alternative
A).  This would place a higher burden of cost on the higher-valued pro-
perty.  These determinations of equity  (ad valorem tax vs. uniform
service fee) would be made by the County Commissioners.

Under Alternative B, the City would assume less bond risk and thus might
obtain a better interest rate than under Alternative A.

Administratively, Alternative B would give authority to a new entity
not now directly involved — Routt County — and would give the County
essentially equal authority with the City in Determining the future of
the wastewater system.  If the City Public Works Department operated
the plant, the County's role as contract customer could result in
interference with line of command in operating the facilities.  With
a properly written contract, this problem could be minimized.

Alternative C, Regional Sewer Service District  (Metropolitan Sewage
Disposal District)

A new "umbrella" regional sewer service district would be formed to
finance, construct, operate and maintain the regional treatment facility.
This necessarily would take the form of a metropolitan sewage disposal
district.

With authority to issue bonds backed by authority to mandate taxes on
the entire study area, including the city, the regional district should
obtain a favorable bond interest rate.  The costs would probably be
essentially the same as in Alternative A.  The directors of the
metropolitan district, who would be appointed by each participating
1  This, of course, assumes that under Alternative A, the City  chooses
to issue G.O. bonds rather than revenue bonds.
                                 -77-

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entity, could authorize only very limited  (a maximum of 3/4 mill)
ad valorem taxes, and would repay the new bonded debt by uniform service
charges.  Operation and maintenance costs must come from service fees.

The new metropolitan district would assume much of the administrative
control of wastewater treatment now held by the City and special
districts.  Those districts could continue in existence to handle
repayment of prior debt or could ultimately dissolve and assign this
responsibility to the metropolitan district.

Water Supply Service

In the preceding sections we have not dealt with the subject of  water
supply.  Since each of the special districts is a water and sanitation
district, they could remain in existence and handle water supply service
as they currently do, i.e., by their own supply or by contract with
the City of Steamboat Springs.  Obviously, before any of the existing
districts dissolves, it must be assured that its water supply functions
are assumed by a responsible successor.
                                -78-

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                 IV.  Other  Existing  Environments


The existing environment of the project area is described in  a  variety
of books and reports and is not repeated here in all its detail.   How-
ever, its major features are described, and special emphasis  is accorded
to the aquatic and agricultural environments.  The total range  of  topics
includes physiography, geology, soils, biology, climatology,  air quality,
odor, history, population, land use, socio-economics, transportation,
noise, solid waste, demographics, recreation, aesthetics, culture  and
other federal or state projects.
                           Physiography

The study area that is delineated by the Steamboat Springs  Regional
Services Authority encompasses 37% square miles.   Its shape ranges
from flat stream valleys to steep mountain slopes.  The lowest eleva-
tion occurs in the Yampa River floodplain on the  west border of the
area (6600 ft.) and the highest occurs near its east border,  at the
base of Mt. Werner (8000 ft.).  The river flows through the center
of the study area, where it has an average slope  of 22 feet per mile
and an average floodplain width of 800 feet.  Along its floodplain are
numerous river terraces, flat mesas and irregularly-shaped  plateaus.
Tributaries of the Yampa are minor and include Walton, Burgess, Fish,
Spring, Butcherknife, Soda and Slate Creeks.

                              Geology

The geologic history of the area is not of paramount importance to the
project although some of its resultant features are mentioned in the
section entitled Evaluation of the Alternatives.   The major mountain
range is called the Park Range and it began its uplift about 60 to 70
million years ago.  Since that upthrust, inland seas or rivers have
covered the area and deposited softer sedimentary rocks. Most prominent
among these rocks are the formations called Morrison, Dakota Sandstone,
Mancos Shale and Browns Park.

Along the Yampa River are located layers of unconsolidated  material,
called alluvium.  This material was placed there  by glaciers and river
flow, and its constituents range from clay-sized  particles  to large
boulders.  The southern part of the Yampa River alluvium is comprised
of black organic silt and clay, three to eight feet in thickness.
Underlying this are layers of gravel-clays, well-sorted sands and
gravel.  Further to the north the organic layer thins out and by
Steamboat Springs it disappears.  From this point on, the surface
alluvium is mainly sand and gravel, varying in thickness between
20 and 40 feet.
                               -79-

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The major geologic hazards for the project include flooding and earth-
quakes.  The 100-year floodplain is depicted in Study Map 1, which
shows the coverage area for a flood occurring with an average frequency
of one in 100 years.  The ramifications of its occurrence are discussed
in the Evaluation of the Alternatives.  The possibility of an earthquake
in this area is remote but it could happen.  The most significant fault
in the area extends through Steamboat Springs in a north-south direction
and it is not known to be active.

                               Soils

Many of the soils in the area are good for farming yet they are usually
limited by slope and lack of moisture (Charlie Hogelin, SCS, Steamboat
Springs, personal communication).  This latter factor is less easily
handled and often leads to erosion.  Those areas that are currently
irrigated are shown on Study Map 2.  However, for the purposes of this
discussion, only those sites along the Yampa River are being considered.
These  sites are shown in Figure  5.

The sites to be irrigated are located on work silt loam  (2A,C) and an
unnamed valley bottom loam  (12A,AW).  The work silt loam is a well-
drained soil that occurs on gently sloping terrain.  Its surface layer,
called the A horizon, is about 20 inches thick and is comprised of silt
loam.  Its permeability is moderate and its available water capacity
for plants is high.  The B horizon is also 20 inches thick, containing
silty  clay loam.  This horizon has a lower permeability and available
water  capacity than the A horizon does.  The C horizon is also 20 inches
thick  and contains silty clays.  The permeability of this horizon is
lowest of the three due to its high percentage of clay.  All horizons
have a high shrink-swell potential and a moderate to low frost-action
potential.  The depth to bedrock is greater than five feet and the
depth  to seasonal high water table is greater than six feet.  When
these  soils are used for irrigation, their percolation rate is generally
slow.

The unnamed valley bottom loam  (12A,AW) is a moderately deep, somewhat
poorly-drained soil.  Its A horizon is nine inches thick with a silt
loam consistency.  Permeability  of this horizon is moderate, while its
available water capacity for plants varies from moderate to high.  Its
pH ranges from 6.6 to 7.8.  The  B horizon has a clay loam consistency
with a 12-inch thickness.   Its permeability is lower than the A horizon's
permeability and  its available water capacity for plants is moderate to
high.  Its pH is  comparable to the A horizon's pH.  The C horizon ranges
from 21 to at least 60 inches and is comprised of gravely silt loam.
It has a very high permeability  due to its large particle size and a
                               -80-

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                            I  WEST STEAMBOAT WATER 8 SANITATION.	—
                                      DISTRICT . BOUNDARY ...
   SLffff BEAR
            I
            KOJ  CAMPGROUND  «»,
         PROPOSED
         INTERCEPTOR
MAPPING    SOIL
  NIT
2A.C.E,
6F
9E,C
IOE.F
         WORK SILT LOAM
         HANDRAN STONY LOAM
         HESPERUS-WATERING LOMPLEX
         BUCKLEY SILTY CLAY
         UN-NAMED LOAM
         UN-NAMED LOAM
         UN-NAMED LOAM
         UN-NAMED LOAM
         PERMA^HESPERUS LAND
         WET ALLUVIAL LAND
         HAYBRO-MOYESON COMPLEX
                                                                   STEAMBOAT SPRINGS
                                                                                      FIGURE 5
                                                                              PROJECT AREA SOILS

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moderate available water capacity for pH.  The pH of this horizon  is
moderately alkaline, varying from 7.9 to 8.4.  All horizons possess
a low shrink-swell capacity although their frost action potential  is
high.  This latter potential is due to the low to moderate permeability
of the A and B horizons  (0 to 21 inches), plus the 24-inch seasonally
high depth to the water table.

The other major soils to be impacted by  the project are represented
by the mapping units 11A and 49A.  These soils are crossed by  the  pro-
posed new collectors.

The 11A soil is a deep, well-drained clayey soil that  is formed  in level
alluvial terrain.  The A horizon possesses a silty clay loam;  the  B
horizon, a clayey loam,- and the C horizon, a silty clay loam.  This
profile takes water very slowly yet holds a large amount.  The depth
to bedrock is greater than five feet and the depth to  the seasonal high
water table is greater than six feet.  Its potential for revegetation
is fair since its top soil is somewhat clayey.

The 49A soil is a deep, somewhat poorly-drained soil,  located  on level
to nearly level terrain.  It has a loamy consistency to a depth  of about
26 inches.  Beyond this depth the materials are river  sands and  gravels.
Because of this condition, the depth to  seasonal high  water table  is
about two feet.  The soil above the water table has a.  moderate perme-
ability and a moderate water holding capacity for plants.  Its potential
for revegetation is fair.

                              Biology

The discussion on biology is divided into one section  on the aquatic
environment and one on threatened and endangered species.  The aquatic
environment is important because it presently receives the secondary
effluent  from the existing sewage operations, and it may receive por-
tions of  the tertiary effluent in future operations.   The threatened
and  endangered species are discussed because their continued existence
could be  threatened by the project and its growth ramifications.

Aquatic

The  Yampa River is  the major aquatic environment of the project  area.
Studies  have shown  its ecological health to be marginal due to several
aspects  of  its physical  environment  (Wright-McLaughlin Engineers,
October  1975).  This has resulted in a poor habitat for fish and a poor
to average  habitat  for aquatic insects.  An explanation for this situa-
tion  is  offered in  the text that follows, organized according  to physical
conditions, plants, insects, and fish.

The physical status of the river was analyzed by Dr. Robert W. Pennak
in July  1975.  He organized the Yampa River into three ecological  units
                                   -81-

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(Wright-McLaughlin Engineers, October 1975).  The first area (I)
extended from the south boundary of the study district to a point
just short of Steamboat Springs, covering a distance of 2.5 miles.
The second area  (II) extended 1.5 miles through Steamboat Springs,
and the third area  (III) extended 4 miles from below the city to
the district's west boundary.

The river banks through area I were characterized by irrigated grass-
lands or hayfields and were frequently grazed by cattle.  When the
activities of these cattle were combined with haying operations next to the
river, natural streamside vegetation was often removed.  This condition
reduced the amount of overhanging cover necessary for good trout habitat.
It may also have allowed eroded particles to be added to natural back-
ground levels and irrigation return flows, which combine to layer the
river bottom with organic silt or clay.^  Potential effects of this
siltation include clogging gills and mouth parts of aquatic insects,
smothering eggs and developing young of insects and fish, plus reducing
the quality of breeding habitat for fish.

The total range of components in the river's bottom included boulders,
rubble, gravel and sand-silt (Table IV-1).  The percentage of sand-
silt in area I was 27, which was several times greater than values from
the other areas.  Although this analysis did not indicate a total
coverage with silt, it did indicate sufficient silt to layer the bottom
between scattered boulders, rubble and gravel.

Bank stability in area I was judged to be 61 percent by Dr. Pennak
(Table IV-1).  A bank was considered stable if no soil sloughing occurred
during the previous year and unstable if sloughing did occur.  Several
banks were investigated in each ecological area.

The average width of the river through area I was 96 feet.  Its average
pool depth was about three feet and its average riffle depth was about
two feet.  This pool depth was too shallow for proper trout habitat.

The length of the river through area I was about 2.7 times longer than
it would be if it assumed a straight-line course.  The resultant meander
would have provided good habitat for trout, except that the physical
conditions of shallow pools, siltation and loss of natural riverside
vegetation precluded it from happening.
   The Routt County Planning Commission unanimously approved a resolu-
   tion calling upon EPA to strike any reference to agricultural impact
   on upbasin riverbank erosion.
                                 -82-

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                      TABLE IV-1

          PHYSICAL CONDITIONS OF YAMPA RIVER1

                       July 1975
Parameter
Bottom Composition
   Boulder
   Rubble
   Grave1
   Sand-Silt
                        Area I
12
17
44
27
             Area II
14
66
14
 6
                                                     Area III
17
67
11
 5
Bank Stability
   Stable
   Unstable
61
39
962
 4
76
24
1  Taken from the Steamboat Springs Wastewater Management Report,
   201 Facilities Plan, Volume One.  Wright-McLaughlin Engineers,
   Denver, Colorado, October, 1975.

2  Artificial stabilization.
                         -83-.

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River conditions in area II were slightly poorer than in area I, due
to encroachment from the city and stream channelization.  Stream channel-
ization had brought about a straighter channel and a more homogeneous
stream bottom, both of which were poor for aquatic life.  The river
was often bordered by dikes, levees, railroad beds or streets, and
the pools and riffles were less well-defined than in area I.  The natural
trout population was small along this stretch although plantings by the
Colorado Division of Wildlife were used to supplement it.  These plant-
ings could have actually hindered the natural trout populations, however,
since they had to compete for scarce food with the introduced hatchery
trout.

Conditions for trout improved downstream in area III.  The river here
had more meander than the straight-channel pattern of area II and its
pools and riffles were deeper, longer and better defined.  Humanly-
induced disturbances occurred above and below the KOA campground, where
channelization has straightened the river course.  Hay cutting and cattle
grazing also added its effects by removing native vegetation near the
river and fostering erosion.

The aquatic plants of the Yampa are generally contained in a film on
the bottom called periphyton.  This film contains not only plants but
also bacteria, fungi, protozoans, tiny animals and the tissue of a mul-
titute of dead organisms.  This dead tissue usually makes up the majority
of the film's substance and it is actively consumed by bacteria and other
tiny organisms.  The plants in the film are generally one-celled organisms
called algae.  A list of these organisms is shown in Tables IV-2 and
IV-3.  They account for the majority of plant production that occurs
within the river's boundaries.

A qualitative collection of these organisms was accomplished on August
25, 1975 by the USGS at stations Y3 and Y8 (Table IV-2).  Station Y3
was located at the USGS gaging station in Steamboat Springs  (Study
Map 1) and station Y8 was located about one and one-half miles upstream
from the Elk River.  The dominant algae found at the Steamboat station
(Y3) were the diatoms Navicula and Nitzschia and the blue-green alga
Lyngbya.  The latter two were characteristic of the putrid zone of de-
composition, which follows a discharge of sewage  (U.S. Dept. of Interior,
1966).  The dominant algae at station Y8 were the green alga StigeocIonium,
the diatom Nitzschia, and the blue-green alga Lyngbya; they, too, were
found in the decomposition zone downstream from sewage discharges.

Additional periphyton was sampled by the USGS on September 5, 1975,
emphasizing the algae's biomass and productivity.  The results of this
sampling have been combined with results of the earlier sampling
(August 25, 1975) in Table IV-3.  Their productivity was reflected in
chlorophyll pigments a and b, which convert sunshine, carbon dioxide,
and water into organic compounds and oxygen.  The density of chloro-
phyll II varied from 6.3 milligrams per square meter at station Y2 to
                               -84-

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                            TABLE  IV-2
                  PERIPHYTON OF THE YAMPA RIVER

                         August 25, 19751
Organism Name
Chlorophyta
   Chlorococcales
      Characiaceae
         Schroederia
      Occystaceae
         Ank istrodesmus
      Scenedesmaceae
         Scenedesmus
   Oedogoniales
      Oedogoniaceae
         Oedogonium
   Ulotrichales
      Chae tophor ace ae
         Stigeoclonium
Chrysophyta
   Centrales
      Coscinodiscaeae
         Cyclotella
         Melospira
   Pennales
      Achnanthaceae
         Achnanthes
         Cocconeis
      Cymbellaceae
         Cymbella
         Epithemia
      Diatomaceae
         Diatoma
      Fragilariaceae
         Synedra
      Gomphonemataceae
         Gomphonema
      Naviculaceae
         Navicula
      Nitzschiaceae
         Nitzschia
      Tabellariaceae
         Tabellaria
   Heterosiphonales
      Vaucheriaceae
         Vaucheria
Cyanophyta
   Oscillatoriales
      Oscillatoriaceae
         Lyngbya
         Oscillatoria
   Chroococcales
      Chroo coccaceae
         Agmenellum
                               Common Name
Green alga
Diatom
   Centric
   Pennate
                        Station    Station
                           Y3        Y8
                           P

                           P
Yellow green alga
Blue-green alga
   Filamentous
   Coccoid
                           P
                           P

                           P
                           P

                           P
                           P

                           D

                           D

                           P
                           D
P

P
                                     P
                                     P
P
P

P

P

P

P

D
                                     D
                                     P
   Preliminary information collected by the USGS  and  subject  to further
   scrutiny and verification.
                                                                           -85'
2  Present.
  3  Dominant.

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             TABLE IV-3




BIOMASS OF PERIPHYTON ON YAMPA RIVER




            September 5,  1975
August 25, 1975

CD
cn
i


Dry Biomass
(g/m2)
Ash Biomass
(g/m2)
Chlorophyll a
(mg/m2)
Chlorophyll b
(mg/m2)
Station
Yl
6.5
4.6
5.0
0.8
Station
Y2
15.0
12.0
6.3
0.6
Station Station
Y4 Y5
6.1 9.5
4.2 6.1
5.0 4.8
0.6 0.4
Station
A3
15.0
3.5
4.1
0.1
Station
A6
1.7
1.2
3.8
0.3

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4.8 at station Y5; this lower density occurred just below the Steamboat
Springs sewage outfall.

Associated with the phytoplankton are larger plants, rooted in the
river's rocky bottom.  They exist in small quantities and do not account
for a significant percentage of the river's plant production.  Addi-
tional plant material is incorporated into the river from terrestial
sources.  Plants from this source could account for more production
than is created by the aquatic plants, especially during the fall.  None-
theless, the health of the river's own plants is essential if healthy
trout populations are to be revived.

The insects of the Yampa are a primary source of food for the trout
population; biologists call them benthic organisms.  They feed on peri-
phyton, organic matter suspended in the stream, and sometimes each other.
They are comprised largely of two-winged flies and caddisflies although
mayflies, beetles, mites and snails can also be found.

The USGS verified this assessment on August 25, 1975 with a benthic
survey at the same two sites sampled for periphyton.  The results of
their analysis are summarized in Table IV-4, according to organism
name, common name and density.  The densities represented the numbers
of organisms taken within  one  square  foot  at each  station.  Their  sampling
near the gaging station  (Y3) was dominated by two-winged flies although
it received secondary contributions from caddisflies.  This situation  a
was more pronounced upstream where the flies were clearly the dominant
insect.  Further downstream at station Y8, caddisflies became the co-
dominant bottom insects, along with the two-winged flies.

When the total variability of insect types was considered, it was
found that ecological diversity decreased below the area's point source
discharges.  Ron Eddy of EPA discovered this phenomenon on the benthic
samples he collected during September 1975  (Publication in bibliography).
Although the total number of organisms stayed about the same at his
stations above and immediately below the city's sewage outfall, eco-
logical diversity decreased immediately below the outfall.  This means
that below the sewage outfall, a greater number of organisms were con-
centrated within a fewer number of species  (or other taxanomic categories) .

In addition to the diversity of these organisms, their population numbers
and the weight were also indicators of the river's health.  The
numbers found at station Y3 by the USGS were 65 per square foot or
    Other  ecological diversities have been developed by Libby Aimes of
    Colorado State University at Fort Collins, Colorado; her work was
    done for BLM and her publication is in progress.
                                -87-

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                         TABLE IV-4
          BENTHIC INVERTEBRATES OF THE YAMPA RIVER

                      August 25, 19751
Organism Name

Hydracarina
Coleoptera
   Elmidae
      Optioservus
      Zaitzevia
Diptera
   Chironomidae
      Microtendipes
      Nanocladius
      Orthocladius
      Pentaneura
      Phaenopsectra
      Polypedilum
      Tanytarsus  j,
      Rheotantarsus
   Rhagionidae
      Atherix     '
   Simuliidae
Epheme ropte ra
   Baetidae
      Baetis
      Ephemeralla
   Ephemeridae
      Tricorythodes
   Heptageniidae
Piecoptera
   Pteronarcidae
      Pteronarcella
   Perlodidae
      Arcynopteryx
Trichoptera
   Helicopsychidae
      Helicopsyche
   Hydropsychidae
      Cheumatopsyche
      Hydropsyche
      Arctopsyche
   Hydroptilidae
      Leucotrichia
      Ochrotrichia
   Leptoceridae
      Athripsodes
      Oecetis
Basommatophora
   Physidae	
Common Name

Water mite
Beetle
Riffle beetle
Fly
   Midge fly
   Snipe fly

   Black fly
Mayfly
Stonefly
Caddisfly
Pond snail
Density
Station
Y3
1.3
0.7
2.3
5.3
0
16.3
0
6.0
0
3.3
0
3.7
1.0
2.0
1.0
0.7
1.0
(no. /ft2)
Station
Y8
1.3
0
3.0
4.7
4.7
9.0
2.7
0
4.7
0
13.7
3.1
1.7
5.3
2.7
3.7
0
   1.0

   0


   0.3

   0
  10.7
   0

   6.7
   0.3

   0.3
   0.7
 0

 0.7


 0

 3.0
39.7
 1.0

 0.7
 1.3

 0
 0
present  not present
Total Density  (no./ft.2)
Wet Biomass  (g/m^)	
                          65.0
                           3.56
           106.7
             4.37
   Preliminary data supplied by the USGS, which is subject to further
   scrutiny and verification.
2  Equivalent to USGS stations Y64 and Y63.
                                                                     -88-

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699 per square meter.  Densities below 1000 organisms per square
meter were considered a poor benthic population  (Dr. R. Pennak,
Wright-McLaughlin Engineers, October 1975), so the Yartpa's bottom
insects near Steamboat Springs would be expected to support low popu-
lations of reproducing trout.  The downstream station  (Y8) was slightly
more productive and supported 106.7 organisms per square foot or 1148
per square meter.  This station was near the Elk River and could support
an average population of reproducing trout.

Many factors of water quality affect the abundance and diversity of
the benthic insects.  Nutrients like phosphates and nitrates can in-
crease their food supply and stimulate their growth.  Other factors,
like suspended solids, can clog their gills and smother their develop-
ing young.  This latter action is most likely in ecological area I,
just upstream from Steamboat Springs, where fine organic material and
clay are layered between the rocks on the bottom.

The most abundant fish in the study area is the native mountain white-
fish, followed by the introduced rainbow trout (Table IV-5).  The
whitefish is normally not considered a game fish although it has good
eating and sporting qualities.  Specimens weighing up to four pounds
and measuring 28 inches in length have been reported.  The rainbow
trout are planted by the Colorado Division of Wildlife and normally
attain lengths of eight to 14 inches.  A naturally-reproducing popu-
lation of rainbow trout also exists and competes for food with the
transplants.  Other trout of the study area include brown and brook
trout.  Brook trout usually occur at the higher elevations and browns
at the lower.  Brown trout are the hardier of the two and grow to
large sizes.

As mentioned previously, the reproducing trout in the Yampa River are
faring poorly in the study.area.  The depth of the river's pools is too
shallow for good trout habitat, especially between the south boundary
of the study area and the northwest boundary of Steamboat Springs.
Also, a lack of vegetative cover diminishes the quality of their habitat
throughout most of the study area.  Their potential food supply from
the benthos is rated poor near Steamboat Springs and average near the
Elk River.  The heavy siltation south of Steamboat Springs also could
be reducing the quality of their breeding habitat  (Ron Eddy, EPA,
comment on Draft EIS).

Other fish faring poorly in the Yampa River include the Colorado squaw-
fish, bonytail chub, humpback chub and the humpback  (razorback) sucker.
In Colorado, these species are found only in drainages of the Colorado,
Gunnison, Yampa and White Rivers.  A recent survey by the Colorado
Division of Wildlife showed a few Colorado squawfish in the lower
Yampa, just above Maybell, Colorado.  None of the others appeared in
                             -89-

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                               TABLE  IV-5
               POPULATION  STATUS  OF FISH OF THE YAMPA RIVER"1
Scientific Name

Salmo giardneri

Salmo trutta

Salmo clarki pleuriticus


Salvelinus fontinalis

Prosopium williansoni

Rhinichthus osculus

Castostomus catostomus

Castostoraus commersoni

Castostomus latipinnis

Castostomus discobolus

Semotilus atromaculatus

Pimephales promelas

Richardsonius balteatus

Cottus bairdi

Xyrauchen texanus

Gilia cypha

Gilia elegans

Ptychocheilus lucius
Common Name         	

Rainbow trout         x

Brown trout
               •
Colo. River
cutthroat trout

Brook trout

Mountain whitefish    x

Speckled dace

Western longnose sucker

White sucker

Flannelmouth sucker

Bluehead sucker

Northern creek chub

Fathead minnow

Redside shiner

Mottled sculpin

Humpback sucker

Humpback chub2'4

Bonytail chub4

Colorado River2'4
squawfish
    Population Status
Abund.   Com.    Low   Scarce
          x
          X
          X
          X
                  X
                         X
                         X
                         X
                         X
                                                                           X
1  Taken from Wright-McLaughlin Engineers, Oct. 1975, information based on
 studies and observations by Colorado Div. of Wildlife, plus input from
 other sources.
2  Endangered species, U.S. Dept0 of Interior.
3  Threatened species, Colorado Division of Wildlife.
4  Endangered species, Colorado Division of Wildlife.
                                   -90-

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the Yampa River study areas although Colorado wildlife officers suspect
some bonytail chubs may live below Craig, Colorado.  Several reasons
for the decline in these endangered species include stream channeliza-
tion, bank erosion, and the elimination of backwater swamps  (Dr. Robert
Pennak, for Wright-McLaughlin Engineers, Oct. 1975) .  Other factors
include competition from introduced species like redside shiner  and
channel catfish (Dave Langlois, Colorado Division of Wildlife, personal
communication).

Threatened or Endangered Species

Several animals in Colorado have been designated as threatened or en-
dangered by the U.S. Fish and Wildlife Service and Colorado Division
of Wildlife.  All animals designated as such by the U.S. government are
classified similarly by the Colorado government, although local con-
ditions may vary and are recognized as being different.  The Colorado
government has also placed several species on their threatened-and-
endangered list that are not included on the national list.  Consequently,
the Colorado  list is more extensive than the national list and it more
accurately reflects local conditions.

When the Colorado list is compared to species in the project area, it
is found that only one occurs there regularly.  This animal is the
greater sandhill crane, which has nests throughout the willow stands
along  the Yampa River.

                            Air Quality

     In this  section the importance of study area climatology is
discussed, followed by a review of air quality.  The odor potential
of wastewater facilities is then discussed and related to interviews
with local citizens.

Climatology

Steamboat Springs has a climate referred to as Highland Continental,
characterized by low precipitation, large fluctuations in daily temp-
eratures, low humidity, moderate amounts of wind and abundant sunshine.
Summer days are warm but seldom hot; summer nights are cool.  Winter
nights are quite cold, particularly along the Valley bottom; however,
the days are  more comfortable because of low humidity and usual bright
sunshine.  The prevailing wind direction into the area is from the west.
These  winds arrive comparatively dry after their long travel over land
and  their moisture loss in passing over mountains.  Relatively open
areas  to the  north and northwest permit easy access for many storms
from the north, compared to the more protected areas of western Colorado.
                            -91-

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It is common in the winter to board the gondola at Mt. Werner in
the morning with the temperatures around 10°F and arrive at the top
in 25°F conditions.  This is characteristic of temperature inver-
sions that hold cold air near the ground with warm air aloft.  These
conditions are quite prevalent and intense in the Study Area.
Figure 6 summarizes some inversion measurements taken near Hayden,
25 miles to the west.  This data was recorded as part of the environ-
mental assessment for that area's coal-fired power plant.

The average annual precipitation is about 30 inches along the moun-
tains, just east of the Study Area, and 20 inches in Steamboat
Springs.  The City experiences  unusually large annual rainfall
for its elevation, attributable to the sharp rise in elevation di-
rectly to the east.  Annual snowfall averages 165 inches and pro-
vides light powder conditions on numerous winter days.  Heavy ac-
cumulations often make Mt. Werner a "powderhound1s" delight follow-
ing its periodic storms.  Monthly variation in precipitation is
shown in Figure 1, taken from 30 years of recorded data.  Also
shown is variation in monthly temperature averages.  Wright-
McLaughlin's "Volume One" compares these averages to daily maximums,
which demonstrate that a large variation in daily temperatures
affects the length of the growing season.

Land areas above 9000 feet have, on the average, have an annual growing
season of about 50 days, with south-facing slopes considered poss-
ible exceptions  (Gathers, 1973).  The growing season is considered
to increase by approximately two weeks for every 1000 feet in
elevation below 9000 feet  (Table IV-6).
                             TABLE  IV-6

                        AREA GROWING SEASON

                                         Growing  Season
             Elevation                        (days)

               9000                             50

               8000                             65

               7000                          80-90

               6000                            100

     Steamboat
     Springs          6700

     Proposed land                     —Source:   Gather,  1973
     treatment  area   6600
                               •92 •

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             Frequency

               50.5%
               15.1
               31.8
                2.6
  Stability

Class i f ication

Stable  (E,F)
Transition (B-C)
Neutral (D)
Unstable  (A)
Prevailing Wind Direction

         E, ESE
           E
           W
           W
                   Mixing Depth (Inversion Height)
Average  1600 feet
Range    100-3800 feet
    8
 \_
 0)
 
 c
 OJ
 §-  3
 0)
        100 300 600 900     1500    2100    2700    3300     3900
                         Mixing Depth--Feet


                   Hayden Meteorological Data

                           Figure  6
     Source:  Environmental Assessment, Yampa Valley  Airport,
              Isbill Associates and Weiner & Associates,  1974.
                                      -93-

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Severe frost at these higher elevations occurs between the end of
August and the first week of June.  As a result, little farming oc-
curs above the 9000 foot level.

Review of the wind data indicates that during the morning, calm
conditions prevail 65.6 percent of the time.  Morning winds occur
15 percent from the northwest - southwest quadrants, with the re-
maining distributed among other quadrants.  Afternoon conditions
provide 43.2 percent calms and 35 percent westerlies.  Windspeeds
average 6 mph over the year although periodic high wind days have
occurred, requiring the closing of ski lifts.

The significance of climatological statistics is that consideration
must be given to growing season length, temperatures, humidity, rain-
fall, length of day and cloud cover, among other factors in designing
a land treatment program.  The most important fact remains that the
candidate areas are presently irrigated so that problems in using
effluent are limited to application rates, coverage areas and
associated hydraulic loading.  These factors constitute the prin-
cipal engineering constraints for a land treatment system as dis-
cussed in the alternative analysis of this EIS.

Air Quality: In the following discussion the knowledge of ambient
air quality in the study area is reviewed as is the applicability
of State and Federal programs.  The Bureau of Land Management has
prepared and circulated a "Draft Environmental Impact Statement
for Coal Development in Northwest Colorado—Air Quality
Section."  Major topics of this draft include agency goals
and model studies and is the only study available which considers
the Steamboat Springs area.

The Yampa Valley lies within the Yampa Air Quality Control Region,
currently priority 3 for the major pollutants of national concern.
Such designation is meant to indicate that no Federal Primary or
Secondary Air Quality Standards are being violated anywhere in the
Region.  However, it should be pointed out that this designation
was arrived at on the basis of limited aerometric data.   High-
Volume  (Hi-vol) suspended particulate and sulfasion plate data are
the only regulatory agency measurements that have been taken in
Routt County.  Both of these measurements are limited in accuracy
with sulfation plates providing only an indication of the presence
of airborne sulfur compounds.

Figure 8 displays recorded levels of total suspended particulate
(TSP) for the Steamboat Springs station.  These measurements indi-
cate almost continuous violation of State and National TSP ambient
standards, which contradicts the above priority designation.  There
is no apparent seasonal trend, nor are there large industrial

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sources nearby that would explain these high  levels.  The  concentra-
tions recorded are characterized as among the  "dirtiest" in  the
State by Colorado Health Department personnel.  Although State
officials express concern, this is considered  a lower priority
and therefore no agency action has been taken  to identify  or sub-
sequently abate the source(s).
                  Fireplace Smoke at Ski Area Village
 Pursuant to a court interpretation of Clean Air Act (1970 as amend-
 ed) ,  EPA and the State are currently preparing "Air Quality Main-
 tenance Plans" for areas thought to be potential future violators
 of ambient standards.   The impetus is to prevent deterioration of
 air quality in "clean" areas and to preserve maintenance of stand-
 ards in other areas, where violations occur but compliance is ex-
 pected.  An anomaly exists in the case of Steamboat Springs where
 one of the highest ambient concentrations persists, while the area
 is not being considered for Maintenance Planning nor has its TSP
 priority classification been reconsidered.  In the absence of point
 sources (industry, etc.) the cause of this obvious problem is like-
 ly a combination of road and field dust, becoming airborne by
 spring, and summer wind gusts and traffic.  During the fall and
 winter, fireplaces and road sand are likely responsible.  To ac-
 curately determine the source(s), TSP sampling in the area must be-
 come more sophisticated.  In addition to knowing the mass-density
 (ug/m  ), the particle size and chemical composition must also be
 determined in order to develop any practical control program.  This
 would be particularly valuable in assessing the air quality in-
 fluence of the planned U. S. 40 bypass.
                            97

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Adding even more importance to this need is the State ambient stand-
ards, which have been redrafted to address "significant deteriora-
tion."  This seemingly complex topic is related to Maintenance Plan-
ning and attempts to define how much the air quality in pristine
areas can be degraded by growth and development.  The significance
of all the preceding discussion is that agency planning and
regulations are becoming more and more complex but until the true
nature of the source-effect relationship is known for TSPf little
success can be realistically anticipated from these endeavors.

In the absence of measured pollutant concentrations, researchers
use mathematical simulation techniques„  These techniques, referred
to as diffusion models, combine emission estimates with historical
meteorological data to predict ambient conditions.  The principal
air quality studies that have been done in the area include the
environmental assessments and impact statements for power plant
development near Hayden and Craig;  expansion of Yampa Valley Air-
port  (Hayden); and the rough draft EIS for coal development in north-
west Colorado, prepared by the BLM and USGS.  Both the power plant and
airport studies dealt with their project areas and do not apply to this
201 Study Area.

The BLM and USGS effort thus far has produced a 2600-page study of
northwestern Colorado.  The air quality portion was required to look
at all possible emission sources and to determine the coal-related
growth impacts on air quality as well.  The BLM consultant used a
diffusion model for the Steamboat Springs area which is not con-
sidered valid.  The model used (Gaussian multi-point and line sources)
is not applicable for mountain valleys due to the effects of the
terrain.  Even though the validity of the predicted concentrations
seems questionable, the following conclusion seems justified:

      "Air quality during the proposed development would be degraded
      in terms of all presently regulated pollutants:  suspended
      particulates, sulfur dioxide, carbon monoxide, nitrogen
      oxides, reactive hydrocarbons and total oxidant.  Although
      emissions controls are proposed at the power plants and mines
      and vehicular emissions are regulated, adverse environmental
      effects could not be avoided."

This preliminary Statement goes on to conclude that Federal TSP
standards will be exceeded in Steamboat Springs as already is the
case.  It also states, "power plant emission of fine particulates
and conversion of sulfur and nitrogen oxides to aerosols would
cause a visibility reduction that cannot be mitigated."  Elsewhere
in the report, BLM states that the visibility range in the region
is 90-100 km, while Steamboat Springs has an average visibility
limited to 10-20 km.
   Some field monitoring of SO- has been done to calibrate the
   diffusion model used.
                               -98-

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As the temporary and permanent population grows, more road sand dust
and fireplace smoke will be emitted to the air  in the Study Area.  When
this is considered in conjunction with power plant aerosols, predomi-
nant westerly winds, intense winter inversions, reduced visibility
in the area, and the continued violation of TSP standards, serious
concern must be raised for the study area's air quality.

The TSP sampler is now located on the County Court House along
Lincoln Avenue, U.S. 40 through the City.  The high levels are
obviously influenced by the heavy traffic volumes on Lincoln Avenue
which help the excessive street dirt and sand to become airborne.  An
adequate urban runoff control program would not only benefit the Yampa
but also likely improve TSP ambient conditions  through routine street
cleaning.

Odor

Wastewater treatment facilities affect air quality primarily in the
area of ambient odor and its impact on nearby citizens.  When treat-
ment works are proposed in new locations, odor potential often
stimulates local emotions and public interest surges.  The small
sewage plants at Steamboat II, Bear Pole Ranch, Sleepy Bear and KOA
experience problems characteristic of plants of their size, not the
least of which is odor.  No odor complaints have been recorded for the
Mt. Werner plant which is located well away from nearby residences.

The Steamboat Springs Sewage plant is located immediately adjacent to
residences and businesses to the west and north.  During the last
week of February, the closest residents to this plant were interviewed.
The families interviewed have lived in the nearby mobile home park
from one to four years.  No one contacted objected to the presence of
the existing plant or a new plant.  In fact, two residents were not
even aware of the existing facilities location.  Occasionally, 86 percent
of the respondents detected an odor which they  attributed to the plant;
however, no one felt it was objectionable enough to merit a complaint;.

Because this system is similar to Mt. Werner, it is dependent on blowers
to keep the system aerobic.  One resident stated that a power outage
had created an objectionable odor.  That same person's main concern was
over the visibility of a new .'plant if located at the existing site.  It
is feared that a new building would block a direct view of Mt. Werner,
which is the principal aesthetic amenity to these residents.  Thus,
building height and visibility are principal concerns of nearby resi-
dents, followed by a general desire to be assured that a new plant,
handling more and more flow, will be no more objectionable than the
present facility.
                            -99-

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                    History and Archaeology

In 1875, James Crawford was so anxious to secure the claim he had staked
in the lush Yampa Valley that he started out before the snow melted and
skied to the site of Steamboat Springs.  By the end of that summer his
family was one of five that had cabins in the area and Crawford had
become the father of the town.

The pioneers were preceded by trappers and prospectors.  The trappers
thought the springs sounded like a paddle wheel steamboat, so the story
goes, and are responsible for the present name.  The Ute Indians called
the area Medicine Springs and had for several centuries used it as a
pleasant, cool summer hunting grounds.

After a small uprising in 1879 the Utes in northwestern Colorado were
removed south to the Ute Reservations and white families felt safer
about coming to Steamboat to settle.  Mail service had been instituted
in 1878; in 1883 a school and a sawmill, which made planked buildings
possible, were founded.

In 1884, Crawford and some other investors formed a company to promote
the town and sell lots.  Later in Steamboat's history other entrepre-
neurs turned to real estate, particularly after 1890 as small family
ranches became the mode.

The town grew steadily until by 1900, the year it incorporated, it had
a population of around 900.  The collapse of the gold mining boom at
Hahn's Peak, 20 miles to the north, created, as elsewhere in Colorado,
a lot of new farmers and ranchers.  And the extension of the Denver and
Rio Grande railroad to Wolcott, 80 miles to the south and a day and a
half by stagecoach, brought the town within ordinary reach of previously
extravagant amenities.

By 1902 Steamboat Springs had a lively commercial life with dozens of
stores, a public library, electricity and telephone service.  A water
and sewage system did not come until 1904.

The long-awaited coming of the railroad to Steamboat itself happened in
1908.  It was mainly a boon to the cattle industry and for a short time
more cattle were shipped from Steamboat Springs than any other single
point in the country.

People expected the railroad to be the missing link in a number of other
industries:  mining of coal, oil and other minerals, timber and tourists.
But mining never developed as extensively as predicted, logs either raced
too fast down the Yampa or jammed at low water, and despite the construc-
tion of a 100-room hotel and huge swimming pools, the town never
developed into a spa.
                               -100-

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 Strawberries did,  however,  boom for several years around that time.
 Because a single farmer converted six acres into a profit of $3000 one
 year,  the entire valley of Strawberry Park was planted with strawberries.
 The berries, grown at high altitudes, came to market later than other
 commercial crops and some went as far as Chicago.  But three years of
 early frosts ruined land speculators and farmers, and the idea died.

 Meanwhile, an everyday winter activity had taken a new, festive turn
 which was to mature a half century later into another boom.  Homemade
 skis, furbottomed to prevent backsliding, were a necessity in early
 Steamboat  for people like mail carriers, ranchers and pallbearers.
 Then, in 1914, a Norwegian named Howelson set up a hill on his property
 as a ski jump and convinced his neighbors that what they had was fun.
 The first ski carnival was held later that year and consisted of a
 jumping event and a cross country race.
Steamboat Springs continued down through the years as a mildly pros-
perous town of steady balues and relatively little change.  For
nearly 50 years the town's population hovered between 1,000 to 2,000.
Its location on Highway 40 near Rabbit Ears Pass brought it some
tourism, and the Olympic skills of Buddy Werner some fame, but for
the most part it remained isolated in its corner of the state.  Then
came the development of Mt. Werner and all was to change.

Archaeology

According to the state archaeologists there are two archaeological
sites within the study area.  Both are located southwest of Mt. Werner
and south of the Mt. Werner sewage lagoon in the neighborhood of the
Yampa River and U.S. 40.  Neither archaeological site is close to
any of the areas under consideration as a site for sewer facilities.
However, EPA realizes that existing archaeological information is
insufficient and is in the process of updating it with a field
study of proposed project sites..  Copies  of this report will be
available upon request by September 15,  1977.

                             Population

 Steamboat Springs has undergone incredible growth and change within a
 short time.  Once a quiet, rural town where ranching, lumbering and
 some mining and tourism were the chief endeavors, it is now the home of
 one of the nation's best known ski resorts.

 The resulting influx of people has brought enormous problems.  Living
 costs have skyrocketed; roads are overcrowded; other public utilities
 are strained to the limit; and agricultural traditions are threatened.
 These issues are discussed in succeeding chapters on land use and socio-
 economics, but in this section we shall deal with the root problem of
 population growth.
                                -101-

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  Like that of many resort communities, the population of Steamboat Springs
  is difficult to tally.    A steady stream of tourists,  skiers and part-
  time residents complicates any population count.   There are  of course
  full-time residents who live and work  in the area year-round,  but. even
  a calculation of their numbers is confused by the rapid growth which
  occurred between 1970 and 1973.  The U.S. Census  figures,  taken in 1970,
  were outdated not long after their release.  Other traditional govern-
  ment sources are of little or no use.   The Northwest (Colorado)  Council
  of Governments lacks population data of its own for either Routt County
  or Steamboat Springs.  The State Planning Office  which has estimates of
  present and future population for the  county does not  separate figures
  for Steamboat Springs,  nor does the federal Office of  Business and
  Economic Research.


 Fortunately, several studies containing population data were completed
 by private consultants at the request of local government;  and one
 federal agency, the Bureau of Land Management, developed population data
 as part of an environmental impact statement for coal leases.  However,
 each of these studies is based on work  completed by Charles Gathers and
 Associates as part of the Comprehensive Plan commissioned by the County.
 It is for this reason that our analysis will focus on Gathers'  estimates
 for the Steamboat Springs area, and will discuss other  surveys only as
 they relate to these estimates.

 The Gathers Report:  In order to obtain estimates of existing population,
 Gathers analyzed the two main economic  bases of the Steamboat popula-
 tion:  the sector of the economy which  serves the agricultural community
 and that related to the skiing industry.1  An estimate  of 1973 agriculture-
 related employment and population was derived from interviews, housing
 surveys, and an analysis of Census data, which applies  somewhat to
 ranching since this was not the sector  in which rapid growth occurred.
 An appraisal of 1973 ski  (or tourism) related population was also
 obtained from interviews and housing surveys, along with assumptions
 about labor participation rates and population density in skier-oriented
 economies.
Together, Gathers estimated the 1973 population of the Steamboat Springs
area to be as follows:

              Permanent                      4,917
              Temporary  (Lodging unit
                         capacity)           5,406
              Total Peak Day Population     10,323
1  Mining, which could affect population if new coal leases are granted,
   is discussed later in this chapter.
                                  -102-

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From these figures Gathers derived population projections through
1995.  The following methodology and assumptions were used:

      All increases in tourist-oriented population would derive  from
      an increase in daily lift capacity  (DLC) at Mt. Werner.  Gathers
      assumes that DLC would increase from 6,000 in 1973 to  12,000 by
      1979.

      After DLC increased, there would be a three-year lag time  in
      lodging capacity expansion to meet the needs of the increased
      numbers of temporary residents drawn to Steamboat as a result
      of increased skiing facilities.


    0 The existing relationship between lodging capacity and tourist-
      related employment was projected to remain the same, as was the
      labor participation rate  (ratio between employed persons and
      total population).

    0 Agriculture-related population would remain relatively static,
      but would tend to decrease as recreation-oriented population
      increases.  Labor participation rates and population density
      would remain static within this sector of the economy.

    0 A 10 percent increment was added to the figures for each economic
      sector as a "safety factor."  This increment was intended  to
      compensate for any other inducements to growth which could not
      be predicted at the time of the study, the most likely of  which
      is increased mining activity.

From the above, Gathers projected the 1995 population of the Steamboat
Springs area to be 23,600 on peak days, broken down into 9,900 permanent
residents and 13,700 transients.

Analysis of Method and Assumptions:  The method used by Gathers  is sound.
However, the assumptions were made when Steamboat was at the tail end of
a tremendous economic boom, and are -overly optimistic.

Using the wisdom of hindsight, we believe that the Gathers estimates of
present population are too high.  Interviews with people in the  Steam-
boat community indicate a sharp cutback in the area's growth over the
last two years.  Construction has fallen off due to overbuilding which
has  left a surplus of tourist-oriented housing.  In addition, a  lack of
jobs  (other than seasonal), a shortage of affordable resident housing,
and  a high cost of living persist, all of which have deterred new addi-
tions to the permanent population.  For this reason we have  concluded
that the Gathers estimate of 1973 permanent population more  appropriately
applies to 1975.

We also feel that Gathers overestimated both the future rate of  growth
and the ultimate population of the Steamboat area by 1995.  we have
                                 -103-

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therefore developed alternative projections based on Gathers' model,
but with different assumptions relating to DLC, government approval to
expand DLC, lag time between DLC expansion and housing construction,
the national economy, the definition of peak population, and the
influence of coal development.

Daily Lift Capacity  (DLC):  The capability of a ski area to transport
skiers up the mountain and distribute them among the slopes is a critical
parameter in Gathers' methodology.  It is also a fundamental factor in
ski area planning and management. .  For this reason many equations have
been derived by the Forest Service and others to consider the physical
characteristics of the mountain as well as the facilities placement.
These equations and specific interviews suggest present DLC at the
Steamboat Ski Area ranging from 6,000 to 7,850 skiers.  The best
estimate in our opinion and that of area personnel is 6,600 skiers for
the existing facilities  (Barrows, 1976).

We believe that the DLC will expand to 8,000 by 1984, to 10,000 by 1991
and to 11,000  (maximum)by 1995, compared with Gathers projection that it
will be 12,000 by 1979.  Representatives of LTV have indicated that
their most optimistic plans would include a minimal expansion of DLC by
5,000 by 1982 or 1983 at a new base site.  One point of uncertainty is
that LTV might sell its interest in the ski area.  Should this occur,
it is not possible to predict its exact effect on plans for possible ski
area expansion.  For this reason we have taken the physical potential of
surrounding terrain, management statements, local and regional Forest
Service projections and County planning staff opinions into account in
arriving at a maximum of 11,000 skiers.

Government Approval;  Any expansion of the dimensions discussed above,
whether by LTV or new ownership, would require the approval of several
agencies, including the U.S. Forest Service, the Routt County Regional
Planning Commission, and the Routt County Board of Commissioners.
Expansion could ultimately be accomplished; however, there would be
several obstacles and time delays.  Representatives of the Forest
Service have recently initiated work on an area-wide Environmental
Impact Statement for their Program Unit Plan for the Routt National
Forest.  It will take approximately five years to complete this study,
and Forest Service personnel have stated that until this process is
completed, no new ski area expansion will be approved.  It is also
possible that a separate EIS will be required for individual ski area
expansions, depending on the nature of the proposed development.  It is
for these reasons that we have used the later lift capacity expansion
dates.

More importantly, the County Commissioners are faced with the substantial
burden of meeting the needs of an expanding population.  They advocate
that growth rates be slowed to allow the County and the City to "catch
up" with the needs of their constituents.  They are certain to take a
                                 -104-

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hard look at proposed ski development expansion in order that they might
be better able to successfully accomodate its impact on the County.
While it is likely that such development will ultimately be approved,
it is our opinion that the County Commission's scrutiny of any proposal
will tend to prolong the time needed to obtain final approval for lift
expansions.

Housing Development:  We have also assumed that there will be a  lag time
of five years between expansion of DLC and construction of increased
lodging.  This assumption was made for two reasons.  First, there has
already been substantial overbuilding of temporary lodging.  Even at
peak periods  (the 30 best days of the ski season), temporary lodging is
only 60% of capacity.  We feel that until this ratio approaches  75% or
more, there will not be extensive new tourist housing construction.
Second, there has been a considerable slowdown in the construction
industry throughout the country.   Money markets are tighter and  finan-
cing is more difficult.  Should there be extensive energy development in
or near Routt County, housing construction will turn towards the needs
of energy workers and will stretch the lag time for ski-oriented
construction beyond the three years projected by Gathers.

The National Economy;  There are some industries which seem almost
immune to fluctuations in the national economy.  Tourism,  particularly
skiing, has recently seemed to be a good example of just such a phenome-
non.  In the past few years, as the nation has been experiencing a
relatively serious recession, overall numbers of visitors  to ski areas
have continued to increase.   Although skiing has increased in the midst
of a recession, it would be oversimplistic to assume that  ski areas
are unaffected by a downturn in the economy.

While tourism is apparently unaffected,  construction of ski area facil-
ities and second home development have become particularly susceptible
to national economic trends.  In a time when national money markets are
tight, speculators and developers are much more cautious about such
capital intensive investments.  While families may continue to indulge
in an annual ski vacation, they will be much more likely to rent a
condominium than to consider the purchase of a permanent second home.

Even with eventual national economic recovery, the ramifications of
overbuilding will continue to be a concern.  The almost tragic over-
development which now threatens neighboring Summit County  (The Denver
Post, 2/15/76, p. IE) and the now defunct Stagecoach and Steamboat Lake
developments in Routt County, graphically present a warning which will
undoubtedly be heeded by developers in the future.  Money markets will
likely assume a similar conservative posture toward these  speculative
ventures.  The effect will probably be a return to classical economic
attitudes where supply will follow well documented demand as opposed to
speculation that supply itself stimulates demand, hence growth.
                                  -105-

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All of these factors contribute to the anticipation of a slower rate of
ski area development and housing construction than has been projected by
Gathers as shown in Figure  9.

Peak Population:  We have made one further modification of the Gathers
data which we feel more clearly represents the actual situation in
Steamboat.  "Peak-season population" refers to the total permanent
population plus an average of the 30 busiest tourist days of the ski
season  (as opposed to December 28, when every pillow in the study area
probably has a head on it).  This 30-day average presently corresponds
to 60 percent of the total tourist accomodations, and as such, is a more
representative and realistic accounting of the seasonal population.  A
peak day projection is also  shown which correlates with sewage flow data
and is thus being used by Wright-McLaughlin for design purposes.

The Influence of Coal Development:  It is fairly evident now that there
will be some increase in local Steamboat Springs population resulting
from the development of extensive coal deposits in Routt and Moffat
Counties.  This fact was less evident when Gathers was doing the research
for the Comprehensive Study  in 1973.  However, this 10 percent "safety
figure" did take into account the expected, but then undefined, stimuli
to growth in the area.  These stimuli, independent of tourism and
ranching activities, could include construction of Bureau of Reclamation
dams and the expansion of the Hayden power plant, or they could include
the increase in population resulting from increased coal development..

Our second permanent population curve includes growth anticipated as a
result of coal development in the Routt-Moffat County area.  This added
population was derived by subtracting Gathers' 10 percent "safety
figure," then adding population estimates for the Steamboat area which
were developed by the Bureau of Land Management in its draft EIS for
coal development in the area.

While we feel that the total population resulting from coal development
is accurately calculated by BLM, again we feel the schedule of develop-
ment is over-optimistic.  We have therefore calculated into the early
development BLM figures a five-year lag time.  This takes into acount
the time necessary to litigate  (environmentally-related) lawsuits, which
may be filed as a result of potential coal leasing.  As the population
curves indicate, with coal development, growth in permanent population
will be accelerated between 1980 and 1990, but will decrease substan-
tially after 1990.
Staff members of BLM stated in the fall of 1975 that there would be an
almost direct tradeoff between coal and recreation development.  Although
BLM is currently less certain about this statement, we feel that should
                                 -106-

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                GATHERS PFAK DAY
                                                 PEAK SEASON POPULATION'
                                                 STEAMBOAT SPRINGS
                                                 201 STUDY AREA
                                                                    PEAK DAY POPULATION
                                                       PERMANENT POPULATION
                                                       — WITH COAL DEVELOPMENT
                                                       — WITHOUT COAL
                                                             •PEAK SEASON POPULATION • PERMANANENT RESIDENTS
                                                              PLUS AVERAGE OF 30 BUSIEST TOUR6T DAYS

                                                            @ AVERAGE ANNUAL GROWTH RATE
 1970      1975
                   1980      1985      199O      1995      2000      20O5
STEAMBOAT SPRINGS REGIONAL SERVICE AUTHORITY
201 STUDY AREA POPULATION PROJECTION
                                107
Figure 9
                                                                          U.S GOVERNMENT PRINTING OFFICE W76-W8 l

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there be an increase in permanent residents in Steamboat as a result of
coal development, there will be a corresponding decrease in the number
of temporary residents.  As a result, the peak population will remain
virtually the same, with or without coal development.  This is because
factors which contribute to population growth are seldom additive.  An
increase in energy-related population will be reflected in many sectors
of the economy.  The housing market will shift from the construction of
condominiums at the base of the ski area to mobile or modular home
development elsewhere in the county; retail services will provide more
hardware, less ski equipment; restaurants will attempt to project more
of a "family" image than they would otherwise; the planned nightclub
would be replaced by a bowling alley.  As Steamboat shifted to accom-
modate permanent energy-related population, it would expend less energy
attracting the temporary, ski-oriented population and would, as a
result, be less attractive to that segment of the population.
The overall effect would be to decrease the number of temporary residents
in the Steamboat area—a number closely related to the number of perma-
nent energy-related residents.  It is for this reason that temporary
and, permanent population show fluctuations as a result of energy
development, while overall peak population does not.
                                -108-

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                             Land Use

Most land in Routt County and greater Steamboat Springs is  agricultural.
Figures from Gathers and Associates show that 73.2 percent  of the
county's square mileage is used for agriculture:  62.8 percent  is range
land, 6.7 percent is non-irrigated farmland, and  3.8 percent is irri-
gated farmland.  Within the greater Steamboat Springs area, defined by
Gathers as a border about five miles beyond the city, 29.2  percent of
the property is agricultural, the largest percentage among  all  cate-
gories of use  (Study Map 2).

Agriculture in Routt County and greater Steamboat chiefly involves the
production of livestock, wheat, and other related activities.   County
farm receipts in 1975 came to $22,800,000, according to a report in The
Steamboat Pilot, compared with $21,362,000 for the previous year.  This
was a six percent rise, as against a five percent increase  for  the state
as a whole.

After agriculture, land use between the county and Steamboat Springs
differs somewhat.  For the county, commercial woodland occupies  20.9
percent of the square mileage, recreation areas 3.2 percent and subdi-
vided land  (outside of urban areas), highways, railways, airports, strip
mines, water bodies and urban areas less than one percent each  (Gathers
and Associates, 1973).

In greater Steamboat Springs, public and semipublic lands,  primarily the
ski slopes on Mt. Werner, comprise 29.1 percent of the total acreage;
vacant land, 23.3 percent; transportation, 8.6 percent; residences, 7.7
percent; and commerce and industry, 2.0 percent.  The big percentages
in Steamboat for skiing, transportation and homes reflect the town's
dependence on  recreation, which now dominates the local economy.

This was not always the case as mining, lumbering and ranching  were the
region's traditional endeavors.   Some tourism existed, but  due  to the
rugged terrain and the town's distance from any densely-populated area
this was not a major source of income.  Recreation, especially  skiing,
was a popular  pastime, but did not provide much  employment.  A small
ski run and jump on Howelson Hill, and a weekend  area, built and owned
by local residents on Mt. Werner, were all Steamboat had to offer until
1969.  In that year, LTV Recreation Development Inc. purchased  the Mt.
Werner area and set off the expansion that would  dramatically alter the
locale's environment, economy and land use.

Other land developers followed LTV.  Steamboat Lake, Stagecoach, Steam-
boat II, Tree  Haus and Riverside  were set up within a few years, shifting
the economic base to real estate  and recreational development.   In each
of the years between 1970 and 1973 land values skyrocketed  as 593
dwelling units were constructed,  61 percent of them in the  Steamboat
Springs area.
                                 -109-

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City of Steamboat Springs
      Ski  Area  Village
           -110-

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The selection of Steamboat Springs as a site for the 1976 Olympics
inflamed the situation.  As one report noted:  "The overall mood of
the county is one of great boom and anticipation"  (HWH Associates, 1972)

The downturn in the national economy, the rejection of the Olympics by
Colorado voters, and the bankruptcies at Steamboat Lake and Stagecoach
put an end to the boom.  For the last couple of years land sales have
been in the doldrums.  Still, as noted previously, no one doubts that
significant growth will occur over the next 30 years, though at a
decidedly slower pace.  There will probably never be another period of
growth like the years 1970-73, but the pressure to develop, to turn
ranchland into commercial real estate will continue.  An article in the
November 13, 1975 Steamboat Pilot  ("The Prospector," p. 6) noted that
"recreational and land sales throughout the nation are beginning to
pick up."  It is only a matter of time before Colorado sales follow the
national trend, despite the memories of Steamboat Lake and Stagecoach.
LTV's advertising, the national attention gained by association with the
Olympics, combined with the area's natural beauty, climate and other
amenities, will keep Steamboat Springs' reputation as an attractive
place in which to vacation or live.

A typical result of all the foregoing activity has been the institution
of zoning regulations, for until 1972 neither Routt County nor Steamboat
Springs had zoning.  But urban development created an awareness that
what an individual does with his property can affect neighbors and
people who live miles away.  The citizens of Routt County have been
especially affected by financial setbacks at Steamboat Lake and Stage-
coach.  Certain other projects, especially road improvements, are
something the area needs urgently but have been cut back due to the
loss of expected revenues.  Dr. J.A. Utterback, County Commission
Chairman, notes, in the November 13, 1975 Steamboat Pilot  (p. 1) that:
"If the tax dollars we project don't come in, then we have to curtail
a certain amount of the services we anticipated providing."

Because of growth-related problems, planning mechanisms in the county
and Steamboat Springs were developed quickly.  With help from Charles
Gathers and Associates, the area soon had:

    0 established county zoning regulations;

    0 set up a management system to administer county planning
      activities;

    0 revised county subdivision regulations;

    0 established or revised zoning and subdivision regulations for
      Steamboat Springs;

    0 initiated drafting of a comprehensive plan for the county and
      its communities;
                                 -111-

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    0 planning commissions established for incorporated towns including
      Steamboat Springs;

Developers in Routt County no longer can act without lengthy consulta-
tion from public officials and the citizen-at-large.  For example,
county subdivision regulations require the completion of four steps
before final approval can be given.  First, an information presentation
must be made to the Routt County Regional Planning Commission.  This is
followed by the Sketch Plan, consisting of basic design, maps of the
area, reports concerning water and sewer systems, and additional
information 'deemed necessary by the commission.  If Sketch Plan approval
is received, data for the Preliminary Plan is then required.  This is
the most costly and time consuming step, for it is at this point that
specific design standards must be met.  Detailed information is required
with regard to geology and vegetation, slope analysis, roads and streets
and protective covenants.  It is also at this stage that state agencies
are notified.  If all goes well, the Final Plat, the last step in the
procedure, should be the simplest of all.  The Final Plat is the perma-
nent and accurate record of the exact size, shape and location of lots,
blocks, streets, easements and other parcels of land within the subdi-
vision.  During all stages, except the first, informal presentation,
adjacent landowners are notified that the proposed development will be
considered by the planning commission.

The existence of this public apparatus is by itself a discouragement to
some growth.  The death of the Olympics also relieved much of the pres-
sure to develop and the boom years left the area overbuilt and overzoned.
Already platted lands could easily hold projected population levels.
Land use trends in the foreseeable future should, therefore, follow the
pattern that has been laid out by planners.  The county should be able
to maintain its unofficial policy of contiguous development by allowing
new construction only on property adjoining previously developed land.
This, hopefully, will avoid some of the problems associated with satel-
lite developments such as Steamboat Lake and Stagecoach, which were
miles from the Steamboat  Springs urban area, and will help in preserv-
ing agricultural land.

New populations will probably fill in and connect the area between Mt.
Werner and the old town.  This is the logical growth pattern and is in
accordance with planning projections  (Study Map 2).  Whatever commercial
and industrial development occurs should be in West Steamboat and south-
east of town along Highway 40.  This development is the logical pattern
and in conformity with the land use plan.

However, some words of caution are in order.  A number of questions
remain about areas that have already been developed, but are a distance
away from other developed zones.  These areas include Steamboat II, Elk
River and Deer Mountain estates.  Most of the property between these
                              •-112-

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City Lagoons Border  Trainer  Court


     Steamboat II Development
             113

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areas and the Steamboat Springs/Mt. Werner core is open land, and is
zoned to remain that way.  While there is no pressure in the immediate
future to change that zoning, and while soil and related considerations
act somewhat as a deterrent, the natural tendency over the long run may
be to connect the clusters.  The question of whether Elk River and Deer
Mountain should be served by interceptor lines to the new sewage facil-
ities is directly related to this issue.

Much of what happens will depend on the political and economic climates,
neither of which can be predicted with certainty.  The county Comprehen-
sive Plan has not yet been formally adopted and even then is subject to
changes.  In addition, the unofficial contiguous development policy is
the result of State Health Department policy which in effect prevents
new point source discharges into the Yampa River because all wasteload
allocations are currently filled.  As a result, new developments must
hook into existing sewage facilities, which makes contiguous development
a necessity as well as a sound policy.
                          Socioeconomics
In Steamboat Springs, when you see someone wearing a cowboy hat, there
is a reasonable chance he is a cowboy.  The existence of ranching gives
the town an authentic western atmosphere, the upkeep of which is very
important.  It is the area's most unique quality, the characteristic
that separates it from the jet-set atmosphere of other resorts.
The local citizenry is aware of this.  A significant amount of talk is
about how to maintain the locale's traditions while reaping the benefits
of the ski boom.  In that sense, Steamboat Springs is not unique.  Other
resort towns have faced the same problem.  The difference is that Steam-
boat Springs is still in a position to succeed where others have already
failed.

Agriculture remains an important part of the local economy.  According to
1974 figures from the Colorado Division of Commerce and Development,
13.8 percent of the local labor force was employed in agriculture,
placing it third among eleven categories listed.  Only "retail trade"
with 19.7 percent and "services and miscellaneous" with 18.5 percent
were ahead of it.

Besides ranchers, the community is comprised of the following groups:

    ° Land developers, who have seen a boom economy go bust.  The area
      is now overbuilt with condominiums and development has slowed
      considerably.  Much of the downturn was caused by events well
      beyond the control of individuals.  The national economic condi-
      tions did not help; and few could have predicted that Colorado's
      voters would reject the Olympics, a circumstance that caused

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  special pain since the area was considered a site for cross-country
  and ski-jumping events.

0 The professional/mercantile establishment, including innkeepers,
  restaurateurs, lawyers, retailers and providers of various other
  services.  Despite the crimp in the condominium market, the
  tourists and skiers continue to come, allowing this group to
  thrive and prosper.  Skier days at Mt. Werner increased from
  244,619 in 1972-73 to 437,447 in 1974-75.  LTV, the corporation
  which owns the ski concession, anticipates a total in the neigh-
  borhood of 500,000 in 1975-76.  Gross retail sales for Steamboat
  Springs rose from $9,978,060 in 1965 to $22,651,097 by 1974.
  Well organized commercial groups like the Chamber-Resort Associa-
  tion and the Restaurant Association thrive in this city and exert
  an important influence on its government.

0 Transients, in their 20s and 30s, who come for the skiing and
  other amenities.  Often staying only a winter or two, they account
  for much of the Workforce at the ski area and in downtown sections.
  They are generally willing to accept low wages in return for a
  lifestyle that leaves plenty of time for recreation.  Many live
  communally, unable to afford the area's expensive housing.  How-
  ever, their lifestyle is a form of voluntary poverty since most
  possess skills to move elsewhere and find well-paid jobs.  Inter-
  views with local residents indicate that fewer transients are
  arriving now than two or three years ago.

0 The permanent workforce, which includes many former transients
  who liked the area and stayed.  Other members of this group are
  government employees, teachers and some miners and construction
  workers.  Competing for jobs  with transients, while struggling
  to raise a family against inflated living costs, many fail to
  make it and leave after a few years.  In fact, a majority of
  Steamboat Springs' residents  (58 percent) have lived there for
  three years or less, according to Colorado Division of Highways
  study.

o Tourists, on whom many of the townspeople depend for their live-
  lihood.  Steamboat Springs was recently rated very high in
  courtesy and friendliness by a 3M National Advertising travel
  study, and there is little doubt that the area offers a special
  charm, particularly to city visitors.  While gearing up the
  economy, the influx of tourists, especially ski vacationers, is
  also the reason for the high cost of land and housing, and for
  the pressure to convert agricultural property to commercial or
  residential use.  Christmas is the busiest time of the ski season
  often supporting 10,000 to 12,000 people.  This surge is partly
  due to the many students returning home with friends to spend the
  holidays.  Local residents have many guests during this time, and
  many locals move in with friends and rent their own homes to
  tourists.

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Senior Citizens:  Persons over 65 years old comprise an above-average
part of the population, 9.7 percent in Routt County compared to 8.5
percent for the rest of the state.  Among the programs for retired
people in Steamboat Springs are:

    0 Meals on Wheels, which expanded this past year, delivering an
      average of six meals per day compared to only one or two in
      previous years;

    0 The Retired Runabouts, a group of 25 to 30 regular members who
      themselves pay for most of their trips and expenses, though some
      funding comes through Routt County Senior  Services;

    ° The Kiwanis Club bus, which once a week drives senior citizens to
      the main business district.  Operated for two years at an annual
      expense to the Club of $1,200, the Kiwanians recently defrayed
      some of the costs with help from the rest of the community.

Most funding for projects comes from the Routt County Senior Services,
including programs for residents of Hayden and South Routt County as
well as Steamboat Springs.  Senior Services, with an operating budget
of $9,500 per year, recently held a fund raising drive to make up an
anticipated $1,000 deficit.  The fund raising was an alternative to
increasing the cost of home meals above $1 or charging for activities
that are now free.  Senior Services also has a Council on Aging to
review present services for the elderly and needs that must be met.

Paramount among those needs are transportation and housing.  Transpor-
tation is a special problem in a cold climate where snow and slippery
sidewalks can make even a short shopping trip dangerous.  Consequently,
Senior Services intend to increase bus service above what is presently
available.  Housing is an even more serious problem and it represents
a substantial financial burden to many.  If they own their own homes,
they face rising property taxes.  If not, rentals at reasonable rates
are hard to find.  Only one low-rent apartment building called Mountain
View Manor is available to senior citizens in Steamboat Springs.  It
was financed through local donations and the Farmers' Home Administra-
tion.  However, all units are filled in this building and some people
have been on the Manor's waiting list for close to a year.  A privately
run nursing home, called Alpine Meadows, has also been available for
about three years.  It currently has around 40 patients, with about
75 percent receiving welfare aid.

Housing;  Housing is not only a major problem for the elderly, but for
everyone else as well.  The ski boom on Mt. Werner and the resulting
push for development have sent land prices skyrocketing.  Interviews
with residents indicate that $25,000 is the absolute rock-bottom price
for a home, while something for under $30,000 is nearly impossible to
find.  These costs create a serious obstacle to people who wish to
remain in an area, where local median income is less than the state
average.  Some long-term residents frankly admitted that should they
                                -116-

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ever be forced out of their present homes, they could not afford new
housing in Steamboat Springs.

As a result, many of the young service workers live communally, some-
times packing more people into a house than zoning allows.   Others,
including professional workers, have turned to the several available
trailer parks as the only reasonable alternative.

Unfortunately, mobile homes, according to interviewees, are a dirty
word in Steamboat Springs.  Aesthetically, they are not very pleasing,
and they probably do not provide a solution for families with children
that would like to settle permanently.  As an interim solution, however,
some residents conceded they are an answer.

A developing trend to convert tourist to permanent housing will be
helpful.  The housing shortage in Steamboat Springs is for residents;
the condominium market, on the other hand is overbuilt.  This latter
dwelling has questionable suitability for full-time occupancy and the
cost may not be reasonable, either.  In sum, because of the economic
pressure of residents, transients and tourists seeking housing, it is
doubtful that there will ever be low-cost housing in Steamboat Springs
if left to the workings of the marketplace.  Only private donations or
government assistance appear able to alleviate the problem as they did
in the case of Mountain View Manor.

Not only is housing expensive, but much of it is in need of repair.  In
a 1974 survey prepared by the Routt County Regional Planning Commission,
over one-fourth of the respondents said their homes needed repair.

Employment:  To a certain extent, the housing shortage is a result of
the job shortage, or more accurately, the. lack of well-paid, career-
oriented  work.  According to 1974 data from the Colorado State Division
of Commerce and Development, a plurality of the area's labor force  (38
percent) is employed in retail trade or service related jobs that pay
less than  $100 per week.  The part-time nature of many service jobs
helps to account for the low salary level.  Still, it is a sellers's
market since the influx of educated, youthful transients provides a
cheap, reliable labor pool for employers.  This can make it difficult
for those who wish to establish roots in Steamboat Springs but must
compete for jobs with a continual flow of temporaries.  The need for
creating more jobs, particularly by attracting light industry, was
mentioned by several interviewees.

After retail trade and services, the largest employment sectors in the
area's economy are agriculture with 13.8 percent, contract construction
with 8.9 percent, and transportation and public utilities with 8.7
 1   In  such cases, the city council's policy has been to take  action
    only when  a written complaint is received.
                                -117-

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percent.  Other employment categories include education  (8.6 percent),
mining  (6.7 percent), government  (4.2 percent), manufacturing  (3.6
percent), finance/insurance/real estate  (2.8 percent) and wholesale
trade  (1.0 percent).  According to the State Division of Commerce and
Development, the best wages were for those in mining ($218 per week on
the average), federal government  ($204 per week), contract construction
 ($180) and transportation and public utilities  ($163).

Poverty, Public Services and Facilities;  Poverty problems exist in the
study area but like many ski resorts, those with low incomes are being
driven out.  Since counties cannot impose a residence requirement for
welfare payments people are free to move in and out of the area and
still qualify.  In 1970, U.S. Census data indicated that 12.9 percent of
families in Routt County were below the poverty level,  compared to
Colorado's 9.1 percent.  But with the boom years, incomes have risen,
and an article in The Steamboat Pilot (The Prospector,  October 30, 1975,
p. 8), noted that "most Routt County residents are earning more than
they did in other years. ..."  However, applications  for food stamps
have increased each winter, with the majority of new applicants coming
from young people in town for the ski season.

Public services and facilities appear to be satisfactory, though, as in
many fast-growing areas, there is difficulty keeping pace with popula-
tion increases.  A capital improvements program and a million-dollar
hospital expansion are underway.

The schools in the area were evaluated in a 1974 report by the University
of Denver Bureau of Educational Research.  It pointed out that:
"Because of the recent additions to all three schools within the
district, no immediate building construction appears necessary."  The
report did go on to note that:  "This financially optimistic situation
should not preclude the necessity for long-range planning and improve-
ment of existing facilities."
                          Transportation

As is the case in many rural towns, transportation issues and concerns
center on the major through highway, for Steamboat Springs, U.S. Highway
40.  In town, the highway is Lincoln Avenue, Steamboat's main street.
The transformation of the town, within the past few years, into a
summer/winter destination resort area has greatly increased traffic and
parking volumes.  The Colorado Highway Department estimated average 1973
daily traffic on U.S. 40 at 5,000 and projected 15,000 in 20 years.  In
winter, especially, traffic along the highway between the town and the
Mt. Werner ski area is congested.  Also, traffic on the road includes a
disproportionate number of heavy trucks.

The Highway Department is planning a major upgrading of U.S. 40, begin-
ning five miles west of Steamboat Springs and progressing ten miles in
an easterly direction to a point just beyond the juncture of U.S. 40
                                -118-

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with State Highway 131.  The improvements will include widening  the
highway to four lanes  between Steamboat and Mt. Werner  and  construct-
ing a central business district bypass via Yampa Avenue.

This construction can create sedimentation problems for  the  stream if
not closely supervised.  Once the construction is completed,  there
must be adequate facilities to handle urban runoff from  the  road to
the stream.

The highway improvement is expected to make for safer, faster and more
efficient traffic flow.  Despite the inconvenience associated with
construction, the road improvements appear to be favored by  the  town.
The Highway Department surveyed over 1,100 citizens in 1972  and  reported
a concern over traffic problems and approval of U.S. 40  improvements in
terms of safety and convenience.  From another vantage point,  a  3M
National Advertising study  (reported in The_Steamboat Pilot,  October 23,
1975) surveyed 500 tourists and reported bad road conditions as  the
number one complaint.

Due to strong local lobbying, a bicycle path is being included in the
highway expansion.  Presently the short bicycle trip between Mt. Werner
and Steamboat Springs on the main roadway is both frightening and
hazardous to bicyclists and motorists alike.

Construction of east, west and bypass segments of the highway is
expected to take ten years.  Land use along the highway  could become
more  commercial unless regulated by zoning.

In-town traffic itself has increased as Steamboat has grown.   Shopping
and lodging facilities at Mt. Werner make it in effect a  second town
center and contribute to the traffic increases between the mountain and
the town.  In downtown itself, the post office has always generated
traffic and parking problems as Steamboat residents do not have  delivery
service and must pick up their own mail.

A central business district "Parking Study," conducted by the town
Planning Commission staff and released in June 1974, related future
parking needs to town growth:  "... as Steamboat continues to  grow
and as places of residence become more removed from places of commerce,
the people of Steamboat will rely more on the automobile to  do their
daily business.'1

Alternate  transportation modes in Steamboat, while they  exist and
are growing are still minor in comparison to auto traffic.

Shuttle bus service between downtown and Mt. Werner went on  a no-fare
basis during the 1974-75 ski season.  The service is contracted  by
the city to the Steamboat Stage Co., and during December 1975 reported
a total volume of  22,176 passengers, an 18 percent increase  over the
                                  -119-

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previous December.  The buses run from 7:30 a.m. to 10 p.m. daily on
a 40 minute schedule for a total of 22 runs each way per day.

A survey of skiers conducted in January 1976 for Weiner & Associates
found only 22.3 percent of the respondents saying they had ever ridden
on the free bus.  The sample, chosen at random on lift lines at Mt.
Werner, numbered 1,319.  The skiers had gotten to the ski area pri-
marily by private car  (58.6 percent); 19.2 percent walked, 15.9 percent
took the free bus, 2.7 percent took hotel transportation and 3.6 came
by other means.

In the Weiner survey, the 22.3 percent figure corresponded with a
similar percentage of respondents who were Steamboat residents.
Many of the remainder did not even know the service existed.

Among comments elicited by the Weiner survey about the bus service
were the following:

       Many people, especially residents of Steamboat II, Strawberry
       Park and areas to the east of Steamboat, said they would be
       willing to pay for the bus if it would run farther east and
       west.

       Many people said they had to use their cars in the evenings
       because the bus did not run past 10:00.  Some recommended a
       minimal charge for the later service.  (Note:  the bus used
       to run later but these runs lost too much money because of
       insufficient patronage.)

       Some respondents wanted more stops added to the route, both
       in town and out.

       A "park and ride" system for getting around downtown Steamboat
       Springs was suggested.

       Ski racks should be installed on the outside of the buses;
       presently riders have to carry their skis onto the bus.

       Parking lots at Mt. Werner are small and some are quite far
       from the lifts, making bus transportation to the ski area
       attractive to some.

       Many people said, however, that they simply preferred driving
       or hitchhiking to riding the bus.

A bus service for Steamboat Springs senior citizens, bringing them
downtown to shop, meet appointments or visit is run by the Kiwanis
Club.  Transportation for the elderly, a significant problem in Routt
County, is discussed under socio-economics.
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There is regular air service from Steamboat to Denver and Grand  Junction
as well as to some smaller Colorado towns.  From 1974 to 1976 Frontier
Airlines has increased its (winter) service from one to between  3-5
scheduled flights each way per day  (Frontier's flights land at the
Hayden Airport).  Rocky Mountain Airways during this same period has
gone from 5 to 8 Steamboat/Denver flights each way per day.  In  addi-
tion, Westair flies in and out from Grand Junction  (on Saturdays only
and just during the ski season).  All incoming flights are met by
Steamboat Stage Co. buses.

Continental Trailways buses between Denver and Salt Lake City stop
at Steamboat twice daily in both directions.  There is rail service
but it is freight only, as is trucking.

Finally, a taxi service is operated by Steamboat Taxi Service, Inc.
It is year-round, although it shut down briefly in the fall of 1975
due to a shortage of business.
                               Noise
Noise, which is often considered the ultimate environmental insult,
is a problem in downtown Steamboat Springs associated directly to
motor vehicle traffic.  Levels of sound are usually measured in decibels
 (dB).  Whispers might register as 20 to 30 dB on a sound-level meter,
while a reading taken near a working jackhammer could be 115 dB or more.
The decibel scale is logarithmic so that a twofold increase in sound
is shown as an increase of 6 dB.  Ear discomfort begins at 120 dB,
while pain results at 140 dB.  Length of exposure is also important
so that long term exposure to perhaps as low as 75 dB is claimed to
cause gradual loss of hearing.  For this reason many municipalities
prescribe an 80 dB limit, measured at 25 feet from the source on the
A scale.  Steamboat Springs has not adopted such a standard so that
awkward nuisance complaints must be used to abate problems.

During the first week of December 1975, measurements were taken by
the EIS team using a General Radio Type 2  (model BR 1565-B) instru-
ment.  Noise level measurements varied with traffic movement as
indicated below:

       Airport Road at Elk River Road           40 dB  CA)
       U.S. 40 at Elk River Road                58-65
       U.S. 40 at west edge of City             62-84
       Lincoln Ave.  (U.S. 40) at 3rd            60-78
       Lincoln Ave.  (y.S. 40) at 5th            58-91
       City Hall                                53-65
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Noise measurements at the Mt. Werner plant remained near 45 dB with
little fluctuation, while the Steamboat Springs site measures in the
50-55 dB range peaking to 65 with traffic movement in the adjacent
residential area.  Based on resident interviews and measurements,
noise does not appear to be an issue associated with this facilities
plan.  However, traffic noise will continue to be a problem even with
U.S. 40 improvements.
                            Solid Waste
The Steamboat Springs area has been using a designated solid waste
disposal site near Milner, 11 miles west of the city.  According to
State Health Department officials, this site is, or soon will be,
permanently closed because of capacity limitations.  The County has
been urged to provide a site near Steamboat, however, none has been
proposed to date.  A suggestion of using an existing Oak Creek site
(25 miles southeast) is considered unreasonable, principally because
of its distance.  Disposal of well digested sludge at Oak Creek would
be considered acceptable to State Health because no water table leach-
ing would be present at this elevated site.
                           Demographics

Routt County is 171 miles from Denver.  Its northern edge borders
Wyoming, and the Colorado counties surrounding it are Jackson, Grand,
Eagle, Garfield, Rio Blanco and Moffat.  The Routt County subdivisions
include Hayden, Oak Creek, Steamboat Springs and Yampa.  The county
seat is Steamboat Springs.

Overall, the population of Routt County consists of native born Colo-
radians with an education comparable to the statewide average.  Colorado,
along with six other states, ranks second, only to Utah  (12.5) in the
U.S. median years of education.  There are fewer children under the
age of five than is the case in general in the state.

The following discussion is based upon 1970 Census data.  The 1970
Routt County population is divided into 83.1 percent rural nonfarm
and 16.9 percent rural farm residents.  Of the 353 farms in 1970, 291
had sales of $10,000 to $39,999; and 15.5 percent exceeded $40,000.
This compares favorably with, farms throughout Colorado, where only
42.7 percent of farms had sales between $10,000 and $39,000.  The
short growing season is reflected in agricultural production of 13.4
percent in crops, and 85.7 percent in livestock and livestock products.

The median income for Routt County is $7,494 as compared with the state's
$9,555.  Routt County families making more than $15,000 represent only
11.7 percent of the population while the state's percentage is 19.7.
Percapita income is $2,631 in Routt compared to $3,106 for the state.
                                      -122-

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There are no racial minorities reflected in the 1,122 rural  farm popu-
lation, and 31 minorities in the 5,479 rural nonfarm population.  The
median school years completed were 12.4, identical with the  state
average.

Persons under five years of age, 7.5 percent, are fewer than the state's
8.4 percent, and those over 65 years of age exceed the state average,
9.7 compared with 8.5 percent.  Both of these differences are reflected
in the Routt County median age of 28.5, 2.2 years above the  state median.
                            Recreation
Routt County and Steamboat Springs offer a wide range of recreational
activities.  Downhill skiing is the area's main attraction, so much so,
that ski-related income and employment dominate the local economy.
LTV's expansion of the Mt. Werner slopes was followed by development of
the Stagecoach area, 25 miles south of Steamboat Springs, and plans for
construction of the Columbine ski area, 35 miles to the north of town
at Steamboat Lake.  Although the last two are not operating, skiers from
around the country continue to flock in record numbers to the existing
trails on Mt. Werner.  Meanwhile, developers hope that new lifts can be
built at Harrison Creek about eight miles southeast of Steamboat Springs.

Downhill skiing is complemented by a host of other winter sports.  As
noted by Charles Gathers and Associates, there is virtually unlimited
terrain for cross-country skiing.  Strawberry Park, just north of
Steamboat Springs, was to have been the site for the 1976 Olympic
cross-country events.  Ski jumping, a popular local activity, would
have been held at Howelson Hill, adjacent to and south of downtown
Steamboat.

There is also ice fishing at Steamboat and Pearl Lakes, swimming at
heated pools in downtown Steamboat Springs and on Mt. Werner, skating
and hockey at Howelson Hill, and practically unlimited areas for
sledding, tobogganing, snowmobiling and snowshoeing.

In the the summer cool nights and warm days contribute much to the
area's popularity as a resort.  LTV and the Steamboat Springs Chamber/
Resort Association have joined with other ski counties in Colorado to
promote their warm weather activities.  LTV operates the Cliff Buchholz
tennis ranch and a golf course on the mountain.  And, needless to say,
the area's vast open lands, woods, mountains and streams provide an
excellent locale for hiking, camping, fishing,, horseback riding and
just plain sightseeing.

Between the summer and winter seasons, these same locales become
crowded with hunters, seeking the variety of wild game in the area,
especially elk and deer.  Residents also like to hunt, often as a
practical way of reducing food costs in a place where making ends meet
can be difficult.
                               -123-

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     Howelsen Hill ski Jump
Steamboat Ski Area (Mt. Werner)
             -124-

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                            Aesthetics

The summer lushness of the Yampa Valley is especially impressive when
viewed from a hilltop.  The swift flowing Yampa and innumerable fishing
steams flow through forests and lush meadows.  What had been grazing
land for abundant game has now become largely cattle range.  But the
Ute summer hunting grounds remain a mecca for sport hunters and fisher-
men, and more recently cross country skiers and backpackers.

The largest group of mineral springs in Colorado give Steamboat Springs
a unique character.  Skiing has been a tradition here long before it
was a major industry.  Otherwise, the town is distinguished, especially
from other ski resorts, by its enduring ranch character:  cowboy hats
ride the heads of genuine ranchers, and the breadth of Lincoln Avenue
is a reminder that it was used, often, for running cattle.

Besides the town, the other noticeable manmade features of the area
include:  cuts on Mt. Werner for skiing and the resort facilities
below; pronounced road cuts for access below the Ramada Inn; the airport;
the railroad; highways and associated strip development; and residential
and commercial development, including trailer parks, single family
lots and multi-family structure complexes.
                              Culture

Within the last five years, the arts in Steamboat Springs have undergone
a dramatic expansion.  A Western history room was opened in the Bud
Werner Memorial Library.  The Arts and Humanities Council raised over
$30,000 in funds to restore the old Denver and Rio Grande Western depot
as a cultural center for the community.  And an annual three-week summer
Arts Festival was instituted in 1974.  The Festival in 1975 included
visual arts, theatre, dance and performances and workshops of the
Colorado Philharmonic and Denver Symphony Orchestras.

These joined the Tread of the Pioneers Museum, Parry-Mansfield School's
summer drama and dance programs and some local art galleries on the
Steamboat Springs culture scene.

In addition, a number of young artists have moved into the area.  One
of them, painter Dennis Pendleton, is quoted in The Steamboat Pilot
 CNovember 13, 1975) as saying that, "No other community in Colorado
offers the same kind of help and enthusiasm as is found here."
                               -125-

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                      Other Federal Projects

A number of other Projects involving federal or state government should
have an impact on the study area.  They are summarized in the text that
follows:

The proposed Yamcolo project, a 9,000 acre-foot reservoir to be
situated on the upper Yampa (Bear) River in Garfield County, south of
Routt County.  To be used for irrigation, it will make the river level
easy to predict and make planning easier for Steamboat's sewage
treatment plant, according to Steamboat Springs City Manager, Roger
McCoy.  Sources of funding for the reservoir could include industry.-
a .57 mill levy increase in Garfield County, a combination loan-grant
from the federal government under the Small Projects Act, and a $1
million loan from the Colorado Water Conservation Fund.

New coal leases to be granted by the Bureau of Land Management (BLM)
after completion of an environmental impact statement.  The impact on
the study area will be felt in two ways.  First, there will be a
population increase caused by miners who will prefer to live in
Steamboat Springs for its commercial, recreational and other advantages,
even though the mines are in southern and western Routt County.  Second,
there will be temporary sedimentation problems in the  Yampa River
caused by road construction and related activities.  A possibility that
environmental groups will file suit against the BLM's environmental
impact statement as they have done in Wyoming and Montana could pre-
vent or delay the granting of the leases.

The Harrison Creek ski area, a proposed development located approximately
eight miles southeast of Steamboat.  Its capacity could be for 6,000
to 8,000 skiers daily.  A decision on whether to approve the plan or
not must wait until the U.S. Forest Service has completed a regional
study on wilderness and recreational needs for the Routt National
Forest, in which Harrison Creek would be located.

A plan by the U.S. Bureau of Reclamation to build several hydroelectric
power plants and transmission systems, which will interconnect with
federally supported steam plants operated by the Rural Electric
Associations.  The latter includes plants at Hayden and Craig run by
the Colorado-Ute Electric Association.

A proposed improvement of U.S. Highway 40 by the Colorado Division of
Highways and the U.S. Department of Transportation.  The project, as
described in the draft environmental impact statement, "would upgrade,
modernize, and improve safety conditions and would relieve congestion
on a ten-mile segment of U.S.  40, east and west of Steamboat Springs."
However, this project could pose water runoff problems.  Coordination
must occur between engineers for the road and sewage facilities to
prevent any drainage hazards.   The relocation of sewage outfalls may
also be necessary, since they cannot be below a major highway.
                               -126-

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A possible water diversion, the Sheephorn Project, which will affect
some 600,000 acre-feet per year of ''runoff" water along the Continental
Divide.  Fifty agencies, groups, and individuals recently filed court
protests on the plan as proposed by Vidler Tunner Water Company, a
private outfit which along with the city of Golden, Colorado, wants to
take water from the Colorado, Yampa and Blue Rivers to Golden and the
Denver metropolitan area.  Most of the 50 entities involved are local,
county or regional, not state or federal.  However, in a separate but
related suit, Vidler Tunnel Water Co. and the City of Golden applied
to the Federal Power Commission (FPC) for permission to begin a
preliminary study of potential hydroelectric facilities.  The FPC
licenses all such facilities in the country.  If a go-ahead is granted
to the company, then all public lands in the project will be with-
drawn from any other entity until the FPC makes a decision.
                                  -127-

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                 V.  Description of Proposed  Alternatives


The planning effort for wastewater facilities has conbined the comments
and recommendations of numerous individuals representing Wright-McLaughlin
Engineers, EPA, Colorado Health Department, City of Steamboat Springs,
SSRSA member districts, Weiner & Associates, Citizens Advisory Committee
and the General Advisory Group.  This consortium narrowed down an original
list of 55 sewage treatment configurations to four basic alternatives
plus a sub-alternative and a no-action approach.   The basic alternatives
are shown in Table V-l; all of them use the existing  Mt.  Werner District
facilities, for flow leveling, while the Steamboat Springs plant  is
retired in 1985 with Alternatives III and IV.
                             TABLE  V-l
              FINAL FOUR TREATMENT PLANT ALTERNATIVES
 Alt.
 No.
  II
Plant Location
          Steamboat Springs Lagoons
Steamboat Springs Lagoons
Process

Extended Aeration-
Advanced Biologi-
cal Treatment

Extended Aeration-
Mixed Advanced
Waste Treatment
Facilities Plan
Designation	

  Steamboat
  E/A-ABT
  Steamboat
  E/A-M/AWT
 III       Midway Regional Site
  IV       Midway Regional Site
                            Extended  Aeration-   Midway
                            Advanced  Biologi-    E/A-ABT
                            cal  Treatment

                            Extended  Aeration-   Midway
                            Mixed Advanced       E/A-
                            Waste Treatment        M/AWT
 It should be noted that the proposed structural alternatives deal only
 with domestic sewage.  They do not specify facilities for the control
 and treatment of urban and agricultural runoff or programs to control
 river bank erosion.  However, Wright-McLaughlin states that the proposed
 alternatives have good compatibility for treatment of non-point discharges
 from urban areas, resulting from snowmelt and storm runoff.  Urban
 runoff could be detained at selected locations and metered into the
 sewage collection system during off-peak hours.  Other runoff could be
 treated by detention/settling only, with some runoff receiving land
 treatment directly.  The details of these  systems  are discussed in
Chapter VIII,  Mitigation Measures.
                                -128-

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                 Alternative I - Present Site and
                   In-Plant Tertiary Treatment
Alternative I calls for the long-term, continued use of the present
city lagoon site as located on Study Map 1.  This site is located
wholly within the 100-year flood plain and adjacent to nearby
residences.  Regional treatment at this site would require pumping of
sewage from Steamboat II, KOA Campground, Sleepy Bear, and Riverside
(already pumping to site) via a 16,400 foot interceptor.  The land use
implications of this pumping are discussed in Chapter IV.

The aerated lagoons at the present site would be modified for flow
leveling and polishing purposes.  The secondary treatment would be
provided by new extended aeration facilities, but would require far
less space, thus accomodating needed tertiary facilities.  The tertiary
treatment  for ammonia would be achieved via an advanced biological
process.   This would involve activated sludge nitrification basins
with secondary clarification and sludge return.  Dual media filtration
would also be used to remove suspended solids and organic material
(BOD5).  Figure 10 displays this process configuration.  Although
very little sludge would be created by these processes, the accumulated
sludge would be deposited on nearby agricultural lands.  Application
methods include the use of a tank truck that could spray or inject
the sludge.

First phase construction would include construction of pre-treatment
facilities, three extended aeration basins, two clarifiers, modifi-
cation of  the existing lagoons, two dual media filter units and a
accessories, disinfection facilities, dechlorination facilities and
the complete sludge system.

                 Alternative II - Present Site and
                      Summertime Land Treatment

This alternative also uses the Steamboat Springs lagoons for the long-
term plant site, plus the lands in Figure 5 for land application.  The
configuration of the plant is shown in Figure 11.  It is similar to that
of Alternative I; however, the extended aeration basins are smaller
because less ammonia treatment is required when land treatment is
employed.  The in-plant tertiary treatment will feature ammonia removal
plus a dual-media filter for removal of suspended solids and organic
material.  The removal of residual chlorine would be accomplished
by SO2 addition.  The treatment of sludge would occur on Meadow Indus-
tries lands by using surface spreading with a flexible hose or by
applying it from a tank truck.  The treatment of effluent would occur
in the plant 100 percent of the time during the non-irrigation season
                                 -129-

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                                                                        existing berms to be removed to
                                                                        reduce existing flood plain hazard
legend    ^(
        denotes first phase construction
    1    pretreatment facility
    2    4-extended aeration basins
    3    4-clarifiers
    4    pumps for filters and filter aid chemicals'
    5    dual media filters and chemical mixing
    6    chlorine feed and contact chamber
S*
                                           ~~\
        7   backwash tank, sludge facilities,
            return pumping facilities for nitrification,
            sludge handling and trucking facilities
        8   emergency sludge drying beds
        9   flow leveling & polishing pond (aerated)
       10   flow leveling pond
       11   aerobic sludge digestion
1  STEAMBOAT EXTENDED AERATION
ADVANCED   BIOLOGICAL  TREATMENT
            Figure  10

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      summer land treatment
      down vafley
                                                                                                                existing bermvto be removed to
                                                                                                                reduce existing flood plain hazard
legend
       denotes first phase construction
   1   pretreatment facility
   2   4-extended aeration basins
   3   4-clarifiers
   4   pumps for filters and filter aid chemicals
   5   dual media filters and chemical mixing
6   chlorine  feed and contact chamber,
    treated wastewater pumping
7   back wash tank and sludge facilities
8   emergency sludge drying beds
9   flow leveling & polishing pond (aerated)
2    STEAMBOAT EXTENDED AERATION
MIXED ADVANCED  WASTE  TREATMENT
             Figure  11

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and 60 percent during the irrigation season.  The remaining forty
percent would be put on the Meadow Industries land during the irriga-
tion season.  Application would be by surface spreading, using existing
contour ditches.

The construction of the new facilities is designed to take place in
1978.  It includes a pre-treatment facility, two extended aeration
basins, two clarifiers, consolidation of the existing lagoons into
one basin, two dual-media filters, a dechlorination facility and in-
stallation of a portion of the land treatment equipment.

                 Alternative III - Midway Site and
                    In-Plant Tertiary Treatment

This alternative is similar to Alternative I and it continues the use
of the Steamboat Springs lagoons until retirement in 1985.  As a result
only limited facilities would be constructed at the Midway Site during
the first phase of construction.  This site is to be located in the
general area shown in Figure 12.  Construction phasing calls for two
extended aeration basins and clarifiers, to be used for summer nitrifica-
tion and back-up BOD removal in the winter.  Other facilities would
include an aerated flow leveling pond, two dual-media filters and
disinfection facilities, as shown in Figure 12.  A facility not shown
in the diagram would be a dechlorination system using S02 addition.
Any sludge generated by the proposed processes would be deposited on
nearby agricultural lands.

The collection system for conveying raw wastewater to the plant would
utilize the current Mt. Werner lagoons for flow leveling purposes.  In
addition, a new 18-inch, 7,600 foot line would parallel the existing
Steamboat Springs outfall.  Another outfall (10,800 ft @ 24") would
be laid across the Yampa just below the City lagoons and parallel the
river to the Midway Site; it would operate by gravity flow.  Riverside
would continue to pump to the City lagoons until its retirement in
1985, after which an interceptor would cross the river connecting to
the new outfall.  Sleepy Bear and KOA would like to connect to the new
outfall during the first phase of construction by crossing the river in
a common interceptor.  Finally, Steamboat II would be pumped across
the river via the railroad trestle.

                 Alternative IV - Midway Site and
                     Summertime Land Treatment

This alternative phases out the Steamboat Springs lagoons in 1985 in a
manner similar to Alternative III.  Interceptor and outfall construction
is also the same as described for Alternative III.  The principal difference
is the tertiary treatment method for ammonia.  In this case, the approach
                                 -132-

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u>
U)
                                                                              alternative plant site here or further upstream
                                                                                                                             —d«notfiilirst phase construction
                                                                                                                              pretreatment racinty
                                                                                                                              4-extended^eration BaStrrs-
                                                                                                                              4-clarifi
       is for-Mfters and filter aid chemicals
     al media filters and chemical mixing
   chlorine feed and contact chamber
   backwash tank, sludge facilities,
   return pumping facilities for nitrification,
   sludge handling and trucking facilities
8  /Emergency sludge drying beds
                                                                                                                              flow leveling & polishing pond (aerated)
                                                                                                                           10  aerobic sludge digestion
                                                                                                                          3   MIDWAY EXTENDED AERATION
                                                                                                                      ADVANCED   BIOLOGICAL  TREATMENT
                                                                                                                                    Figure 12

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outlined for Alternative II, i.e., 40 percent summertime land treat-
ment would be used in conjunction with 60 percent in-plant treatment.
Figure 13 shows the plant construction would include the first aerated
pond, one clarifier, two dual-media filters, disinfection facilities,
dechlorination facilities and partial land treatment and sludge facilities,

                    Mt. Werner Sub-Alternative

The Mt. Werner sub-alternative is proposed by the Mt. Werner Water and
Sanitation District and LTV.  It would involve the treatment and diver-
sion of 410,000 gpd from Mt. Werner's wastewater treatment plant to the
LTV golf course.  Water would be pumped to the existing LTV reservoir,
to be applied according to a variable schedule.  In exchange for the
effluent, 0.6 cfs of natural flow would remain in Fish Creek instead
of being treated as domestic water and applied to the golf course.  The
resultant effect on Fish Creek would be an elevation in minimum summer
flow from 0.5 to 1.1 cfs.

                       No-Action Alternative

As the title implies, no capital expansion program would be initiated
and the existing treatment facilities would continue in their present
fashion.
                                -134-

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CO
en
I
                                                                   alternative plant site here or futner upstream
                                                                                                          summer land treatment area
                                                                                                             »    »   »-  >   I
                                                                                                                      1   pretreatment facility
                                                                                                                      2   4-extended aeration basins
                                                                                                                     3   4-clarifie/s
4  pumps-for fitters and filter aid chemicals
      I media filters and chemical mixing
   chlorine'feed and contact chamber,
   treated wastewater pumping
   backwash tank and sludge facilities
8  emergency sludge  drying beds
9  trow leveling & polishing pond ( aerated )
                                                                                                                         flow leveling & storage pond for summer
                                                                                                                         land treatment
                                                                                                                     4  MIDWAY EXTENDED  AERATION
                                                                                                                 MIXED ADVANCED WASTE TREATMENT
                                                                                                                              Figure  13

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            VI.    Evaluation of  Alternatives
This section sets forth the projected impacts associated with the four
action alternatives and the one no-action alternative.  Alternatives I
and III refer to in-plant treatment at the existing and Midway sites,
respectively.  Alternatives II and IV refer to the land treatment
options at the existing and Midway sites, while Alternative V is the
no-action alternative.  All of these alternatives are discussed in
the text that follows under the headings of water quality, geology,
soils, biology, air quality, land use and cost.
                           Water Quality

The impacts on the area's water quality can be divided into those on
surface waters and groundwaters.  If any of the action alternatives
are implemented, and the discharge regulations are adhered to, the
impacts on surface waters should be positive.  However, the overall
quality could still deteriorate if urban and agricultural runoff are
not checked.  If the no-action alternative occurs, the impact on
surface waters would be negative; for increased effluent loads of
the future would exceed the capacity of the existing plants to ade-
quately-treat them.  The resultant discharges would be of a lower
quality and the impacts on the Yampa River would be negative.  If
a land treatment alternative is developed, both surface waters and
groundwaters could be impacted.  The surface waters could receive
impacts from underdrains if the lowlands are irrigated.  Their quality
would have to comply with the discharge permit.  The impact on
groundwaters depends on the quality of the effluent and on application
rates.  The resultant impact should not contribute to water quality
changes that exceed EPA's recommended drinking water standards.
The details of these contingencies are discussed in the text that
follows.

Alternatives I and III

Alternatives I and III are the in-plant alternatives at the existing
site and the midway site, respectively.  Their operational goals are
the discharge of effluents that meet the 1983 standards, as delineated
in the previous section on water quality goals.  Assuming these
standards are met or exceeded, the impact on the existing Yampa
River ecosystem would be beneficial.

Site Selection:  The two sites being proposed for the secondary
treatment facilities are the current and the Midway site, each of
which, is described earlier.  The Midway site has a more westerly
location and lower elevation, where it can receive sewage from the
entire SSRSA study area by gravity, except for a small amount of
pumping at Steamboat II, KOA and Sleepy Bear.
                                  -136-

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Such a system provides for greater operating reliability and lesser
operation and maintenance costs.  This system could not be used as
extensively at the existing site due to this site's higher elevation.
However, if land treatment is employed, the existing site would be
in a better position to provide gravity flow to the lowlands near
Midway.  Based on these considerations, the Midway Site appears to
be the best choice for the treatment plant.

Another consideration is the choice of a sludge disposal site.  This
choice can be determined by guidelines developed at both federal and
state levels.  The federal guidelines, published June 3, 1976 in the
Federal Register, are called Municipal Sludge Management, Environmental
Factors.  A summary of these factors are listed below:

     0  Non agricultural use of sludge disposal is recommended over
        uses where sludge products could be directly ingested by
        humans.
     0  The pH of the sludge/soil complex is recommended to be 6.5
        or greater to prevent solubilization and migration of most
        metal ions.
     0  Stabilization is recommended to reduce odors and pathogens.
     0  Incorporation methods are recommended as a means of improving
        public acceptance of sludge application by decreasing odor
        generation and unsightly deposits on crops.
     0  Spray application of digested sludge is acceptable, pro-
        viding the transport of aerosols is minimized beyond the
        application area.  The use of low-pressure sprays, short
        risers or a remote application site is recommended.
     0  Determine N, P and K requirements for the disposal site;
        supplemental potassium fertilizer is often required to
        provide a balanced macro-nutrient composition.
     0  Add no more plant-available nitrogen than twice the plant
        requirement.  The plant-available nitrogen equals NH3-N,
        and N03~N from the soil, plus NH3-N, NCU-N and 0.15  organic
        -N  from the sludge.  Volitilization of sludge NH^-N is
        about 50 percent.
     o  A monitoring plan is required when application rates exceed
        10 dry tons per acre per year for liquid digested sludge
        or 50 dry tons per acre for dried or dewatered sludge
        deposited over three years.
     0  Forage or pasture crops should not be consumed by animals
        when these crops are physically covered with sludge.  When
        direct ingestion is possible, the sludge's lead content
        should not exceed 1000 mg per kg dry weight and cadmium
        content should not exceed 1000 mg per kg dry weight.
     o  An EPA advanced waste treatment research laboratory is
        available for consultation.
                                       -137-

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The state guidelines on this matter are based partially on thn fedora]
guidelines although with some modifications and additions.(Colorado
Dept. of Health, 1976).  These additional factors are listed below:

     o  Stabilized sludge applied to the land should possess the
        following quality on a dry weight basis - N (2 to 6%), P
        (2 to 6%), K  (.25 to 1.00%), Zn (500 to 3000 ppm), Cu (250
        to 1500 ppm), Pb (100 to 1500 ppm), Ni (25 to 1000 ppm)  and
        Cd (5 to 30 ppm).
     0  Sludge may be stored, providing it is adequately stabilized
        and surface waters are protected.
     o  Mean annual water table should be greater than seven feet
        and the nearest well should be greater than 150 feet away.
     o  Slope of the application site should be less than five
        percent or soil losses should be less then five tons per
        acre per year, calculated by the Universal Soil Loss Equation.

Since project alternatives I and III involve the deposition of sludge
on nearby agricultural land, the preceding guidelines could be helpful.
However, if either alternative is adopted a definite site that con-
forms to these guidelines should be developed, studied and approved
prior to approval of Step III grant monies.

Secondary Treatment;  Two types of biological treatment systems have been
proposed for the secondary level treatment.  The first is the extended
aeration-activated sludge process; the second is the newer Bio-Disc ro-
tating biological filter process.  The configuration of these treatment
schemes would be the same at either of the two sites.

The comparative waste treatment efficiencies of these two processes are
similar.  Both have achieved greater than 85 percent removal of BOD and
suspended solids and both are fairly resistant to upset conditions, re-
quiring a minimum of operator attention.  The Bio-Disc process does not
have a sludge return requirement which implies greater simplicity, but
it does require primary clarification and subsequent anerobic digestion
of the sludges.  Waste sludges from the extended aeration process would
be aerobically digested and would generate less sludge than the Bio-
Disc system.  This process would be easier to operate and less susceptible
to upset conditions f but it would demand a higher power requirement for
the oxygen supply.  Despite this requirement, the extended aeration-
activated sludge system is preferable due to higher costs of purchasing
a Bio-Disc system.

Tertiary Treatment;  The in-plant biological tertiary treatment systems
considered for the Steamboat Springs region consist of an activated
sludge nitrification facility and the Bio-Disc rotating filter system.
If the Bio-Disc system is used, an intermediate secondary clarifica-
tion system would not be required.  The activated sludge facility
would consist of a separate entity located in series with an ex-
tended aeration treatment step.  The treatment efficiencies documen-
ted by both processes are high enough to meet the ammonia discharge
levels, calculated by the design engineer for the proposed ammonia
discharges.  Both of these nitrification systems are temperature
dependent and the rate of ammonia conversion decreases as influent
                              -138-

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temperature decreases.  Thus, the development of a good, active bio-
mass for the nitrification process could be a problem during the
winter months in the Steamboat area.  This consideration would be
especially applicable to BOD removal rates.  In addition, since
biological systems are not easily or quickly started at these tempera-
tures, both of these systems should probably be maintained on a year
round basis.  Switching between an inplant and a land irrigation
system, and then back again, would likely raise serious operating
and control problems.

Since the Bio-Disc system does not require a sludge return stream,
it is inherently easier to operate and probably less susceptible to
upset via operator error.  However, capital costs would be much
greater in the Bio-Disc System and would probably preclude its use.

Process Performance:  The sensitive parameters to be handled by the
treatment processes include ammonia, chlorine, BOD and suspended
solids.  Ammonia would be controlled by one of the two previously-
mentioned biological systems, where nitrification would convert
ammonia to nitrate.  Either of these systems is designed to produce
a discharge that would result in a river concentration less than
0.02 mg/£ of"un-ionized ammonia.  This level has been selected
by the EPA to protect fish and aquatic life.  The possibility of it
being exceeded would be greatest during the summer if in-plant processes
are providing the tertiary treatment.  During the rest of the year, the
possibilities would be slight.  Due to these conditions the Colorado
Water Quality Control Division is expected to issue a variable ammonia
discharge permit and will provide requirements for operator monitoring.
The ammonia portion of the new permit will be implemented after
upgrading of the new facilities.

Associated with future reductions in ammonia will be increases in
nitrates.  The effect of these nitrates cannot be predicted, yet in
certain situations they are known to stimulate algal growths.  The
EPA recognizes this potential problem and is in the process of
modifying the test used to assess nitrates in lakes, so it can be
applied to streams.  When this modification is made, tests will be
run on the Yampa River and safe levels of nitrate loading will be
developed.

The situation for chlorine is regulated by their current discharge
permit, which specifies that discharges of residual chlorine should
be less than 0.5 mg/ &.  The existing permit expires on June 30,
1976; however, a revised permit from the Colorado Water Quality
Control Division will include a new limitation for total residual
chlorine, to be complied with upon upgrading the facilities.  This
revision will reflect the EPA's recent research on the matter.
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The proposed EPA Criteria for Water Quality, October 1973 recommends
that maximum acceptable residual chlorine concentrations in waters
be less than 0.003 mg/1 for chronic exposure.  Maximum concentrations
could be 0.05 mg/1 for a period of up to 30 minutes in any 24-hour
period.  However, recent communications from Dr. Brungs of the National
Water Quality Laboratory, Duluth, indicate that these values should
be re-evaluated.  The revised recommendations are as follows:
       Type of
     Chlorine Use

     Continuous
 Concentration of Total
   Residual Chlorine
A.
Not to exceed
0.01 mg/1
     Intermittent
                     B.
A.
                     B.
    Not to exceed
    0.002 mg/1
For a period of
2 hours a day, up
to, but not to
exceed, 0.2 mg/1.

For a period of
2 hours a day, up
to, but not to
exceed 0.04 mg/1.
Degree of
 Protection

This concentration
would not protect
trout and salmon
and some important
fish-food organisms;
it could be partially
lethal to sensitive
life stages of sensi-
tive fish species.

This concentration
would protect most
aquatic organisms.

This concentration
would not protect
trout and salmon.
                              This concentration
                              should protect most
                              species of fish.
Dr. Brungs further indicates that, "if free chlorine persists, more
restrictive criteria are warranted.  Alternate procedures or sub-
stitutes for chlorination should be investigated."  Dr. Brungs feels
that this approach is well founded since residual chlorine is more
persistent than the few minutes or hours indicated by some authorities.
Further, the current state of art in aquatic chemistry is not sophisti-
cated enough to allow chlorine modeling in streams, so that a case-by-
case evaluation may be necessary.

There are several analytical methods currently being used to determine
residual chlorine.  Some, like the orthotolidine method, are subject
to gross interference from other oxidizing agents, turbidity, and
color.  Additionally, orthotolidine is extremely instable at low
                             -140-

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pH values and cannot be used to measure chloramines or total residual
chlorine.  Since the toxiclty of free chlorine and chloramines are
of the same order of magnitude, Brungs recommends that the amperometric
titration method be used.  He indicates that Duluth has consistently
measured total residual chlorine in effluents at the 0.002 mg/^
(+100%) level using the amperometric method.  Marlin Helming, of
EPA's Denver laboratory, has stated that they are able to measure
total residual chlorine in effluents down to the 0.02 mg/£ +50%).
It appears, therefore, that the detectability of total residual chlorine
should not present a problem.

Methods of dechlorination and alternate means of disinfection are
available.  However, recent work by EPA has indicated that, perhaps,
not all of the total residual chlorine is being removed with several
of the currently used methods of dechlorination.  Both salmonid and
non-salmonid fish are apparently able to detect chlorine below analyti-
cal detection limits.  Zones of passage must be maintained in streams
to prevent avoidance reactions.  Regarding alternate methods of dis-
infection, such as ozone or other nascent compounds, consideration
must be given to the potential impact which they or their byproducts
can have on non-target organisms.

It has been recommended that an aeration system be used to dissipate
the chlorine prior to discharge.  The ability of aeration to accomplish
that goal is seriously questioned.  Wright-McLaughlin Engineers were
advised to review this proposal and to re-evaluate dechlorination and
alternate means of disinfection.  Consequently complete chlorine removal
using  SC>2 as the reducing agent has been included in all alternatives.

The treatment of BOD and suspended solids should be adequately handled
by the proposed systems.  The BOD removal rates will vary with temper-
ature, being lowest during the winter.  However, the dual-media filter
will assit the biological processes during this time by filtering out
organic matter.  The suspended solids will also be removed by this
process, as well as by settling.

Despite these proposals to control the quality of the discharge,
one natural pollutant could still reduce the quality of the Yampa
River.  This parameter is zinc, which appears in the influent at
the existing Steamboat Springs plant  (Table VI-1).  Although this
element should concentrate in the sludge, the level of concentration
is not known.  If no concentration occurs, it could still be diluted
by the river.  During other periods it could actually dilute the
river's concentration, which varies from zero to 0.55 mg/£  at
nearby monitoring stations.  In either case the potential impact
cannot be determined with existing information.  Consequently, the
EPA recommends future monitoring of zinc in the effluent, as well
as the immediate receiving waters.  Such monitoring is not a pre-
requisite for the construction grants program, yet the results of
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such monitoring will improve our understanding of a potential hazard
to the water quality of the Yampa River.  This information could also
provide a basis for future control programs if deemed necessary or
feasible.
                             Table  VI-1
                       Influent Water Quality1
     Parameter
     Suspended Solids
     Total Dissolved Solids
     Phenols
     Oil and Grease
     Ammonia-nitrogen
     Organic-nitrogen
     Kj eldahl-nitrogen
     Nitrate-nitrogen
     Phosphorus
     Settleable Solids
     Trace Elements2
        Aluminum
        Boron
        Copper
        Iron
        Lithium
        Manganese
        Strontium
        Silver
        Titanium
        Zinc
Concentration (mg/1)

       45
      255
       <0.001
       17
        6.2
       10.5
       18
        1.3
        2.6
        7.0
        0.01
         .1
         .1
         ,1
         ,1
        0.001
        0.01
        0.02
0.
0.
0.
0.
     iReceived April 12, 1976; analyzed by the Industrial Laboratories
        Company.
      Other trace element below level of detection.
Alternatives II and IV

The two land treatment Alternatives for tertiary treatment of waste-
waters are alternatives II and IV.  Both of these alternatives would
divert secondary effluent, treated and disinfected, into the valley
bottomlands near the Yampa River or into nearby uplands.  Both of
these lands would be irrigated during the normal irrigation season,
extending from July to mid-October.  As a corollary to this approach,
sludge would also be applied to these lands, distributed on a year-
round basis.
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The land application of wastes for wastewater treatment is not a
new practice.  A survey conducted by the American Public Works
Association  (1972) documents at least 315 municipal systems that
use this approach  (Sullivan, Conn, and Baxter, 1973).  A second
study conducted in the Rocky Mountain-Prairie Region identifies
19 municipal sites that use the land application approach  (Dean,
1974).  These latter sites occur in Colorado, Montana, North Dakota,
South Dakota, Utah, and Wyoming, where applications are used for
irrigation of golf courses, crops, hay and/or pastures.

Land application approaches are generally classified as irrigation,
overland flow, and infiltration-percolation.  The approach for
Steamboat Springs is intended to be irrigation and/or irrigation-
overland flow.  Irrigation, in this sense, would be construed as
the controlled discharge of effluent to support plant growth.  The
basic environmental assets of this action would be:  1) to renovate
the waste effluent prior to discharge; and 2) to beneficially support
crop production.  The principal constituents to be removed would be
ammonia-nitrogen, biochemical oxygen demand and suspended solids.

Land application uses the land and its associated biological systems
as a living  filter.  The renovation is both microbiological and
physiochemical in nature and includes chemical precipitation, adsorp-
tion, absorption, filtration, plant root uptake and oxidation.  Many
of the impurities that are entrapped in the soil are eventually used
by higher plants as growth components and, in the process, the waste-
water receives the equivalent to tertiary treatment.

The discussion that follows describes this kind of treatment, under
the headings of climate, wastewater application, site and soils,
treatment efficiency, effects of nitrogen on groundwaters, effects of
trace  elements on groundwater, health considerations, and surface
water runoff.

Climate:  The climatology of a specific site affects the length of its
growing season, the type of crop production, the kinetics of the break-
down of the  applied wastes, and the quantity of wastewater that can
be disposed.  The operation of existing land treatment facilities have
been documented for northern climates  (Dean, R., 1974; Malhatra, S.K. ,
et al., 1975; Sanks, R. L., et al., 1976; Sopper, W. E., et al., 1975;
and Sullivan, R. H., et  aL, 1973).  Preliminary research near Steamboat
Springs indicates that excellent renovation can be attained if the
proper design and management is provided  (Wright-McLaughlin, October
1975).  Consequently, even though, the short growing season of the
Steamboat area would limit the length of the land application season,
climate considerations should not inhibit successful renovation of
the wastewater if proper loadings are applied.
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Wastewater Application:  The proposed method of applying secondary
effluent to the Meadow Industry lands would be by contour ditches.
The application rate through these ditches would be approximately
29 inches per year.  This rate is based on a net crop irrigation
requirement of 22 inches per year, calculated by SCS methodology
(Wright-McLaughlin Engineers, June 1977).  It is based on local clima-
tology, soil conditions and biological needs of reed canary grass.
The total irrigation requirement  (29 inches per year) is developed
by assuming an irrigation efficiency of 75 percent, even though local
practices often result in 50 percent efficiencies.  This approach
allows for a considerable margin of safety to be included in the plan.

The nitrogen loading from the proposed application should be about
82 pounds per acre in 1985 and 157 pounds per acre in 2010 (Wright-
McLaughlin Engineers, June 1977).  These rates are below recommended
uptake rates for reed canary grass, which can vary between 226 and
359 pounds per acre.  Consequently, the proposed system may be limited
by nitrogen additions and may require a change to another grass species.
Such a change could be facilitated by consultations with local SCS
personnel.

The required lands for the proposed project have been reduced as a
result of the June 1977 compromise.  Current plans call for the use
of 83 acres by 1985.  Additional lands are available in case future
operations are expanded.  This approach allows for further study and
evaluation, prior to committing all the summer-time effluent to the land.

The anticipated sludge volumes for the project are expected to be 1.2
million gallons per year in 1985 and 3.4 million gallons per year in
2010.  Solids content of 1985 loads should be one percent and for the
2010 loads, two percent.  Nitrogen content of the sludge is expected
to be ten pounds per million gallons in 1985 and 15 pounds in 2010.
Comparable effluent values are expected to be nine pounds per million
gallons in both 1985 and 2010.

The required sludge treatment acreage is a small percentage of the
required total acreage and is included in the previously-mentioned
figures for the effluent.  Sludge application rates are identical to
effluent rates since water content is almost the same and nitrogen
content is within acceptable application limits.  Application methods
are to be by surface spreading from contour ditches or by application
from a tank truck.  EPA prefers the former method or any injection
variations of the latter, in order to minimize the generation of aerosols,

Since no tests have been run on the chemical quality of the existing
sludge, it is difficult to comment on its compliance with recommended
state and federal guidelines.  Consequently, EPA recommends that this
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task be undertaken during the Step II process.  Such a task is also
necessary to satisfy state requirements, which make recommendations
to counties on the acceptability of their sludge disposal operations.
At this time, however, heavy metal concentrations in the sludge are
expected to be well within the recommended maximum limits since there
are no industrial processes in Steamboat Springs that would add such
contaminents.

Site and Soils;  Soil characteristics are one of the most important
factors in determining the acceptability of a proposed land treatment
site.  Soils vary between predominantly clay soils with relatively
low percolation rates to the sand-gravel types, with higher rates.
The different rates are a result of the soil particle sizes and the
spaces between them.  Soils with the best combination of these factors
are well-drained loams or sandy loams, for they would be capable of
supporting good productivity in Steamboat Springs„  Factors of addi-
tional importance would by pH, salinity, nutrient levels, and  adsorption
and fixation capabilities of inorganic ions (EPA, March 1975).

Factors that would be unfavorable for land treatment, according to
R.L. Sands, T. Asano and A.H. Ferguson (1976), are listed below:

      0 slopes greater than 15% in forested areas and greater than
        100% in grassland  (under certain conditions there may be
        exceptions to these values depending on soil permeability
        and application).

      0 bedrock closer than three feet to the surface or extensive
        outcropping of bedrock (the EPA prefers five feet as a minimum).

      0 soils that swell more than 30%.

      o infiltration rates that are either extremely low or SAR values
        that are high.

      0 water table closer than three feet to the surface during the
        spraying season (EPA recommends a minimum of five feet or
        adequate underdrains).

      0 highly saline soils or highly saline wastewater.

      0 excessive boron or copper in the wastewater.

      0 several barely acceptable characteristics listed above,
        which in combination indicate an unsuitable site.
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All of these conditions are satisfied for the land treatment soils.
However, other conditions like slow percolation and seasonally high
water table do offer some localized constraints.  Fortunately, the
slow percolation rates have been accommodated by conservative appli-
cation rates, which may even be marginal for satisfying the water re-
quirements of the project crops.  The water table of the work silt loam
(2A,C) should be deeper than the recommended EPA depth (5 ft0) or the
recommended Colorado depth  (7 ft.).  However, depths for the unnamed
valley loams (12A,AW) could be as shallow as two feet during early
summer and as deep as eight feet during winter.  This variation exceeds
the recommended standards and could promote localized pooling in the
early summer.  Such conditions should be avoided due to the probability
of anerobic soil conditions and insect breeding.  Avoidance can be
accomplished by a reduction in application rates until soils are capable
of taking more.

Other potential impacts on the soils will come from construction
activities for the facilities and the collection system.. Major concerns
are wetness, preservation of topsoil and prevention of erosion.  The
wetness is a likely event on 12A, 49A and AW soils.  This possibility
is most likely in the early summer when the water table can be only
two feet beneath the surface.  The preservation of topsoil and the
prevention of erosion can be minimized by employing the mitigation
measures outlined in Chapter VIII.

Besides hydraulic loading, other factors could effect the fertility
of the soils under consideration.  Trace elements do accumulate in
soils and should be concentrated within the EPA's recommended levels
for irrigation waters (March 1975).  A comparison of these recom-
mendations with the influent analysis in Table VI-1 suggests that
trace elements should not be a problem.  Other possible hazards
include high salinities or high sodium adsorption ratios.  They,
too, are not expected to be a problem.

Treatment Efficiency;  Extensive investigations have been conducted
during the past several years in an effort to identify the treatment
efficiencies that might be expected from a well designed land treat-
ment system.  This information is now well documented  (Pound and
Crites, 1973; EPA, March 1975; and Sank and Asano, 1976) and is sum-
marized in Table VI-2.  As can be seen from this table, the overall
renovation expected from a properly managed land treatment system is
excellent.  Removal of BOD,-, SS, N, P, trace metals, viruses and
bacteria are all excellent and such a system should have no difficulty
meeting the 1983 design goals as developed by the design engineer.
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                               TABLE  VI-2

ESTIMATED PERCENTAGE RENOVATION EFFECTIVENESS OF LAND DISPOSAL TECHNIQUES

                                                       Rapid  Infiltration
                  Spray Irrigation   Overland Runoff	Ponds
OD 99
S 99+
70-90
95-99
race metals 95-99
rganic toxicants 99
iruses and bacteria 99+
ations 50-75
nions 0-50
80
80
60-90
60-80
60-80
60-80
90
30-50
0-10
99
99
30-80
50-90
50-90
90
99+
30-75
0-50

-------
Effects of Nigrogen on Groundwater:  Nitrogen contained in wastewater
usually takes the form of organic nitrogen, ammonium-nitrogen, and
nitrate-nitrogen although, organic and ammonium-nitrogen are the
principal forms applied to the land.  Organic nitrogen is usually
present in suspended form and is filtered and decomposed into ammon-
ium; ammonium-nitrogen is either gasified or oxidized to the nitrate-
nitrogen.  Nitrate-nitrogen is not retained in the soil but is either
utilized as a crop nutrient, leached to the groundwater, or released
as a gas following denitrification.  The nitrates released to the
groundwater are a potential hazard since concentrations in excess of
45 mg/1 can cause methemoglobinemia in small children.  However, this
potential hazard should be controlled with the proposed application
rates and the natural removal rates.  The proposed application rates
for nitrogen vary between 82 and 157 pounds per acre per year, and
these amounts should be taken up by the project crop, reed canary
grass.  Nonetheless", monitoring of groundwater will be undertaken
to assure the program's success.

Effects of Trace Elements on Groundwater:  Trace elements, heavy
metals and refractory organics that are applied to soils are generally
fixed in the soil particles and, in some cases, rendered nontoxic by
bacteria.  These constituents can be leached out of the soil, however,
by excessive hydraulic loadings or by decreases in pH beyond 6.5.
Thus, adequate system management will be a necessary requirement.
Trace metals should not be a problem at the Steamboat Springs site
due to preliminary influent analysis  (Table VI-1).

Health Considerations:  The health hazards associated with wastewater
use are caused by pathogenic bacteria, viruses, protozoa, worms and
fungi.  None of these are regularly analyzed although the hazard
from pathogenic bacteria is identified indirectly  through the mea-
surement of fecal coliforms or total coliforms.  The fecal coliforms
come almost entirely from the digestive tracts of humans and warm-
blooded animals, while the total coliforms come from many other
sources as well.  The relationship between fecal coliforms and disease
organisms has been substantiated for Salmonella  (Geldreich, 1970;
Geldreich and Bordner, 1971), where a high correlation was established
between Salmonella and fecal coliforms when fecal coliform densities
exceeded 200 per 100 ml.  Since the wastewater is to have less than
this amount before land application, its content of Salmonella should
be low.  However, its content of other disease organisms cannot be
predicted but they, too, may be low.

Viruses are more difficult to measure than bacteria but are also a
potential health, hazard.  Research by Plotkin and Katz  (1967) indicated
that only one virulent virus is sufficient to infect a person if it  con-
tains susceptible cells.  Also, Berg  (1971) suggested that waterborne
viral diseases need not occur at the epidemic level to be of  signifi-
cance.  Infection could occur and not produce overt symptoms, and the
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infected individual could serve as a viral source for others.
Although no large-scale spread of viral diseases is known to have
occurred by the water pathway, a small outbreak has been reported
that infected 800 people  (Mosley, 1967).  Viral diseases that could
be transmitted by water include poliomyelitis, gastroenteritis and
diarrhea; however, the most convincing evidence exists for infectious
hepatitis.

Since most of the pathogens found in wastewater are from human sources,
exotic pathogens may be of concern.  Such organisms could come from
foreign countries, transmitted by visitors to Steamboat Springs.  Due
to the foregoing viral information, viruses would pose the greatest
potential threat but they still would have to contact susceptible
cells to be destructive.  The transmission of these viruses to sus-
ceptible people would be negligible for all the alternatives, except
for those people that directly handle the wastewater.  They would
be in contact with aerosols that could contain an exotic virus but
the possibility of infection would be slight.

The transmission can occur through groundwater percolation, crop
contamination, or aerosol conveyance.  The danger from percolation
should be minimal since practically all bacteria and viruses are
removed during passage through the first several inches of soil
 (Pound and Crites, 1973; EPA, March, 1975; and Spyridakas and Welch,
1976).  Hazards from the pathogenic contamination of crops are a
lesser known quantity, however.  Crops slated for direct human con-
sumption should not be irrigated with wastewater during the last month
before harvest, especially vegetables.  Other crops such as corn do
not readily pick up and pass along intestinal bacteria but they could
pick  up other pathogens.  Problems for grazing animals include the
ingestion of parasites that are incorporated into range plants.
However, past records indicate that this should not be a problem.

The conveyance of pathogenic organisms via aerosols is a major concern,
especially where spray irrigation is used.  Aerosols are simply droplets
of liquid that have become airborne, and aerosols from municipal waste-
waters do contain viruses and bacteria.  The public health implications
of these have not been adequately examined in the field, but health
hazards have been postulated.  A lack of evidence for disease trans-
mission by these aerosols divides professional opinion on the question.

For the Steamboat Springs proposals several conclusions can be made
and actions can be taken to mitigate these potential problems.  First,
aerosols are not a problem in areas where flooding is used instead of
spray irrigation.  However, runoff should be monitored for possible
contamination.  Second, if a spray irrigation system is used, applica-
tion  areas should be fenced or posted and provided with a buffer zone
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around the spray field.  Low-pressure nozzles, with application streams
pointed downward, would also help to minimize the aerosol formation.
During windy days, the spray application should be minimized or even
stopped completely.  For the Steamboat locale, the low relative
humidity will also tend to minimize any problem.

Experience in other areas is valuable in gaining insight into possible
problems at Steamboat Springs.  Currently, wastewater is regularly
being applied to a number of Colorado golf courses where public
contact is intensive; no apparent ill effects have resulted from
this practice  (Dean, 1974).  The AWPA study of 1973 failed to show
any significant health problems associated with land application
(Sullivan, R. H. et al., 1973).

Another consideration is that irrigation waters will be fully treated
to secondary levels and disinfected via chlorination.  Thus,  the
effluent quality at the point of application should be quite high
and reduce the danger of health hazards.  Also the uptake of heavy
metals by plants should be slight since the wastewaters are not
expected to contain high concentrations.  This means that any sub-
sequent transfer to wildlife should be slight.  Increases in local
insect populations should also be slight if application rates are
adjusted to minimize surface pooling and runoff.

Surface Water Runoff:  If the lowlands are irrigated by secondary
effluent or liquid sludge, some treated waters would be diverted
to the Yampa River.  These waters would be collected by underdrains
and discharged as a point source.  This discharge will require a
NPDES permit, to be administered by the Colorado Water Quality
Division.  If violations occur from such a system, application
rates would have to be reduced and more area would have to be
irrigated.
                              Geology

If inplant processes are chosen for Steamboat Springs, or if no
action is taken, the impact on the area's geology should be negli-
gible.  If the land treatment alternatives are chosen, though, impact
could accrue to the water in the alluvium or the sedimentary layers.
These possibilities are discussed in the evaluation of land treatment.
If a 100-year flood occurs, then a geological hazard could impact the
project facilities.

The 100-year flood plain is shown in Study Map 1 and indicates that
the existing facilities would be flooded and the sewage lagoons
surrounded.  Such an occurrence would disrupt treatment and increase
the polluting nature of the discharge.  The river would be flowing
at about 8,000 cfs, however, so its dissipating capabilities would
be considerable.  Perhaps a more serious impact would be the water
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damage done to the facilities.  This potential damage can be minimized
with the proper design and it is recommended that this be done.  If
the Midway Site is chosen, its location would be placed outside of
the 100-year floodplain so that waterproofing contingencies could be
eliminated from its development.

                               Soils
The soils of the project area would receive significant impact only
if one of the land treatment alternatives is chosen.  They should be
enriched by the nutrients and trace elements in the wastewaters.
However, yearly samples should be taken and analyzed so that the
changing character of the soils can be observed.

                              Biology

The principal impacts on the area's biological systems are on the
Yampa River if Alternatives I, III and V are chosen and on the cultivated
fields if Alternatives II and IV are chosen.  The former impacts are
fully discussed in the evaluation on water quality and the latter ones
are discussed in the evaluation on land treatment.  None of Colorado's
threatened or endangered species should be directly effected by the four
action alternatives, although the habitat of Colorado Squawfish and
Bonytail Chub would be deteriorated by the no-action alternative.  The
survival of these fish is endangered and the no-action alternative would
allow discharges of ammonia and residual chlorine to increase in their
downstream waters.  These discharges would deteriorate the quality of
their habitat.  Furthermore, development spawned by the action alter-
natives could eventually impact the greater sandhill crane due to
human encroachment on their habitat.

                            Air Quality

The study area currently violates state and national ambient air
quality standards for total suspended particulate (TSP).  The principal
cause has not been identified but is probably road dust from the
heavy traffic volumes along Lincoln Avenue  (U.S. 40), fireplace smoke,
and fugitive dust common to agriculture areas.  Future growth and
development, as facilitated by an enlarged sewage treatment system, will
aggravate this situation particularly through increased traffic.  How-
ever, the majority of the present traffic volume is through-traffic,
independent of local growth.  In addition, a proposed U.S. 40 by-pass
will probably result in lower ambient concentrations of TSP by trip
diversions.  Street washing or other programs to control non-point
discharges will undoubtedly improve this situation as well by control
of street dirt.
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One advantage of the Midway Site is that it offers a land buffer
against noise and odor problems.  Since a pressurized spraying
system is not being proposed for either effluent or sludge, aerosol
hazard potential is eliminated.  In addition, the plant will be
located in a remote area, thus odor complaints under upset conditions
are not anticipated.

                             Land Use
In this section key issues are discussed regarding site and treatment
alternatives as they relate to growth and land use.  The "no-action"
alternative is considered first, followed by discussions of the area's
land use goals and how they would be affected by the Midway and exist-
ing sites, and by land treatment.

Alternatives

It seems quite unlikely that no action can be taken.  Steamboat Springs
sewer facilities are already in violation of water quality standards.
More growth is expected and nearly all local residents interviewed
felt that something should be done.  Were federal monies not available,
however, the city would probably have difficulty in finding the revenues
to build even a minimally acceptable facility.  The results could be
rather negative, as follows:

New point sources of pollution along the Yampa River are currently
prohibited because wasteload allocations are filled.  New construction
must, therefore, tie in with an already existing sewage system.  If
the city's facilities, the largest existing system in the area, were
to be left unimproved, the State Health Department could order a halt
to all new construction.  This was the case in Montrose, where state
officials ordered a local building permit moratorium under authority
granted by the State Water Quality Control Act of 1973.

Some people, especially the young, already pack more roommates into
a house than zoning allows.  In addition, there is an urgent need
for low and middle income housing.  Therefore a moratorium, were
it extended for any length of time could intensify the already present
housing and economic problems.

In all probability, a moratorium would also create such political
pressure for building new sewage facilities that the federal government
would eventually have to contribute funding or an extremely large bond
indebtedness would have to be assumed by local residents, the latter
being vulnerable to the bond sales market (See Chapter III).

Although the County and the City of Steamboat Springs have not yet
adopted a comprehansive plan, land use and zoning maps and the goals
formally stated by the Citizen's Advisory Committee  (CAC) for the
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regional sewage authority provide a basis for determining desired
long-term land use.  The latter, combined with interviews of local
residents and a look at existing trends, reveals a fairly clear
pattern of what future land use should be (Study Map 2).

A prime goal is preservation of agricultural land.  The water-
oriented goals and policies of the Citizen's Advisory Committee
state that:  "All alternatives investigated must enhance the agri-
cultural industry of Routt County and the SSRSA study area to provide
a diverse economy for the stability of the region."  As many inter-
viewees noted, since the study area is overzoned, future population
can easily be contained within already platted areas, making it
unnecessary to rezone agricultural land for some other use.  EPA's
evaluation pays particular attention to this goal, since more than
anything else, the pressure to convert agricultural property to other
purposes has caused serious growth and socio-economic problems in the
past.

No appreciable difference exists between plant site alternatives as
far as their effect on land extending from the southwest edge of the
study area north along Highway 40, encompassing the Mt. Werner, Fish
Creek and Tree Haus areas.  According to the unofficial 1995 land use
plan, much of the future development should take place in this section,
filling in the region between the Steamboat ski area and the town.
Both Midway and the existing site will allow gravity flow from this
area, facilitating the development that is planned.  The use of the
present Mt. Werner lagoons for flow leveling will provide an advantage
by compensating for seasonal flow variations that result from extensive
tourist accommodations in this area.

The original townsite of Steamboat Springs and West Steamboat is
another major area slated for growth, according to the 1995 land use
maps.  Again, there is little distinction that can be drawn between
plant sites as far as their impact on this area.

The area along both sides of the Elk River Road, from its intersection
with U.S. 40 to the airport, (County 129), is mostly open land, but
its location between the airport and town makes for a natural growth
zone, especially for industry and commerce.  Both plant sites would
receive gravity flow from this area.

Land north of the airport is primarily open and is intended to remain
that way according to Gathers.  The River and Deer Mountain subdivisions
are the only residental developments in this area.  These approved
satellite subdivisions are partially built out with, future growth
thwarted by soils conditions which prevent the use of individual
septic systems.  If interceptor sewer lines are extended to this
area, sewage will have to be pumped uphill as far as the airport,
regardless of which plant site is chosen.  Although pumping would
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be a discouragement to growth in this area, a modern sewer system
could facilitate development which is contrary to the draft compre-
hensive plan.

The broad expanse of land west of the Elk River Road/U.S. 40 Junction,
extending north and south of the Yampa, is the principal area of land
use concern.  As shown in Study Map 2, this area contains both the pro-
posed plant sites and land treatment area.  The Riverside, Sleepy
Bear, KOA and Steamboat II residential areas and the Selbe and Hogue
farms are located along the north side of the river, while south of
the river, land use is devoted to both irrigated and non-irrigated
cropland as shown in Study Map 2.  The concern is for the open farm-
land extending from the present city lagoons west to the Midway Site
and beyond.  A subjective argument exists regarding the role wastewater
facilities play in influencing future land use.  Will the selected
plant site encourage, facilitate, or discourage growth in the remaining
area slated to continue as agricultural?  Specifically, there is concern
that the Midway Site would encourage development because gravity flow
could be utilized in most of this area.  Pumping, it is argued, with
its extra costs, would be necessary if the present site is maintained,
thus providing a growth deterrent.

On the other hand, north of the highway between Steamboat II and the
present site there is only a finite amount of property that could be
readily developed, namely the area in the immediate vicinity of
Steamboat II, which would require pumping even to Midway, and another
parcel across the road from Riverside.  The remaining open land north
of the Yampa is mostly on top of a mesa and is not likely to be developed
due to construction costs and probable planning agency opposition.  As
for the area to the south of the Yampa, there is such strong community
sentiment to maintain this land as agricultural that the selection of
a plant site will not by itself provide an inducement to urban growth.
Those interviewed, including ranchers, public officials, planning
commission members, and the citizenry-at-large expressed nearly unani-
mous support for keeping this area as is.  Barring unforeseen events,
this land will be incorporated into the final Comprehensive Plan with
its present agricultural designation.

The only clear conflict with apparent community goals and sound land
use principals in this area is a proposed trailer park as indicated
in Study Map 2.  This zoned use would create another satellite develop-
ment around Steamboat, few of which have been successful.  The proposed
"Meadow" midway site would remove the intended trailer park use, thus
keeping the majority of this parcel in productive agricultural use
and compatible with the surrounding area.  The question remains whether
the existence of the plant and connecting interceptor south of the
river will create pressure for development in this area.  The proposed
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County Comprehensive Plan recoramende agricultural use which does not
preserve this use even if adoped.  A comprehensive plan is a recommen-
dation, and as such does not limit or dictate land uses.  The ultimate
control lies within zoning regulations as adopted and modified by the
county commissioners.

EPA attorneys, at the time of this final EIS, are working with city
and county officials to create a legal restriction on new taps along
the proposed interceptors.  A grant condition will be imposed by EPA
on the SSRSA which will require that Steamboat Springs take all legal
means possible such that taps on the new interceptor be limited to
existing incorporated sanitation districts and existing residences
including Sleepy Bear and KOA.  The grant condition will be in effect
for a period of 10 years or until Phase II expansion.  The purpose of
this grant restriction is to make every possible effort from the federal
level to assure compatible land uses consistent with local desires.
The interceptor tap restriction was originally proposed by Dr. John
Utterback, Chairman of the'Routt County Commissioners.  City, SSRSA
and Routt County concurrence is anticipated with this plan.

The other alternatives keep the main plant at the present Steamboat
Springs site.  The existing site is in a section that could very well
become densely populated.  The land surrounding the present lagoons is
slated for high intensity industrial development to the north and east
on the 1995 plan and for medium density residential just to the west.
A trailer park and housing development are already in operation on
nearby property.  The history of sewer systems in populated areas is
not very good.  People have an almost instinctive reaction against
sewage, and there are practical fears of noise and odor.  Interviews
with residents of the nearby trailer park revealed no complaints about
the present facilities, but one cannot be sure that future residents
will feel the same, or that expanded facilities will not make a differ-
ence.  Eventually, complaints from residents and businesses in the
neighborhood could force the city to consider a new location.

In sum, it appears that there is little appreciable difference between
the sites as far as their effect on growth patterns is concerned.  For
that reason, the existing site may be desirable for the short term in
order  to  fully utilize present facilities, but over the long run the
Midway Site is preferable since it provides adequate buffer away
from nearby residences, thus consistent with sound land use principals.

Land use  criteria must also be considered when land treatment is under
consideration.  Application of disinfected secondary effluent to a
parcel of land requires the long-term commitment of that land for
treatment purposes.  The area proposed for summertime land treatment
is shown  in Figure 14 and  is the same area that public officials,
study  area residents and property owners agree should remain agricul-
tural.  Simultaneously, summertime  land treatment, by keeping the
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                                 PROPOSED
                                INTERCEPTOR
                                   I IMC
APPLICATION  SITES

REGIONAL PLANT  SITE

STORAGE  RESERVOIR
        FIGURE  14
   LAND  TREATMENT  SITES
STEAMBOAT SPRINGS  REGIONAL
     WASTE WATER SYSTEM

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direct discharge in winter, would, through the technology employed,
link the waste-load allocation to a design population.  Since the
waste-load allocation is in pounds per day, the waste-load allocation
will continue to serve as a growth constraint and a growth management
tool.  Therefore, EPA encourages this mode of tertiary treatment for
the Steamboat Springs area.
                               Costs

In the draft EIS cost estimates were summarized as prepared by Wright-
McLaughlin.  Since that time extensive effort has been made in pro-
ducing accurate cost estimates for the two alternatives under active
consideration; extended aeration and advanced biological treatment at
the City lagoon site, and extended aeration and mixed advanced wastewater
treatment  (EA-MAWT) at the Midway Site.  Table vi-3 summarizes capital,
operation and maintenance costs according to a present worth comparison
technique.  This approach takes into account the time effect on money
and indicates an estimated $343,260 savings with the Midway EA-MAWT
alternative over the twenty year planning period.

The Steamboat Springs City Council on June 22, 1977 approved a combined
plan which includes the Midway Site and both technologies of EA-MAWT
and EA-ABT as discussed in the recommended action chapter.  The total
estimated costs of this selected action are compared in Table VI-4.
It is estimated that the combined process will increase overall costs
by approximately $138,500.  This amount represents only a 1.9 percent
increase over the Midway EA-MAWT alternative.  Given limitations of
engineering costs estimates, it can be said that the City's selected
plan is essentially identical in cost to the Midway EA-MAWT alternative.
In comparison to all other alternatives considered, it appears that
the City's choice is the most cost effective means to achieve agency
water quality standards while at the same time meeting capacity needs.
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                                TABLE VI-3

                        COST  EFFECTIVE COMPARISON
                            MAIN ALTERNATIVES
                                Steamboat
                EA-ABT
  Midway	EA-MAWT
Phase I:

   Collection System
   Treatment System
   Total Capital Costs

Present Worth Phase I:
   (.9401 factor)
 1,122,450
 3,647,260
$4,769,710
 1,506,100
 2,661,400
$4,167,500
                4,484,000
             3,917,850
Phase II:

   Total Capital  (Treatment)
     Costs

Present Worth Phase II:
   (.6099 factor)
Total Capital Present Worth

Operation and Maintenance
   Present Worth   (20 years)
TOTAL PRESENT WORTH
   575,450
                  350,960


                4,834,960


                2,813,710


               $7,648,670
 1,905,160
             1,161,960


             5,079,810


             2,225,600


            $7,305,410
AVERAGE ANNUAL COSTS
(20 years - .0899 factor)
               $   687,620
            $  656,760
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                               TABLE VI-4

                        COST EFFECTIVE COMPARISON
                              SELECTED PLAN
Phase I:

   Collection System
   Treatment System
   Total Capital Costs

Present Worth Phase I:
                                                       Midway Site
                                            Extended Aeration With AST and M/AWT
1,506,100
2,686,200
4,192,300

                      3,941,200
Phase II:

   Total Capital Costs

Present Worth Phase II:
1,914,500
                      1,167,600
Total Present Worth of
   Capital Costs

Total Operation and Main-
tenance Present Worth
   (20 years)
TOTAL PRESENT WORTH
AVERAGE ANNUAL COSTS
                      5,108,800
                      2,400,000


                     $7,443,100


                     $  669,130
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              VII.  Recommended  Action
It is EPA policy that the selection of the engineering alternative  be
done at the local governmental level providing engineering economic and
environmental criteria are met.  This selection was made on June  22,
1977 by the City Council and Board of County Commissioners and  it was
supported by the design engineer, the environmental consultant  and
the EPA.  Based on this concurrance, the final design is being  developed
and several unresolved issues are being addressed.

The alternative chosen is the one designated as Alternative IV  in this
report.  It provides tertiary treatment by in-plant processes during
the non-irrigation season and by a combination of in-plant processes
(60%) and land treatment (40%) during the irrigation  season. The exist-
ing Steamboat Springs plant will be used for secondary treatment  until
retirement in 1985 (approx.).  The collection system  would use  the  Mt.
Werner lagoon for flow leveling and would divert most of the wastewater
to the Steamboat Springs plant.  From here the treated effluent would
be directed to the Midway plant for final treatment and processing. The
installation of the collection system would be funded by the districts
involved, except for improvements in I/I and the installation of  outfalls,
It would involve the improvement or replacement of several thousand
feet of existing outfalls in the Mt. Werner and Steamboat Springs
districts, plus the installation of a new outfall that would connect
Steamboat Springs and the Meadow Industries site. This latter  line
would also receive wastewater from KOA, Sleepy Bear and Steamboat II.

The major components of the new plant would include a pre-treatment
facility, two extended aeration basins, two clarifiers, dual media
filters, disinfection facilities, dechlorination facilities, sludge
facilities and an aerated polishing pond.  The extended aeration  basins
would provide for BOD removal and some nitrification  (25 to 50  percent).
Additional BOD would be removed by the dual media filter, which would
also remove suspended solids.  The aerated pond would then provide
additional treatment and flow leveling.

During the irrigation season, 40 percent of the incoming wastewater
would be treated and disinfected before being applied to the land.   The
in-plant treatment would consist of primary, secondary and tertiary
treatment (nitrification).  The application to the land would be  by
surface spreading, applied to the Meadow Industry lands.  The applica-
tion rate would be about 29 inches per year and it would supply about
82 pounds per acre of nitrogen in 1985 and 157 in 2010.  The hydraulic
loading represents a.  conservative approach that takes many environmental
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factors into account.  The nitrogen levels reflect the input of
summertime effluent and year-round sludge and they are well within
acceptable uptake capabilities for the project crop, reed canary
grass.   The effluent would be applied by existing contour ditches
and the sludge, by a flexible hose or tank truck.  If a tank truck
is employed, EPA prefers injection to spraying.

The construction phasing is planned in two stages, one commencing in
1978, the other in 1985.  The first phase would provide for the in-
stallation of all equipment previously mentioned.  The second phase
would provide for two more aerators, two additional clarifiers and
a second pond.  Their completion and successful operation would
signal the retirement of the existing plant at Steamboat Springs.
Phase II operation involves higher annual power costs due to increased
flows and energy-consuming aerators that will replace the lagoons at
the Steamboat Springs site.
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                VIII.   Mitigation  Measures
The proposed mitigation measures are discussed in the text that
follows.  They are designed to minimize the projected impacts  that
are delineated in Chapter VI, Evaluation of the Alternatives.   They
are discussed under the headings of water quantity,  water quality,
soils, biology, air quality, history and archaeology, and socio-
economics.

                          Water Quantity

The most significant water quantity problem facing the SSRSA is the
excessive inflow/infiltration (I/I) within their collection systems.
This factor often accounts for up to 85 percent of the total flow
at the Steamboat Springs plant.  To minimize this action the Public
Works Department of Steamboat Springs is initiating a program  to replace
some of the lines in the older part of the city and place them below
the frost line.  This activity should reduce winter I/I by over 20
percent.

Additional measures are proposed by Wright-McLaughlin Engineers so
that year-round I/I can be reduced by approximately 50 percent.  They
would involve replacing some of the older lines in Steamboat Springs
with the new ones paralleling the older ones.  Such action would allow
the older lines to continue to collect groundwaters and discharge it
to the Yampa River drainage.  If this technique is employed, the dis-
charge should be integrated into plans to control urban runoff.  It
could require some settling to remove suspended solids or possibly
some other form of treatment.  Tests on the quality of this water
would be necessary to determine the necessary control or treatment.
The discharge, itself, would require a permit from the Water Quality
Control Division of the Colorado Health Department.

After proper controls have been placed on discharging some of  the I/I,
it should be considered for recycling purposes.  This possibility
would depend on its water quality and the needs of potential users.

Other means of controlling I/I have been proposed for the Mt.  Werner
collection system, which would consist of replacing existing pipe,
grouting it and providing liners.  These proposals, along with the
others, are considered cost effective by Wright-McLaughlin Engineers
when compared with facilities expansions.  This proposal is presently
being implemented and the future facilities have been designed accord-
ingly.
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                           Water Quality

The water quality of the Yampa River can be maintained and improved
by implementing the recommended action, by controlling and treating
urban and agricultural runoff, and by stabilizing the river banks.
All of these factors are necessary if the 1983 goal of the Water Pol-
lution Control Act is to be achieved.  An important corollary to the
recommended action is sound and alert management of the proposed
system.  This factor would be especially important during the irri-
gation season when application rates must be properly adjusted to
account for aerobic soil conditions and proper treatment before dis-
charge into the Yampa River.  This latter consideration will require
periodic monitoring of the discharge to see if it complies with permit
requirements.  Another consideration would be the quality of the receiving
waters in the ground.  Again, periodic monitoring will enable manage-
ment to regularly assess this parameter and take corrective action
if necessary.

During the non-irrigation period it would be necessary to regularly
monitor the quality of the effluent and the sludge.  Parameters of
concern include ammonia, residual chlorine, BOD and suspended solids;
the effluent concentrations must conform to a  discharge permit.  The
constituents in the sludge will affect the application rate so their
quality will also be monitored.  Such information would be helpful in
finding both the optimum application rate or the optimum application
method.

Control of agricultural and urban runoff can be achieved in several
ways.  The following three areas are considered most important by
Wright-McLaughlin Engineers  (June, 1977):

      0 Implementation of institutional measures to control runoff
        and prevent practices that cause erosion and other sources
        of non-point pollution.
      0 Implementation of correction measures that will mitigate
        erosion and pollution, such as steep roadside cuts and
        unmanaged trash and garbage areas.
      0 Implementation of runoff control measures for heavily developed
        areas, which include good street sweeping and structural
        measures to contain and partially treat shock loading.

The institutional measures of this program would include regulations
relating to floodplains, detention ponding and erosion control.  The
floodplain regulation would create a riparian zone that would restrict
residential and industrial development and would promote open space.
It also should encourage a non-agricultural zone along the river banks
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to promote re-establishment of natural vegetation.  A model for such
a program already has been prepared by the Colorado Water Conservation
Board and could be applied to Steamboat Springs.

A detention pond regulation would involve the formation of a municipal
drainage and flood control agency.  It would develop operating funds
by charging property owners, according to the runoff from their property
that is created in excess of natural flows.  Credits could be provided
to owners who reduced their runoff through the creation of detention
areas on roofs, parking lots or grassy areas.  If these incentives could
not generate sufficient voluntary reductions, then associated operating
funds would be available to implement structural controls for the entire
city.

Erosion control regulations would focus on a variety of areas related
to earth-moving activities, construction and urbanization of open land.
They would be designed to prevent water pollution from sediment, fer-
tilizer, pesticides and other substances that are potentially harmful
to humans or aquatic life.  Sensitive areas to be regulated would include:

      0 Earth-moving activities, which should be limited in their
        areal extent.
      0 Surface water diversions, which should be required around active
        construction areas.
      0 Velocity control of surface diversions, which should be en-
        couraged to minimize erosion.
      0 Revegetation, which should be implemented during the first
        growing season after ceasation of construction.
      0 Interim revegetation, which may be advisable during projects
        of lengthy duration.
      0 Collection of runoff in sedimentation basins, which should
        occur prior to joining local rivers and streams.  Diversion
        to treatment facilities should be implemented only if the
        unnatural runoff is considered serious.
      0 Dumping of oil, grease, antifreeze, pesticides and general
        refuse, which is already controlled to some extent by exist-
        ing state regulations.

After some of these institutional measures are implemented, additional
correction measures could be undertaken to control runoff from road
systems and ski areas.  For example, all disturbed areas along road-
ways should be revegetated, according to local SCS practices.  When
roadside slopes exceed a gradient of 3:1, structural measures should
be implemented instead of revegetation.  When natural drainage patterns
intersect a road, they should be allowed to pass through conduits,
since unnatural diversions often foster excess erosion and sedimentation.
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The construction of lift facilities and ski slopes should be planned
in such a way to prohibit the need for significant fall construction.
The construction areas should be left free of construction debris and
other waste material.  As an area is developed, a plan should be clearly
made and approved by the Forest Service to show how runoff from recent
construction activities will be managed so that flows laden with sedi-
ment will not discharge directly to streams.  Suggested measures are
detention ponds below recently constructed lift facilities and dis-
charge of runoff into heavily wooden areas via a spreader pipe so that
the water is filtered by the vegetation and soil layers in that forest.
Also, the ski slopes should be left with as much cover as possible, and
in general, not cleared by bulldozers, etc.  If areas are completely
cleared, significant control measures should be taken to establish a
healthy vegetation cover.

Once institutional regulations are developed and various correctional
devices are employed, runoff control measures should also be employed
at the highly urbanized areas of Steamboat Springs and Mt. Werner
Village.  A first step would involve the implementation of a street
cleaning program, which has already developed for Steamboat Springs.
Another action could involve the collection of runoff from the highly
urbanized areas and its routing to sedimentation ponds.  The collection
system for this program would be the most expensive, while the sedimen-
tation ponds would be the least expensive.

Wright-McLaughlin Engineers estimates that it would cost about $1,575,000
for  such a system, not considering land acquisition costs and contin-
gencies.  This estimate is based on $1,425,000 of collection costs for
280  acres in the "Old Town" region of Steamboat Springs.  The pond
costs of $150,000 are based on a seven acre-feet pond in the Mt. Werner/
Fish Creek area and a nine acre-feet pond in the Steamboat area.  Both
of these ponds would be designed to contain runoff from all the mean
annual rainfall so that shock loading could be detained and released
slowly.

If this system could be implemented in the project area, a major step
would be taken to achieve the national water quality goals of 1983.
If further advances are deemed desirable, urban runoff from the collec-
tion system could be routed to the regional sewage plant during off-
peak hours.  Implementation of this program would involve the purchase
of automatic metering devices, costing around $60,000, plus a slight
increase in O & M costs to operate the system.  EPA believes that Steam-
boat Springs needs to be more aggressive in analyzing and eventually
instituting these non-point programs.  To date their activities have
been limited to a street cleaning program and controls on constructed
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related erosion.  Of course the structural alternatives considered above
would be costly for the city to implement and federal funds are not
currently available for this purpose.

                               Soils

The soils of the project area will be impacted due to irrigation with
effluent and sludge, construction of new facilities and installation
of new collectors.  The irrigation with effluent and sludge should
impart beneficial effects if distribution rates are controlled.  Yet
the construction of new facilities and the installation of new collec-
tors should provide local conditions for erosion.  Consequently,
these activities should be performed during drier periods of the year
to mitigate against loss of top soils.  Plans also should be made to
collect seepage waters and prevent them from entering the Yampa River
via surface flow.  If natural surface runoff does enter the project
sites, it should be diverted.

The topsoils of the project sites will be valuable during revegeta-
tion phases of the project and should be stock-piled.  Along the
right of way for the interceptor topsoil can be replaced immediately
on the previously covered trench.  Furthermore, if construction
persists longer than one summer, these soils should be protected by
a cover crop.  Acceptable cover crops include oats or rye grass
 (Lolius sp.).  Note that the latter species is not cereal rye, which
is deemed undesirable by some local ranchers.

Once construction activities have been completed, plans should be
made to prepare the site for revegetation.  Stock-piled top soils
should be re-distributed over disturbed areas, layered according to
their pre-construction thicknesses.  Final grading should allow for
proper drainage and should provide for safe operation of farm equip-
ment  (< 3:1 slopes).  After final grading has been completed, tests
should be conducted to analyze the soils' nutrient composition.  Such
Such tests may be conducted at the CSU F^ctension Service in Fort Collins,
Colorado, while sampling bags may be obtained from the local SCS office.

If nutrient deficiencies are identified, the CSU lab will recommend
nutrients to be applied and their application rate.  When fertilizer
is applied, it should be mixed to a depth of four inches, using a disc
or other suitable device.  This activity should continue until a firm,
uniformly-fine seedbed is prepared.  Once disking has been completed,
harrowing should be undertaken to further break up the clumps.  If
fertilizer  is not applied to certain portions of the site, disking
and harrowing should be undertaken anyway, to prepare these areas for
planting.  When any of these operations are conducted on sloping land,
the equipment should be driven along the general contours.
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The seeding mixture should be comprised of 50 percent Timothy and
50 percent smooth brome, variety Manchar  (Tom Pick, SCS, personal
communication).  These grasses already occur along valley bottom lands
and terraces and they are hearty perennials that form good sod.  If
a legume is added to the mixture,  Alsike clover should be used since
it is less likely to cause bloating in livestock.

The recommended seeding method is drilling since it maximizes the
potential for establishment.  Seeding rates for this method should
be three-quarters of a pound of Timothy and six and one-half pounds
of smooth brome for each acre seeded.  If Alsike clover is added to
the mixture, less than one pound per acre would be sufficient.  If
broadcast methods are used instead of drilling, all seeding rates
should be doubled.  If seed stocks are less than 100 percent pure,
seeding rates should be increased accordingly.  Proper implementation
of this program is designed to produce 40 live seedlings per square foot.

The best time for seeding would be fall, between late September and
October.  The second choice would be early spring with small amounts
of snow still on the ground.  Irrigation should be used only if fer-
tilizer is used or if it can be accomplished by using low flow rates
over short periods of time.  High flow rates could drown or wash away
seedlings if it persisted in its intensity.

Mulching should be employed only on slopes that possess a gradient
greater than 4:1.  Mulch materials should be unweathered, unchopped
hay or small grain straw, preferably wheat.  Application rates should
vary between one and one-half to two tons per acre, or 70 to 90 pounds
per thousand square feet.  The selected mulch should be spread uniformly
so that approximately 75 percent of the soil surface is covered.  Once
this material is in place, anchoring devices should be employed to
minimize losses from wind and water action.  Acceptable anchoring
devices include peg and twine, nettings, tillage, mulch anchoring tools
and pick chains.

Routine inspections should be made of vegetated areas.  If an area
does not respond adequately, re-seeding should be attempted, using one-
half of the original seeding rates.  If over 60 percent of an area is
damaged or if it has not properly vegetated, re-seeding should be
attempted with all original rates and procedures.  If other contingencies
are encountered, consult with local SCS representatives.

Therefore, EPA will condition the Step II grant to SSRSA such that the
construction includes a suitable revegetation plan developed under the
above guidelines.
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                              Biology

The biological systems most effected by the project are the Yampa
River, proposed irrigation and sludge disposal sites, and the con-
struction site.  All of these systems have been discussed in the
previous two sections on water quality and soils.  Impacts on these
systems are a direct result of the proposed project.  Yet secondary
impacts may occur also as a result of increased human activity brought
about by the project.  This activity could impact the greater sandhill
crane, a state endangered bird species.  Studies of this bird have
concluded that a one-quarter of a mile buffer zone should be provided
around active nests.  Additional protection can be afforded by avoiding
development near their spring dancing grounds and their fall staging
grounds.  Sandhill cranes have been observed in the project area along the
Yampa River but neither their dancing or staging grounds are in this
vicinity.

                            Air Quality

The most significant problem with the quality of the project's air is
the generation of fugitive dust from automobiles and trucks.  This
problem can be mitigated by a more effective street cleaning program,
which is proposed to reduce the pollution loads from urban runoff.

                      History and Archaeology

EPA recognizes that the limited information currently available in
archaeology in the area is not adequate to consider right of way
selection or the exact site of the plant as well as possibly recover
any sites of archeological significance.  Therefore a supplemental
report on archeologically significant sites is currently being prepared.
Unfortunately, this report will not be completed in time to print as
part of this final EIS.  Copies of the report will be available by mid
September 1977 and sent to interested parties upon request.  The State
Historical Preservation Officer will be contacted following his review
of this report for his recommendation on mitigating measures for
archaeological sites.

If archaeological artifacts are discovered during construction or
plowing activities, these activities will be stopped.  A qualified
archaeologist should then be summoned to investigate the site.  If
the findings are significant, accomodations should be made to allow
proper excavation and assessment.  However, these accommodations should
be done in such a manner that construction delays are minimized.  EPA
will also condition the Step II grant to SSRSA that construction activity
include consideration for the results of this field survey of archaeo-
logical sites.
                              -167-

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                          Socio-Economics

The main socio-economic factor to be mitigated is the poor financial
conditions of the districts.  This condition is discussed in Chapter
III and it must be rectified before construction funds can be released.
The EPA must be assured that the member districts can produce their
25 percent of the total projected cost.

      Interceptor and Force Main Crossings of the Yampa River

The proposed interceptor will cross the Yampa River west of the present
Steamboat lagoons.  In addition, two force main systems for KOA, Sleepy
Bear and Steamboat II will cross the river (See Figure 4).  This con-
struction activity requires a permit issued by the U.S. Army Corp of
Engineers Sacramento District under section 404 of the Federal Water
Pollution Control Act.  This 404 permit is issued with EPA concurrence
that such construction will comply with Colorado State Water Quality
Standards and minimize adverse affects on wildlife habitat.  The details
of construction design will be accomplished during Step II.  At this
time it is anticipated such construction will be cut and fill along the
river bottom.  In order to minimize the expected adverse affect of stream
siltation during construction which could harm fish spawning, EPA will
condition the Step II grant to SSRSA to include compliance with 404
permit conditions including but not limited to the following:

     1)  Consultation with U.S. Fish and Wildlife Service and the
         Colorado Division of Wildlife such that the construction
         period avoids fish spawning or fish movement for spawning.

     2)  Placement of non-toxic fill material as bedding material or
         as cover material.   (EPA prefers the original cover material
         be replaced).

     3)  Heavy equipment use in the stream be minimized either by
         using a dragline or backhoe in order to reduce sedimentation
         during construction.

     4)  Minimize disturbance of the entry trenches along the banks
         by using dragline or backhoe equipment.

Rather that specifying a certain period suitable to meet the first
criteria at this time, these agencies should be contacted after permit
application to best determine the least conflicting periods during the
year of construction.  The SSRSA must apply for the 404 permit to the
Corp of Engineers at least 180 days prior to anticipated construction.
                               -168-

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              Groundwater Control During Construction

The proposed interceptor  line will require trenching in areas of
shallow groundwater necessitating dewatering of the trench.  If such
water is discharged to the Yampa River or to an irrigation ditch in
the area, this activity would require a permit from the Colorado  Dept.
of Health issued under the National Pollution Discharge Elimination
System  (NPDES).  Such permits usually require limitations on suspended
solids and free of oil and grease.  No other contaminates are expected
in this water.  EPA prefers that this limited amount of water be
applied as irrigation water to the fields in the area if the land owner
agrees to such a procedure.  If the construction and dewatering occur
during a wet period, this water may be a nuisance to hay production.
Under these conditions, the water should be pumped to the higher (and
drier) upper terraces with owner consent or after passing through a
settling pond and meeting the NPDES permit conditions, discharged to
the river.  Therefore EPA will condition the Step II grant to SSRSA
such that they comply with any NPDES permit issued and further that
the contractor shall prepare a plan for wasting this water which em-
phasizes its use for irrigation.

                        Energy Conservation

EPA wishes to promote engineering designs that conserve the nation's
limited energy resources.  There are two basic ways to accomplish
this for the proposed facility:

     1)  Encourage insulation and design for the enclosed portions
         of the plant that reduce space heating requirements.

     2)  Encourage high efficiency and/or phasing of the pumps
         needed in the system.

Insulation requirements currently established by the Federal Housing
Authority include minimum standards of R-30 in ceilings and R-19 in
outside walls.  Double windows and proper sealing are logical compon-
ents of a well insulated building.  Passive design can also aid in
reducing building thermal space heating demand.  Such design includes
southern exposure for windows and doors while on northern exposures
such openings are reduced or eliminated.  Solar heating is not likely
to be cost effective given the low space heating demand of the proposed
structures (these facilities do not require the same temperatures or
night time heating of residential buildings for example).  Nevertheless
EPA encourages the SSRSA to investigate the need for solar heating during
Step II design.

Pumping efficiency depends both on the rated efficiency of the pump and
the percent of load on the pump.  Electric motor efficiencies currently
                             -169-

-------
range between 88% and 93%.  More efficient motors usually have a higher
initial cost.  Pump systems consume less total energy when the hydraulic
load is near the capacity of the pump.  The latter presents a problem
to the design engineer in terms of energy conservation since selecting
a pump initially close to current hydraulic capacity does not allow for
increased flows due to growth.  In some cases it is possible to add pumps
or phase in new pumps rather than operate a larger pump under low loads
until growth occurs.

Therefore EPA will condition the Step II grant to SSRSA such that the
design of the new facility shall comply with the minimum insulation
requirements established by FHA for residential housing.  In addition,
the design shall consider the cost effectiveness of using high efficiency
electric motors, pump phasing to allow for maximum pump loads, and a
solar heating system.
                          Growth Restrictions

In accordance with the expressed wishes of the Routt County Commissioners,
an outfall tap restriction will be instituted prior to issuance of Step 3
grant funds.  This will limit access to the regional plant interceptor
line and prevent growth inducement inconsistent with community goals.

This grant condition shall read as follows:

     "The secondary effluent transmission line or outfall line
      between the existing lagoon system and the Midway site
      shall be restricted so as to prevent future connections
      within the present unincorporated areas of Routt County
      and areas outside of the present boundaries of the exist-
      ing sanitation districts as of the date of this grant.
      Existing residences occupied prior to the date of this
      grant are exempt from this provision.  The above restric-
      tion shall apply for a period of ten years or until Phase
      II expansion is undertaken, whichever occurs first.  The
      City of Steamboat Springs shall take all legal means avail-
      able to implement this restriction."
                             -170-

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          IX.  Unavoidable Adverse  Effects

After the impacts of the recommended action are mitigated, the
remaining impacts are considered  unavoidable.  Most of these impacts
are on the area's water quality and they are considered minor.  They
include increases in background levels  of BOD, nitrogen and residual
chlorines in the Yampa River.   The BOD  represents organic material that
can be consumed by aquatic insects or that  can be decomposed into
nutrients.  These nutrients could produce a fertilizing effect on the
plants of the  Yampa River, thus  improving  its productivity.  The
nitrogen compounds would include  ammonia and nitrates, and they could
also provide a fertilizing effect on the Yampa River.  Both BOD and
ammonia could reduce the river's  oxygen concentrations although this is
expected to be slight.

Qther unavoidable impacts include the loss  of approximately 20 acres
of productive cropland  due to the construction of the new plant.
Impacts associated with the land  application program  are expected to
be beneficial, and its potential  adverse impacts should be avoidable
through proper application rates  and proper management.
                                 -171-

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     X.  Short-Term Uses and  Long-Term Productivity

The short-term uses of the study  area  are centered around cattle
ranching and skiing.   The proposed  facilities plan provides support for
these industries and strives  to do  it  in an environmentally sound
manner.  It should benefit the productivity of local croplands if
effluent and sludge are properly  applied to them.  However, when the
effluent is discharged into the Yampa  River, some degradation in water
quality could result,  even though it would represent an improvement over
existing conditions.   These effluents  could also improve the productivity of
the river's ecosystem, by fertilizing  with  organics, ammonia and nitrate.

After 20 or 30 years,  the productivity of the area's croplands could
still be enhanced by the application of sewage wastes.  However, the
productivity of the Yampa River could  deteriorate if other sources of
pollution are not checked.  These sources include urban and agricultural
runoff, plus river bank erosion.  All  of these sources affect the short-
term productivity of the Yampa although they could degrade it even more
in the future.  Urban runoff  should increase more than the others and
special considerations should be  given to its control and treatment.
The output of agricultural runoff,  should be relatively constant
unless new techniques can be  developed to reduce it.  The overall
impact could be a long-term reduction  in aquatic productivity.
                             -172-

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         XI.  Irreversible and  Irretrievable Commitment

              of  Resources


Despite the improvements in environmental quality that the recommended
action would provide,  certain  resources would be required to implement
it.  These resources would include  raw materials to build the plant and
its distribution system:  steel,  concrete, plastic, glass, etc.  Most
of this material would represent  an irreversible and irretrievable
commitment of resources although  future improvements in recycling
technology could enable some of it  to be reclaimed and reused.  Other
resources would include various types of energy, necessary to build
and operate the system.  These resources would be irretrievable once
they are used.  During the operation of the system, the energy costs
would represent about 48 percent  of the total operational costs.
Other costs are listed in Table XXVII and include costs for labor,
repairs and chemicals.  The total outlay for 1985 is projected to be
$102,097 and for 2010, $192,121.

The land would represent another  resource committed to the project.
Those lands under irrigation would  be committed for the duration of
the project, after which they  could be returned to their current use.
However, the quality of these  lands could be irreversibly altered by
the proposed irrigation practices,  even though this is expected to be
beneficial.  Those lands used  by  the plant should not be irreversibly
committed since future reclamation  activities could restore most of
their productivity.

                              TABLE XXVII

              Average Annual Operating Costs  (1976 dollars)

                              For Phase I              For Phase II
                               by  1985                  by 2010

     Labor                    $31,856                  $59,576
     Chemicals                11,523                   14,855
     Repair and Replacement   10,916                   28,854
     Power                    49,932 @2CAwh           92,856
     Land Treatment Credit    -2,130                   -4,020
        (sale of crops)
     Total                   $102,097                 $192,121
The condition of the Yampa River will be  altered by the increased
sewage load to be discharged into it.   This  change could be beneficial
if the discharged nutrients promote an increase in the river's
productivity.  However, future changes in sewage treatment could alter
these conditions so it is only irreversible  throughout the lifetime
of the proposed facilities.
                              -173-

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                      Bibliography
Benoit, D.A.,  unpublished data, 1971.  Long term effects of hexavalent
  chromium on the growth, survival, and reproduction of the brook
  trout and rainbow trout.   National Water Quality Laboratory, Duluth,
  Minnesota.

Berg, G. 1971.  Integrated approach to problem of viruses.  J. Sanit.
  Eng. Div. Amer. Soc. Civil Eng.  97(SA6):867-882.

Biesinger, K.E. and G.M. Christensen,  unpublished data, 1971.   Metal
  effects on survival, growth, reproduction and metabolism of Daphnia
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Bunin, J.  Predicted ecological impact of the 1976 Nordic Olympic
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Chapman, G.A., unpublished.  National water quality laboratory,
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Charles Gathers & Associates, October 1973.  Routt County Colorado
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City of Steamboat Springs.   1975.   Proposed 1976 annual budget,  City
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Colorado Air Pollution Control Commission.   May 1974.  Designation of
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Colorado Business Magazine, Nov/Dec. 1975.   Denver, Colorado.

Colorado Division of Commerce & Development.  January 1974.  Colorado
  community profile, Steamboat Springs.  Denver, Colorado.

Colorado Division of Highways, U.S. Department of Transportation,
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Colorado Health Department.  1976.  Guidelines for sludge utiliza-
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Colorado Interstate Gas Company.  1972.  Colorado Marketing Manual,
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Cooper, K.M.  1974.  1975 Economic forecast, the outlook for Colorado
  and the nation.  United Banks of Colorado, Denver.
                                -174-

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County Treasurer.  June 30, 1975.  Routt County Treasurer Semi annual
  financial statement, Steamboat Springs, Colorado.

Dean, R.J.  1974.  Land application of effluents in the Rocky Mountain
  prairie region.  Masters thesis, University of Colorado, Boulder,
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Denver Olympic -Organizing Committee, Rocky Mountain Center on
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Everhart, W.H., unpublished data.  1971.  Zoology Department, Colorado
  State University, Fort Collins, Colorado.

Geldreich, E.E.  1970.  Applying bacteriological parameters to
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  113-120.

Geldreich, E.E. and R. H. Bordner.  1971.  Fecal contamination of
  fruits and vegetables during cultivation and processing for market.
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Hem, John D.   1970.  Study and interpretation of the chemical
  characteristics of natural water.  U.S. Government Printing Office,
  Washington,  D.C.

Isbill & Associates.  May 1974.  Routt County Stol Airport land use
  alternatives.  Routt County Planning Commission, Steamboat Springs,
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League of Women Voters.  Know your county, Routt County Colorado,
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McCall-Ellingson & Morrill.  April, 1974.  Water quality management
  plan for the Green River basin.  Colorado Department of Health,
  Denver, Colorado.

Metcalf and Eddy, Inc.  1972.  Wastewater engineering.  McGraw Hill,
  New York.  782 pp.

Mosley, J.W.   1967.  Transmission of viral diseases by drinking water,
  in transmission of viruses by the water route,(G. Berg, ed.)
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Plotkin, S.A.  and M. Katz.  1967.  Minimal infective doses of viruses
  for man by the oral route, in Transmission of viruses by the water
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  p. 151.

Pound, C.E. and R.W. Crites.  July 1973.  Characteristics of municipal
  effluents.  Proceedings of the Joint Conference on Recycling Municipal
  Sludges and Effluents on Land.  Champaign, University of Illinois,
  pp. 49-62.
                                -175-

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Powell, Lee A.  1972.  Steamboat Springs: the first 40 years.  Steamboat
  Springs, Colorado.

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Routt County, Colorado.  1975.  Abstract of assessment and levies.

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  Regional Planning Commission, prepared for Colorado Division of
  Planning, Denver, Colorado.

Routt County Regional Planning Commission Staff.  November, 1974.
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  housing characteristics, Routt County, Steamboat Springs, Colorado.

Routt County Regional Planning Commission Staff.  August, 1974.
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Sullivan, R.H. et al.  July, 1973.  Survey of facilities using land
  application of wastewater.  Office of Water Program Operations,
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                               -176-

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                               -177-

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  management report, 201 facilities plan, volume two.  Denver, Colorado.

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  volume one, Steamboat Springs wastewater management report, basic
  information and analyses.  Denver, Colorado.
                                     -178-

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                         Appendix A

           Water Quality Standards and Regulations


                           TABLE I

                 STREAM QUALITY DESIGNATION

Standard               Meaning

Al, A2, Bl, B2         Suitable as a raw water supply treatable
                       to drinking water standards

Al, Bl                 Cold water fishery  (DO = 6 mg/1, Temp.
                        680 F)

A2, B2                 Warm water fishery  (DO = 5 mg/1, Temp.
                        900F)

Al, A2                 Suitable for all purposes for which raw
                       water is customarily used including primary
                       contact recreation  (Fecal Coli = 200/100 ml,
                       pH = 6.5-8.5)

Bl, B2                 Suitable for all purposes for which raw
                       water is customarily used except primary
                       contact recreation  (Fecal Coli =
                       1000/100 ml, pH = 6-9).
                          A-l

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                             TABLE II

          COLORADO STANDARDS FOR THE DISCHARGE OF WASTES
   Parameter

   BOD 5

   Suspended Solid

   Fecal Coliform
   Residual Chlorine

   PH

   Oil and Grease
                                Parameter Limitation,  Effective
                                       August 21, 1975	
                7-Day Average

                   45 mg/1

                   45 mg/1
            30-Day Average

                30 mg/1

                30 mg/1
                As determined by the Division of Adminis-
                tration of the State Health Department to
                protect public health in the stream classi-
                fication to which the discharge is made.

                Less than 0.5 mg/1

                6.0 - 9.0

                10 mg/1 and there shall be no visible
                sheen.
Parameter
BODC
                   TABLE  III

ROUTT COUNTY STANDARDS FOR DISCHARGE OF WASTES
                   (Summary)

                      Parameter Limitation Effective:
             July 11, 1973      July 1, 1975      July 1, 1978
Suspended Solids

Fecal Coliform
   (to Class B3 stream)

Residual Chlorine

PH

Oil and Grease
                30 mg/1

                30 mg/1

              500/100 mis
  25 mg/1

  25 mg/1

500/100 mis
  10 mg/1

  20 mg/1

500/100 mis
             Not less than 0.1 mg/1 and not more than 0.5 mg/1.

             Applicable Water Quality Standards  (6.0 - 9.0)

                10 mg/1            10 mg/1           10 mg/1
                             A-2

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                                       STEAMBOAT SPRINGS  REGIONAL SERVICES .AUTHORITY
                                                EFFLUENT  LIMITATION CRITERIA^ 1 >
CONSTITUENT
IRAW WATER
1 SUPPLY
NATURAL
BACKGROUND
LEVEL
2010
TREATMENT
PLANT /,
INFLUENT*
EFFLUENT LIMITATIONS
' '978 1983
1985
RATIONALE (CONTROLLING USE)
                   MAJOR
                              CRITERIA
CxvGE'l DEMAND
Biochemical
Oxygen Demand

Cit-iical Ox-
ygen Demand
Dissolved Ox-
ygen
SCUDS
Suspended Sol Id
Sett leable
Solids
Total Dissolved
Solids
PHYSICAL/CHEMICAL
PARAMETER
Temperature
pH
Turbidity
Color
Alkal inlty
Chlorl ne

MICROORGANISM
fecal Co! iform
. , ruses
ORGAN ICS
Pesticides
Phenols
Oils S Greases
MACRO NUTRIENTS
Ammoni a N
/Mu -Ml
\ wii -w j

















6.9


22.2 mg/l














3.06 mg/l




8.9 mg/l





1*7 1 mg/l



8.3
28 JTU




255/100 ml
70.6/100 ml






.07 mg/l

. rn f
168 mg/
(5'»32*')

219 mg/l
(7086#)



IU6 mg/l
' '2 '




















10 mg/l
(3SW

10 mg/1
(238 #)




6 "ntfn.

20 mg/l

.5 mg/l



20° C
maximum
6 - 9
20 JTU


.l-.Smg/


200/100 i






Varies
Monthly
2-9mg/l

10 mg/l
(238 #)


20 mg/l

6 my/ 1 m 1 n

10 mg/l

Free From
500 -
1.000 mg/l


+ 1C of amb
6.5 - 8.5
10% change li
Free From

.025 mg/l


I 200/100 ml

.01 96 HR
LC 50
.005 mg/l
.05 96 HR
LO 50

Varies
Monthly
2-9 mg/l


5 mg/l


10 mg/l

S mg/l mln

5 mg/l

Free From
500 -
1,000 mg/l


lent
6.5 - 8.5
C.P.
Free From
30 130 mg,
.025 mg/l


200/100 ml

.01 96 HR
LC 50
.001 mg/l
-L0 50 *

Varies
Monthly
0.5-9 mg/l
EP* requires minimum 85% removal. Discharge permit limit of 238 Ibs/day. County resolution limit of
10 mg/l for 1978. Permit limit controls effluent quality to less than 10 mg/l for first phase con-
struction. Non-point pollutants are additional. 5 ppm limitation for 1965 compatible with background
level and future population loads.

Compatible with BOD removal. Lower COD desirable

Minimum for cold water fishery. Stream standards and ant 1 degradation statement* required.
EPA requires minimum 85% removal. County resolution limit of 20 mg/l for 1978. 1963 end 1965
standards compatible with BOO removal. 1985 limitation agrees with NDCP.

1378 limitations based on State, County standards, 1983 and 1985 agrees with stream standards and NDCP.
TDS not critical. Major sources of TDS are area hot springs.
Parameter Involved with ammonia.


Stream standards require, critical parameter Involved wl th ammonia.
Stream standards require, critical parameter involved with ammonia, 1983 and 1965 values necessary
for NDCP, aquatic life and recreation waters.
1978 values based on Colomdo and County standards, 1983 and 1985 values for aquatic life.
Stream standards-
1 Fresh water wildlife.
1983 and 1985 value based on no decay loss In mixing and maximum .002 mg/l concentration for


EPA Standards.
Goal Is absence of viruses. No test data, but currently In effluent.

Aquatic Life.
Fresh water public supply, 1983 based on assimilative capacity, 1985 NDCP.


1985 values use extreme values of temperature. TDS and background level to insure very
low probability of toxic conditions to acquatlc life. See T--.;;t for monthly values.

>
w
(1)   Prepared by Wright-McLaughlin Engineers, April,  1976.
C2)   Assuming a 25% reduction in excess  infiltration  and inflow.

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                                                Tr-PLF V  (con't)
                                    STEAMBOAT SPRINGS REGIONAL  SERVICES  AUTHORITY
                                             EFFLUENT LIMITATION CRITERIA
CONST ITUFNT
RAW WATER
1 SUPPLY
NATURAL
BACKGROUND
LEVEL
2010 .
TREATMENT
PLANT /•, t
INFLUENT^ f

1978
EFFLUENT LIMITATIONS 1

198)
1985 '
RATIONALE (CONTROLLING
USE)
                       MINOR   CRITERIA
MACRO NUTRIENTS
Tola 1 Ni trogen
Organic N

Nitrate N
Phosphorous
Potassium
Sul fur (Sul fides
Calc t urn
Magnes 1 urn
MICRC NUTRIENTS
1 ron
Manganese
fioron
Zinc
Copper

Molybdenum
MtTALS
A lun i nuo
Lead
Mercury
Chromium
Cadmium
Nickel
Sodium I




.6 mg/l



5.7 mg/l
2.7 ms/l








> .01 mg/l
> .1 mg/l

> .01 mg/l

2> «g/l




.26 mg/l
.07 mg/l
.17 mg/l

110 mg/l
IS/ mg/l

.19 mg/l
ClAl mn/1
. u*+ i mg/ i









8.7

d mg/l
C»72#)



7 ma/I
f?*A4)
\*joff /


















10 mg/l



5 mg/l

.01 mg/

















10 mg/l


< 9.0 mg/l
5 mg/l

.002 mg/l



1.5 mg/l
.25 mg/l
5—fl/ 1
fng/ i
.015 •*& HR
LC 5S(2)
.5 96 to
LC 50
.05 mg/l


.15 mg/l
.001 mg/l
.15 mg/l
.02 mg/l
.1 mg/l


10 mg/l


< 9.0 mg/l
5 mg/l
.15 mg/l
.002 mg/l



.3 mg/l
.05 mg/l
1 mq/
.003 96
HR LC 50
O.I 96 HR
LC 50
.01 mg/l

5 mg/l
.03 mg/l
.0002 mg/l
.03 mg/l
.00*4 mg/l
.02 mg/l


As nitrates must be limited, Total N cannot be appreciably greater, alto see text.
Limitation involved with Total Nitrogen limitation, normal processes convert organic
to other nitrogen forms.
Drinking water standards.
Limitations based on dilution by streamflow that give reliable levels to maintain recreation
waters. See text.
NDCP, based on background level. . , .
Aquatic life, 1983 based on assimulative capacity, 1985 NDCP.' '
See alkal Inity.
See alkal Inity.

Fresh water public water supply, aquatic life, 1983 based on assimulative capacity
Fresh water supply, aquatic life, 1983 based on assimulative capacity, 1985 NDCP.
Aquatic life, 'O-3 based on assimulative capacity, 1985 NDCP.
Aquatic life, 1983 based on assimulative capacity, 1985 n'DCP, also for Livestock drinking water.

Limit for irrigation water, 1983 based on assimulative capacity, 1985 NDCP.

1985 limitation for agricultural
Aquatic life, 1983 based on assimulative capacity, 1985 NDCP.
Aqjatic life, 1983 based on assimulative capacity. 1985 NOCP
Aquatic life, 1983 based on assimulative capacity, 1985 NDCP.
Aquatic life, 1983 based on asslmulatlva capacity, 1985 NOCP. /'
Aquatic life, 1983 based on assimulative capacity, (985 NDCP.
See alkalinity.
(I)   NDCP  No Discharge of Critical Pollutants.
(2)   96 HR LC50   Median Lethal  Concentration - Concentration causes  death to 50% of a population  within 96 hours.
(3)   Assuming a  25% reduction in  excess infiltration and inflow.

-------
                                                                 TABLE IV
ui
                  PARAMETER
             Total Flow
             Total BOOr
             mg/1
             Total Suspended Solids
             mg/1
             Fecal Coli form
             no./100 ml
             pH Uni ts
             Total Residual
             Chlorine  mg/1
             Total BODr
             Ibs./day
             Oi1  and Grease
AGENCY

  SB
  SS
  MW
  SZ
  SB
  SS
  MW
  SZ
  SB
  SS
  MW
  SZ
  SB
  SS
  MW
  SZ
  SB
  SS
  MW
  SZ
  SB
  SS
  MW
  SZ
  SB
  SS

  MW
  SZ
  SB
  SS
  MW
  SZ
                                                       DISCHARGE PERMIT REQUIREMENTS -'-
                                                                      for
                                            SLEEPY  BEAR (SB), STEAMBOAT SPRINGS (SS), MT.  WERNER  (MW),  STEAMBOAT I I  (S2)
                                                Monitoring Schedule                  Average    Effluent   Concentration
FREQUENCY
Monthly
Weekly
Weekly
Weekly
Monthly
Quarterly
Quarterly
Monthly
Monthly
Quarterly
Quarterly
Monthly
Monthly
Quarterly
Quarterly
Monthly
Monthly
Weekly
Weekly
Weekly
Weekly
Dai ly
N/A
SAMPLE-TYPE
1 nstantaneous
Total

Continuous
Instantaneous
Grab
Compos i
Grab
Grab
Grab
Compos i
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
N/A

te



te













   30 CONSECUTIVE
     DAY PERIOD
                7  CONSECUTIVE
                  DAY  PERIOD
DAI LY
30
30
30
30
30
30
30
30
200
200
200
1000
shall
shall
shall
shall
N/A
N/A
N/A
45
45
45
45
45
45
45
45
400
400
400
1500
remain between 6.
remain between 6
remain between 6
remain between
0.5
N/A
0.5
N/A
60
N/A
N/A
N/A
60
N/A

N/A
N/A
N/A

.0 - 9.0
.5 - 8.5
.0 - 9-0
6.0 - 9.0
N/A
0.5
N/A
                                              Weekly    Grab
                                               Quarterly  Grab
                                               Monthly
                 (effect f-W>as soon as reasonable 5- practical,
                  but not later than Sept. 1, 1976)
                 (effective as soon as reasonable & practical,
                  but not later than July 1,  1977)
                 (effective immediately)
                (effective after July 1,  1977)
shall  not  exceed  10mg/l  in any grab & no visible sheen
                                         10.0
                        10.0
                       10.0
 3.0
 181

  37
13.64
                    ^SOURCE:
                       EPA  "Authorization  to  Discharge Under the National  Pollutant Discharge  Elimination System."

-------
                Appendix B - Contents on Draft EIS
             DEPARTMENT OF HEALTH, EDUCATION. AND WELFARE

                             REGION VIII

                         FEDERAL. OFFICE BUILDING

                         I9TH AND STOUT STREETS

                        DENVER. COLORADO  8O2O2
                          July 8,  1976
                                               OFFICE OF THE REGIONAL DIRECTOR
Mr. John A. Green
Regional Administrator
U.S. Environmental Protection  Agency
1860 Lincoln Street
Denver, Colorado  80203

Dear Mr. Green:

Thank you for the opportunity  to review the draft Environ-
mental Impact Statement  (EIS)  for the Steamboat Springs
Regional Service Authority  (Routt County,  Colorado.)

It appears that the impacts  expected to result from the pro-
posed project and reasonable alternatives  thereto have been
adequately addressed.
                               Sincerely yours,
                                ulon R.  Garfield
                               Regional  Director
cc: Office of Environmental Affairs,HEW
    Washington, D.C.

    Council on Environmental  Quality
    Washington, D.C.  (2 copies)
                             B-l

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                  Colorado-Ute Electric Association, Inc.
                                P. O. Box 1149
                            Montrose, Colorado 81401
                                                 July 16,  1976
Mr. John A. Green
Regional Administrator
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver,  Colorado 80203

Dear Mr.  Green:

             Steamboat Springs Regional Service Authority
             _ 201 Wastewater Facilities Plan _

      Colorado-Ute Electric Association, Inc.,  supports the action
proposed in the Draft Environmental Impact Statement concerning
the Steamboat Springs Regional Service Authority 201 Wastewater
Facilities Plan.

      Colorado-Ute has two steam -electric generating stations
downstream from  the proposed action.  The two-unit Hayden Station
(one unit operating,  one unit in a start-up mode) in western Routt
County will withdraw (when both units are operational)  11,800 acre-
feet of water per  year from the Yampa River five miles east of Hayden.
The two -unit Craig Station (under construction) in Moffat County will
require  18,720 acre-feet of water per year from the Yampa River to be
taken four miles downstream from Craig.

      Since intake water quality  has a direct effect on the operation of
electric generating stations, Colorado-Ute strongly supports the Steam
boat Springs Regional Authority's efforts to improve the Yampa River
water quality -

                                   •Very truly yours ,
                                   John JyBugas
                                   President
JJB-JAW:ke

cc:   G. Krumins
      R. W. Bryant
                                  B-2

-------
                         DEPARTMENT OF THE  ARMY
                      SACRAMENTO DISTRICT. CORPS OF ENGINEERS
                                 65O CAPITOL MALL
                           SACRAMENTO, CALIFORNIA   95814
           X 11 PL Y TO

           ATTENTION OF
SPKED-W                                                           22  July 1976
Regional Administrator
U.S. Environmental Protection Agency
Region VII
1860 Lincoln Street
Denver, CO  80203
Dear Sir:

This is in response to your recent letter requesting review  and  comment  on the
Draft Environmental Impact Statement  (EIS) for the  "Steamboat  Springs  Regional
Service Authority, 201 Wastewater Facilities Plan."

Apparently, the proposed plan would include crossing the Yampa River at  one or
more locations.  Details of these crossings are not presented; however,  it is
suggested that these crossings be designed to pass  floodflows  and  to include
sufficient backfill and riprap protection to preclude possible flood damage to
facilities.  Also, a Department of the Army permit under Section 404 of  the
Federal Water Pollution Control Act Amendments of 1972 may be  required from
this office if the proposed project includes discharge of dredged  or fill
material in waterways.

Thank you for the opportunity to review the draft EIS.

                                         Sincerely yours,
                                              SE C. WEDDELL
                                         Chief, Engineering Division
                                         B-3

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           DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE

                          PUBLIC HEALTH SERVICE

                         CENTER FOR DISEASE CONTROL


                                                     BUREAU OF LABORATORIES
                            July 26, 1976          VECTOR-BORNE DISEASES DIVISION
                                                       POST OFFICE BOX 2087
                                                   FORT COLLINS, COLORADO 80522
Mr. John A. Green
Regional Administrator
U.S. Environmental Protection Agency
Region VIII
1860 Lincoln Street
Denver, Colorado  80203

Dear Mr. Green:

Thank you for providing us with a copy of the draft environmental impact
statement  (EIS) for the "Steamboat Springs Regional Service Authority
201 Wastewater Facilities Plan" and for inviting our comments.

Vfe note that Alternatives II and IV eliminate tertiary in-plant treatment
and, instead, entail application of the disinfected effluent in a land
treatment program designed to use the land as a natural filter medium.
Vfe also note that the Environmental Protection Agency  (EPA) recommends
the approach of Alternatives II and IV for the Steamboat Springs study
area  (page 11 of draft EIS).  It is these two alternatives that are of
concern to us with regard to the production of mosquito species which
may transmit disease.

The association of mosquitoes with areas irrigated with sewage wastewater,
as proposed in Alternatives II and IV, is well documented elsewhere
 (Zimmerman and Newson, 1975, Proc. 62nd Ann. Meet. New Jersey Mosquito
Control Assn., pp. 154-155).  Vfe also have received reports from mosquito
abatement personnel in Marin County, California, which indicate that EPA
subvention for wastewater treatment has exacerbated existing mosquito
problems as a result of land application of wastewater.  Mosquitoes may
develop and emerge from water which stands for 48 hours or longer.  The
exact developmental time is affected by temperature and the availability
of nutrients in the water.  Certainly, sewage effluent rich in organic
matter is a highly favorable medium for mosquito production; particularly
so when applied to pasture or other grassy areas.

Mosquitoes of particular concern which occur in the Steamboat Springs
area and which favor the type of breeding habitat just described include
Culex tarsalis and Aedes dorsalis.  The former species is the principal
vector of western equine encephalitis  (WEE) and St. Louis encephalitis
 (SLE) viruses in the western United States, and A. dorsalis also may be
                                   B-4

-------
Mr. John A. Green
July 26, 1976
Page 2
involved in the transmission of WEE in some areas.  Both viruses are the
cause of morbidity and mortality among humans in Colorado, and WEE virus
also causes encephalitis in horses.  For example, during 1975 there were
17 cases of WEE and 3 cases of SLE in humans in Colorado, and approxi-
mately 250 cases of WEE in horses in the state.  These diseases do not
occur in the absence of vector mosquitoes; therefore, the creation or
expansion of breeding habitats for these mosquitoes must be viewed with
concern.

In the event that sewage wastewater is used for a land treatment program
in the Steamboat Springs area, we urge that appropriate measures be taken
to assure that vector mosquito breeding habitats will not be created or
expanded.  Such measures would include  (1) land preparation of treatment
areas to eliminate low spots which would allow ponding of water,  (2) ade-
quate drainage of treatment areas and controlled application of water to
prevent water from standing for more than 48 hours, and  (3) a surveillance
system for mosquito production so that remedial action can be taken if
required.

We appreciate being afforded the opportunity to comment on this project
and would appreciate receiving further drafts and a copy of the final
environmental impact statement.

                                   Sincerely yours,
                                   Richard 0. Hayes, Ph.D., M.P.H.
                                   Chief, Water Resources Branch
cc:
Mr. Ted Davis
                                   B-5

-------
                FEDERAL ENERGY ADMINISTRATION
                            REGION VIII
                           1075 South Yukon
                       P.O. Box 26247, Bolmai Branch
                        Lakewood, Colorado 80226

                           July 27, 1976
Mr. John A. Green
Regional Administrator
Environmental Protection Agency
Region VIII
1860 Lincoln Street
Denver, Colorado  80203

Dear Jack:

The F.E.A. Regional Office has reviewed the Draft Environmental
Impact Statement  (DES) on the Steamboat Springs Regional Service
Authority - 201 Wastewater Facilities Plan, in accordance with
your letter received June 21, 1976.  The F.E.A. would like to submit
the following comments for your consideration:

    1)  Table II  on page 18 mentions the goals and policies of the
Steamboat Citizens Advisory Committee.  These standards seem rather
unrealistic when  one considers that the water qualities measured at
the Milner and Oak Creek Station consistently violate Colorado
standards for B-|  streams.  The policies and goals on page 18 seem
to point toward an Ai environment, which brings up the following
question.  Even though the proposal is badly needed, will Colorado
A] standards be obtainable at the Milner station after the project's
completion?

    2)  It is apparent that natural sources are discharging 24 tons
of salt per day from the mineral springs around Steamboat.  Although
this does not directly relate to the sewage disposal projects, it
would be beneficial if this water was treated to remove excessive
salts.  Is this under consideration?

Aside from the above general questions, it is obvious the wastewater
plan is badly needed and worthy of immediate attention.

Thank you for giving us the opportunity to review and comment on this
most worthy and vital project.

                                  Very sincerely yours,
                                  Dudley E. Faver
                                  Regional Administrator
cc:  Mr. Robert Stern, NFEA


                                 B-6

-------
            UNITED STATES DEPARTMENT OF AGRICULTURE
                        FOREST SERVICE

                      11177 West 8th Avenue
                        P.O. Box 25127
                     Lakewood, Colorado 80225
                                                              8420
                                                    August 4, 1976
John A. Green, Regional Administrator
U. S. Environmental Protection  Agency
1860 Lincoln Street
Denver, Colorado  80203

Dear Mr. Green:
Thank you for the opportunity  to  review the Draft Environmental
Statement for the Steamboat  Springs  Regional  Service Authority,
201 Wastewater Facilities Plan.

Although the project does not  directly  affect National  Forest
lands, secondary effects may include the need for additional
domestic water storage brought on by additional  growth  in the
Steamboat Springs area.  An  efficient waste water treatment plant
would allow for growth.

We concur with the recommended plan  and support  the land treatment
measure.  The latter would be  especially desirable if feasible
for strip mine spoil reclamation.

Sincerely,
S. H. HANKS
Deputy Regional Forester,  Resources
                              B-7
                                                                6200-11 (1/69)

-------
                    United States Department  of the Interior
                               OFFICE OF THE SECRETARY
                                  MISSOURI BASIN REGION
                                 DENVER, COLORADO  80225
In Reply Refer To                                      .
   ER 76/615                                          MG ° 4 '976
           John A. Green, Regional Administrator
           Environmental Protection Agency - Region VIII
           1860 Lincoln Street
           Denver, Colorado  80203

           Dear Mr. Green:

           Following are consolidated comments on the draft  environmental  state-
           ment for Steamboat Springs Regional Service Authority,  Routt  County;
           Colorado, based on reviews by the Bureau of Land  Management,  National
           Park Service, Bureau of Outdoor Recreation, Fish  and Wildlife Service,
           Geological Survey, and the Bureau of Reclamation.

                                     General Comments

           The proposals examined in the above draft environmental statement
           would involve very little of the Bureau of Land Management's  legal
           jurisdiction or special expertise.

           No established or studied units of the National Park System appear
           to be adversely affected by the plan.  Neither does the plan  appear
           to adversely affect any site registered as a National Historic, Natural
           or Environmental Education Landmark, or any site  listed as eligible  for
           such registration.

           The statement should reflect consultation with the National Register
           of Historic Places, and discuss whether any National Register proper-
           ties will be affected.  If the plan has an effect on a  National Regis-
           ter listing, the statement should reflect further compliance  with
           Section 106 of the National Historic Preservation Act of 1966 (P. L.
           89-665).

           The draft statement does not clearly confirm consultation with  the
           Colorado State Historic Preservation Officer, who is Mr.  Stephen H.
           Hart, Chairman, State Historical Society, Colorado State Museum, 200
           14th Avenue, Denver, Colorado  80203.  The final  environmental  state-
           ment should reflect that he was consulted to determine  whether  the
           plan will affect any cultural site that may be in the process of
           nomination to the National Register, and it should also contain a
           copy of his reply.
                                          B-8

-------
Ltr. to John Green, EPA, Denver, Colo., Subj:  Review of DES for
Steamboat Springs Regional Service Authority, Routt County, Colo.
(ER 76/615)
The statement does not adequately provide consideration for cultural
resources that may be affected by the proposed wastewater treatment
facility.  In order to correct this situation, the Colorado State
Archeologist (Dr. Bruce Rippeteau, Department of Anthropology, Uni-
versity of Colorado, Boulder, Colorado 80304) should be consulted
regarding the need for an archeological survey that will comply with
the letter and spirit of Executive Order 11593 and the National
Environmental Policy Act of 1970.  Results of such a survey should
be provided in the final statement along with any recommendations
for mitigative measures.  Provision should be made for immediate
work stoppage in the event previously unknown archeological resources
should be discovered in the course of the project to insure proper
professional review of such resources and proper mitigative action.

Aquatic wildlife resources within the project area are adequately
discussed.  The awareness of potential impacts that the proposed
action will have on endangered fishes and the recognition of a need
for strict effluent water quality standards to insure their continued
survival are commendable.

Terrestrial wildlife resources, as discussed in the draft environmental
statement, are quite general.  It is suggested that an inventory of
terrestrial wildlife currently inhabiting the construction site be
included in the final environmental statement.  Assessments of impacts
on fish and wildlife resources during construction phases of the proj-
ect should also be included.

It is recommended that the statement describe the current recreational
use of the Yampa River as well as the potential of this project to
enhance such use.  In addition, the present collection system, together
with proposed interceptors and outfall lines for each alternative,
should be mapped and the trail potential of the associated rights-of-way
examined in the final environmental statement.

                          Specific Comments

Page 68 - Table XX; correct scientific names:

          Humpback chub      - Gila cypha
          Bonytail chub      - Gila elegans
          Colorado squawfish - Ptychocheilus lucius
                                  2

                                 B-9

-------
Ltr. to John Green, EPA, Denver, Colo., Subj:  Review of DBS for
Steamboat Springs Regional Service Authority, Routt County, Colo.
(ER 76/615)
Page 69 - Rare and Endangered Species

          The greater sandhill crane and the Colorado
          Cutthroat trout, though not on the United
          States' List of Endangered Fauna, are on
          Colorado's State List of Threatened and
          Endangered Wildlife.

          For clarification, species appearing on
          Colorado's State Endangered List and the
          United States' Endangered List should be
          separated.

We appreciate the opportunity to review this draft environmental
statement and hope our comments will be helpful to you.

                                  Sincerely yours,
                                   pecial Assistant
                                  to the Secretary
In duplicate
                                 3
                               B-10

-------
 ROUTT COUNTY REGIONAL PLANNING COMMISSION
                                       August 4, 1976
       Mr. John A.  Green,
       Administrator - Region VIII
       Environmental Protection Agency
       1860 Lincoln
       Denver, Colorado  80203
                                            Re: Steamboat Springs  201
                                            Environmental Impact Statement
        Dear Sir:
        The Routt County Regional Planning Commission has reviewed the Draft EIS,
        Steamboat Springs Regional Service Authority, 201 Wastewater Facilities
        Plan and submits the following comments:

        1.     On Page  ii there is a statement which says that the Yampa River is
              in poor  condition due to upstream bank erosion, among other reasons.
              This broad statement implies improper agricultural practices up-
              stream,  and is not substantiated within the  study.  The Commission
              unanimously passed the following motion:

              Mr. de Ganahl moved to direct the Staff to write a letter to be
              submitted to the Environmental Protection Agency requesting that the
              scope of the Environmental Impact Statement  be strictly limited to
              the effects of sewage effluent and urban non-point runoff in the
              Yampa River.  Mr. Hufstetler seconded the motion, which carried
              unanimously.

        2.     Land treatment may be a viable alternative.  However, neither the
              study nor the consultant provided data to support the fact that
              land to  be provided for this use could absorb the effluent loads
              proposed rather than have the soil saturated with subsequent
              surface  runoff or that the amount of effluent would be satisfactory
              for productive agricultural purposes.

        3.     A statement is made that the growing season  in the proposed area is
              90-100 days (p.11).  The Colorado Agricultural Handbook states that
              the normal growing season is 59 days for Steamboat Springs.  Further
              clarification of this statement is necessary.  Also, if a crop, such
              as hay,  is to be harvested, the actual number of days land application
              is done  should be reduced to enable this harvesting.
>.O.  BOX  9017 STEAMBOAT  SPRINGS, COLOR A DO , 80477  TEL.  879-270'
                                          B~

-------
Environmental Protection Agency                            August 4, 1976
4.     References to the fact that there is no adopted Comprehensive Plan
       for Routt County are not entirely correct.  There is an adopted
       land use plan for the West Steamboat Area, and there has been
       adopted a statement of Comprehensive Plan Policy for the entire
       County.  The West Steamboat Plan includes most of the area under
       consideration for location of the Regional Wastewater Facility.

5.     Among reasons given to support statements that the present Steamboat
       Springs treatment facility location is not acceptable are that it
       is in a floodplain and would have to be floodproofed, which is
       correct.  The statement continues  by  implying that residential
       development of the'area will continue.  Both the West Steamboat Land
       Use Plan  and the study recognize only the residential development
       which now exists and suggests that additional adjacent development
       be industrial in nature.  Also, additional residential development
       within a recognized floodplain is not desirable.  Industrial-type
       development can be compatible with wastewater treatment plants.
       Industrial uses may also be desirable at this location because of
       the existing approach pattern to the Routt County STOL Airport.

       Statements within the study also indicate that the present plant is
       not causing problems for the adjacent development.  This development
       commenced after the treatment plant went into operation. A new or
       expanded  facility, treating wastewater at 1983 standards should be
       no more objectionable than the existing facility.

6.     Population projections may or may not be adequate.  Peak population
       was averaged for the high thirty-day period.  This possibly should
       have been done for the peak day situation.  Also, it is doubted that
       an increase in coal development in the area will cause a corresponding
       decrease in recreational population.

7.     Financial capability of some of the entities to be included in this
       project is highly suspect.  Before total commitment to an expensive
       wastewater solution is made, additional fiscal study and agreement
       is necessary.

8.     In addition to the West Steamboat Plan and the Comprehensive Plan
       Statement of Policy, the Commission approved the following motion:

       Mr. Sprengle moved that the Routt County Regional Planning Commission
       resolve that the location of sewage facilities will not be allowed to
       influence growth contrary to its plans.  Mr. de Ganahl seconded, and
       the motion carried unanimously.
                                     B-12

-------
                                       -3-
Environmental Protection Agency
August 4, 1976
9.     The Commission made no motion to either support or deny the recommended
       alternative Number IV.

                                        Sincerely,

                                        ROUTT COUNTY REGIONAL
                                        PLANNING COMMISSION
                                       /••L-"
                                        Daniel R. Ellison,
                                        Planning Administrator
DRE/kw
                                    B-13

-------
               U.S. DEPARTMENT OF TRANSPORTATION
                    FEDERAL HIGHWAY ADMINISTRATION
                              REGION EIGHT
  Mr. John A. Green                                              August  6,  1976
• Regional Administrator, Region VIII                             IN REPLY REFER TO:
  U.S. Environmental Protection Agency                              08-00.21
  1860 Lincoln
  Denver, CO  80203
  Dear Mr.  Green:

  Our office appreciates the opportunity to  review  the Draft Environmental
  Impact Statement on Steamboat Springs  Regional Service Authority, 201
  Waste Water Facilities Plan.

  This proposed development will have no significant  impact on the State
  Highway System.   We have no other comments to offer.

                                    Sincerely yours,
                                    F.  S.  Allison
                                   B-14

-------
                 United States Department of the  Interior
IN REPLY KEKEK TO-
               GEOLOGICAL SURVEY
                    Box L^lMti
                Denver Federal Centej
               Denver, Colorado 8022V
                 Mail Stop #415
                                   August 9,  1976
                                                    Water, ^sources Division
       Memorandum

       To:


       From:

       Subject:
Regional Administrator, U.S. Environmental Protection Agency
Region VIII, 1860 Lincoln Street, Denver, Colorado 80203

Timothy D. Steele, WRD, Lakewood, Colorado

Steamboat Springs Regional Service (Routt County, Colorado)
Authority 201 Waste-water Facilities Plan — Draft Environ-
mental Impact Statement (EIS) Review Comments
        Attached are detailed technical and editorial comments on the subject
        draft report prepared for EPA by Weiner and Associates of Denver,
        Colorado.   It would be appreciated if these comments could be given
        consideration in preparation of the final EIS for this facility plant.
        If any specific questions are raised regarding any of the comments, do
        not hesitate to give me a call.
                                             Timothy D.  Steele
        Attachments
             Ron Pifer
             Weiner and Assoc.,  Inc.
             Ron Eddy,  Environmental  Protection  Agency
                                          B-15

-------
          STEAMBOAT SPRINGS REGIONAL SERVICE AUTHORITY 201

                      WASTE-WATER FACILITIES PLAN

               REVIEW COMMENTS BY U.S. GEOLOGICAL SURVEY

                      (Compiled by T. D. Steele)

     1.  Page 2, last paragraph.—The Northwest Colorado Coal EIS Report
has been prepared jointly by personnel of the U.S. Bureau of Land
Management and the U.S. Geological Survey.

     2.  Page 4, first paragraph.—More supporting evidence is needed
to characterize the Yampa River as "poor to fair".  Site the reference
indicating that the Yampa River is "one of the poorest trout streams
in the Colorado mainstem".  This condition could be due to the heavy
fishing demands or. long-term ambient conditions rather than the implied
adverse human-induced impacts on water quality.  Although heavy "silt"
deposits may be noted along mainstem banks during low flows, these most
often are removed each year by scouring during high flows due to snow-
melt in the spring.

     3.  Page 5, second paragraph.—".  .  . additional facilities for
treatment of organic matter  (biochemical oxygen demand—BOD) and
suspended sediment found in domestic and municipal waste."

     4.  Page 5, last paragraph.—Clarify the  term "flow leveling".

     5.  Page 7, paragraph on alternative II.—One might disagree with
the second sentence.  Ammonia tox'icity may likely increase below 5 C
due to cold stress on fish.  Winter periods may be equally as critical
as summer months.

     6.  Page 7, paragraph on no-action alternative.—Could the existing
5 treatment facilities not be brought into compliance with the water-
quality standards?  True, the economy scale and modes of operation must
be considered, but the inference of the sentence  is misleading.

     7.  Page 10, Treatment Options, first paragraph.—Seasonal loadings
are much higher in the winter months.  Has the land-treatment option been
discounted entirely for the winter period?

     8.  Pages  13 to  14.—The range of present-value capital costs is
relatively small (plus or minus 8 percent).  How  much uncertainty  is
inherent in these figures?  Has EPA officially  (explicitly) supporter
a preference for alternative IV?   (See recommended action).  State some
of the "additional material" needed.

     9.  Page 21, table 3.—If the 7-day, 10-year low-flow statistic is
computed by monthly rather than annual  increments, it should be stated
explicitly and another term should be used.
                                  B-16

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     10.  Page 22, 3rd paragraph.—The U.S. Geological  Survey  surface-
water record for the Yampa River site at Steamboat  Springs  (station
09239500) began in October 1904.  The published  record  has  not been
continuous to present; the 67-year period of  record  sites is actually
for the  1905-06 and 1910-74 water years.

     11.  Page 23, figure 3.—Because monthly mean  flows are shown,
a monthly bar-graph would be preferred over a continuous hydrograph.

     12.  Pages 23-24.—Recall comment on page 21 with  regard  to  Q    -
definition.  It would seem that apples and oranges  are  being compared
here.

     13.  Page 24, second paragraph.—A need  is  indicated here for a
regional analysis of low-flow characteristics.   Studies by  Tuthill
(1975),  University of Colorado, M.S.  thesis,  and  the USGS  (Livingston,
1970, open-file report) should be cited and considered  here.

     14.  Page 26, first paragraph.—The term "data" is plural.   Cite
reference to USGS Open-File Reports 76-367, and  76-368.  The USGS had
primary  responsibility for design and execution  of  the  data-collection
program.  The data collected for the  Waste-Assimilative Capacity
Analysis, in part shown in table VIII were applied  to further  analysis
and evaluation using two operational  water-quality  models  (Bauer  and
others,  1976, in review).

     15.  Page 28, Table VII.—The indicated  source  of  data in this
table is hard to read.  Should give specific  station number and/or
location.

     16.  Page 29, third paragraph.—"chemical conditions"—need  to be
more specific; water hardness is a critical factor.

     17.  Page 29, third paragraph.—See comments for page  26,  first
paragraph.  Often only one measurement was made,  so  the "maximum-
minimum" designation is a misnomer.

     18.  Page 29, fifth paragraph.—Some big assumptions are  being made
here.   The effects of the nearby sulfur springs  should  not  be  under-
estimated.   (R. E. Moran, USGS, oral  commun., 1976).  Specific conductance
of cold  springs  (estimated 40-50 gallons per  minute  flows)  has been
measured at 7,500 micromhos per centimeter.   Specific conductance of
hot springs is estimated at  1450 micromhos per centimeter at 250  gallons
per minute.
                                   B-17

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     19.  Pago 30, Table VIII.—In the course of modeling application
by USGS, some adjustments to the data shown here were mnde.  For example,
it is now felt that sampling site YM-5 (Y5 in your table) is non-
representative of the total cross-section of the mainstem stream, so
that too high an influence from the Steamboat Springs sewage-treatment
plant effluent is reflected in the observed data (See D. P. Bauer and
others, 1976, in review).  We would prefer that the station code
designations set by the USGS be maintained throughout the report in
order to expedite cross-referencing.

     20.  Page 31, first paragraph.—Ongoing USGS work by Brogden and
Giles should be cited if their reports are in final published form.

     21.  Page 34, first paragraph, last sentence,—"data collected
by U.S. Geological Survey and Colorado Department of Health presented
in Tables VIII and )( respectively, show that .  . . ."

     22.  Page 33, last paragraph, last sentence.—This does not agree
with .Northwest Colorado Coal EIS Report which gives a plant design
capacity of 650,000 gpd.

     23.  Page 34, fourth paragraph.—Stated design capacity does not
agree with that given in Northwest Colorado Coal EIS (65,000 gpd).
Note the typo in line 6  ("is" instead of "if").

     24.  Page 37, second paragraph, line 2.—Note typo "one" instead
of "on".

     25.  Page 40, last paragraph.—How "extensive" have the Wright-
McLaughlin investigations been?  Cite references and summarize results.

     26.  Page 41, Table XI.—To what extent are agricultural return
flows accounted for in this summary?

     27.  Page 41, second paragraph.—More recent samplings of mineral
springs should be noted  (See comment item 18 above).  Do odors from
springs "provide a natural esthetic asset"?

     28.  Page 46.—Technical and economic impacts of water infiltra-
tion losses cannot be emphasized enough.

     29.  Page 60, Aquatic section, first paragraph.—Reference  should
be made to the work by EPA (Ron Eddy, 1976, in  review), and CSU
(Libby Ames, Department of Zoology and Entomology, 1976).  These
studies would take issue with the "poor" catagorization regarding  the
Yampa River ecological health.  References are  needed for each category:
(1) aquatic plants, (2) insects, and (3) fish.  The recent EPA study
did show decreases in diversity below point-source discharges, but
total number of organisims did not follow a similar trend.
                                3
                               B-18

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     30.  Page 60, last paragraph.—Cite specific references to detri-
mental "chemical and physical conditions".  Up to this point only the
possible suspended-sediment physical limitation has been mentioned.
The matter of effects of year-round variations in sediment loadings
on spawning has not heen addressed.  Possible lack of spawning areas
and sedimentation may be more significant factors in reducing trout
populations than reduced insect population,

     31.  Page 62, first paragraph.—"poor" classification of stream
area II needs further clarification.  Up to now it has not been noted
that food for trout is scarce.

     32.  Page 62, second paragraph.—Describe what is meant by
"humanly-induced disturbances".

     33.  Page 62, third paragraph.—Diatoms are also algae.

     34.  Page 62, fourth paragraph and table XVII (page 63).—See
page 30, Table VIII note.  Suggest preserving YM, YT, and YE designations
(See table 2 of USGS Open-File Report 76-367).  Line 5—substitute
term "algae" for "plants".  The two diatoms and blue-green alga also
were found at USGS sampling site Y-71 (Yampa River above Oak Creek)
during  the August-September reconnaissance survey.  Biomass was 8.2
grams per square meter dry and 0.6 grams per square meter ash.

     35.  Page 62, fifth paragraph, first sentence.—"Other sites also
have been sampled by the USGS."   (Omit rest of sentence as written).

     36.  Page 63, Table XVII.—Note changes in footnote designation
on attached revised sheet:                      r-       0 equals observed;
not actually accounted, E equals estimated; not actually counted.
"Melosira" is misspelled.

     37.  Page 64, Table XVIII.—Suggested revisions:  (1) Note USGS
source  of data; (2) omit date designation (see previous comment);
(3) maintain YM code designations to avoid confusion with USGS
reconnaissance survey data; (4) data appear to be contrary to text,
in that biomass is higher upstream from Steamboat Springs.

     38.  Page 65, first paragraph, line 2.—"combined density" don't
think one can simply combine a_ + b_,

     39.  Page 65, third paragraph, sentence 3.—This was also the
case at site Y-71 (Yampa River above Oak Creek) upstream from Steamboat
Springs.

     40.  Page 65, fourth paragraph, line 8.—The use of indicator
organisims has a large degree of uncertainity at the generic level,
let alone the family level.
                                 4
                                B-19

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     41.  Page 65, fifth paragraph, last sentence,—This inference is
very dependant upon the types of organisims that are increased.  If
the number per square meter are increased with nothing but chironomids
it is doubtful that the carrying capacity would increase.

     42.  Page 65, last three paragraphs.—Study-report inferences
are based upon results on samples collected at one point in time using
a technique (Surber) many biologists would refute.

     43.  Page 66, Table XIX.--It should be noted that USGS data for
number per square feet differ greatly with EPA results (Ron Eddy,
oral communication, 1976) .  This discrepancy may be due primarily to
the smaller mesh size used by USGS.  Without this inter-comparison and
related discussion, perhaps utility of this tabular summary is minimal.

     44.  Page 67, paragraph 3, last sentence.—Suggest that the last
sentence be omitted.  Is the inference that other fish species also are
doing poorly?  (See also paragraph 4, first sentence).

     45.  Page 67, fourth paragraph.—Last two sentences in paragraph
should be referenced.

     46.  Page 68, Table XX.—Cite data source in this table.  Who
established the population status designation?  Does Colorado Fish and
Game have more specific data on relative abundance of indigenous
species?

     47.  Page 76, paragraph 3, first sentence.—See comment item 1
above regarding preparation of Northwest Colorado Coal EIS Report.
BLM was lead agency but numerous USGS personnel collaborated in prepara-
tion of the report.

     48.  Page 81, last paragraph.—Begin first sentence with "It is
our opinion that  . .  . .".

     49.  Page 84, second paragraph.—Implications of use of "peak
season" population figures relative to the "peak day" or "peak week"
values needs to be discussed in greater detail, particularly as to its
effects on design of waste-water treatment facilities.

     50.  Page 84, third paragraph, last sentence,—Numerous reservoirs
have been proposed for construction in the Yampa River basin other than
those by the U.S. Bureau of Reclamation,

     51.  Page 87, fourth paragraph, first sentence.—Define "semi-
public" lands.

     52.  Page 99, Table at bottom of page,—Spell out units of measure-
ment (dB = decibel?).  What is meant by "(A)"?

     53.  Page 100, third paragraph.—What part of Routt County is 171
miles from Denver?  Is this road or air miles?

                                 5
                                B-20

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     54.  Pages 104 to 105.—Several non-Federal Projects are described
in this section.  No mention was made of the Lake Catamount develop-
ment which potentially has significant quantity and quality implications
on the Yampa River waters flowing into the Steamboat Springs area.
Also, the proposed Oak Creek Power Project has major water-development
components impacting upon the water resources of the study area.

     55.  Pages 129-130.—Ground water-surface water interactions in
the study area reach of the Yampa River need to be considered, both
from a physical and legalistic standpoint.

     56.  Page 143.—This section is quite general.  Long-term water-
quality effects should be discussed in some detail.

     57.  Pages 149-153.—The following references should be considered
for inclusion:

     Livingston, R. K., 1970, Evaluation of streamflow data program
          in Colorado:  U.S. Geol. Survey Open-File Report, 72 p.

     Steele, T. D., Bauer, D. P., Wentz, D. A., and Warner, J. W.,
          1976, An environmental assessment of impacts of coal develop-
          ment on  the water resources of the Yampa River Basin, Colorado
          and Wyoming—Phase-I Work Plan:  U.S. Geol. Survey Open-File
          Report 76-367, May 1976, 17 p,

     Steele, T. D., James, I. C. II., Bauer, D. P., and others, 1976,
          An environmental assessment of impacts of coal development
          on the water resources of the Yampa River Basin, Colorado
          and Wyoming—Phase-II Work Plan:  U.S. Geol Survey Open-File
          Report 76-368, May 1976, 33 p.

     Tuthill, D. R. Jr.,  1975, Low-flow quantity analysis for mountain
          tributaries—the Yampa River Basin:   Colorado University
          unpublished M.S. thesis, 73 p.

Attachments
   p. 63, table XVII
   p. 64, table XVIII
TDS 8/9/76
                                 6
                                B-21

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UNITED STATES DEPARTMENT OF AGRICULTURE

SOIL CONSERVATION SERVICE
      P-  0.  Box 17107,  Denver,  Colorado 80217


                                                           August  9, 1976
     Mr. John A.  Green
     Regional Administrator
     U. S.  Environmental Protection Agency
     Region VIII
     1860 Lincoln Street
     Denver,  Colorado 80203
      Dear Mr.  Green:
     We have reviewed the draft environmental  impact statement for the Steamboat
     Springs, Colorado,  Regional Service Authority-201 Wastewater Facilities Plan.

     We have the following comments:

     1.   Page 58,  Soils;

          a.   We believe  the description of  the soil resource in this section is
              inadequate  and should be strengthened in the final EIS.  We suggest
              a soil map  of the project area be included in the final EIS.

          b.   Charles  A.  Hogelin is the SCS  District Conservationist at Steamboat
              Springs. We suggest this correction be made in the final EIS.

          c.   It is apparent that Wright-Mclaughlin Engineers misunderstood the
              information provided them by SCS  concerning the land capability
              classification system.

              According to the SCS land capability system, the term "cultivation
              or land  suitable for cultivation" is referring to cultivated crops
              such as  wheat or other row-crops  grown on cropland.   (Land Use
              Capability  Class I-IV.)

              Non-cultivated crops we  defined as permanent pasture, hayland and
              rangeland.   (Capability  Classes V-VIII.)

              (Two pamphlets are enclosed to further explain the SCS Land Capabil-
              ity Classification System.)

              As a result of the above misinterpretation of resource data by Wright-
              Mclaughlin  Engineers, we believe  the following sentences should be
              deleted  from the final EIS:
                                     B-22

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        "However, these soils are currently being cultivated and have been
        cultivated for many years.  Because of this disparity, Wright-
        Mclaughlin Engineers asked the SCS for an explanation.  They were
        told that the current classification is based on the soil temperatures
        for growing corn.  Yet, corn is not grown on these soils along the
        Yampa Valley.

        However, due to the rationale for developing these ratings, they are
        not deemed as sufficient evaluations for the land treatment altern-
        atives proposed for the SSRSA."

2.  Pages 10 and 122:

    Installation of an "underdrain system" is mentioned as a construction
    to lower the high water table to facilitate large amounts of wastewater
    application.

    However, the location, size, and environmental impact of the proposed
    "underdrain" is not discussed in the draft EIS.  Therefore, we believe
    that final EIS should address this topic in greater detail.

3.  Page 122; Wastewater Application;

    a.  We believe the final EIS should address the potential surface run-
        off of effluent which may occur when the rate of wastewater applica-
        tion approaches 7 acre-feet per acre per year.

    b.  What is the infiltration rate of the soils located at the proposed
        site, with and without, the "underdrain system"?

    c.  We believe the final EIS should further evaluate the statement that
        Reed Canarygrass may need supplemental fertilization, even if 63-147
        pounds of nitrogen per acre per year are applied by the effluent.
        We believe the 300 pounds of nitrogen, uptake (per acre per year)  by
        reed canarygrass represents a maximum level of nitrogen uptake.
        Reed canarygrass will grow quite satisfactorily on lesser rates of
        nitrogen.

4.  Page 123:

    We suggest the final EIS include the source of the information listed
    in Table XXIV.

5.  Page 122-127:

    It appears the rate of wastewater application is correlated to the
    amount of nitrogen shich can be applied without adverse effects.

    We suggest the final EIS evaluate other limiting factors of land appli-
    cation of effluent; such as, soil infiltration, toxic levels of micro-
    nutrients, and the slow rate of nutrient uptake during spring and fall
    which further shortens an already limited growing season.

                               B-23

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6.  Page 130; Soils:

    We suggest the potential accelerated soil erosion which may occur during
    and after construction be recognized as an adverse impact in the final
    EIS.

7.  Page 140; Water Quality:

    We suggest the Routt County Soil Conservation District be added to the
    final EIS as a unit of state government, which provides assistance to
    landowners in reducing non-point source pollution.

8.  We believe the final EIS should specifically address the following
    items:

    a.  Will the project include provisions for controlling soil erosion
        during construction?

    b.  Will sediment basins, mulching critical erosion areas, etc., be
        utilized during construction to minimize downstream sedimentation?

    c.  Are there provisions for stockpiling topsoil during construction
        for later use in revegetation work?

    d.  Discuss the erosion control measures that will be used to control
        soil erosion after construction activities are completed.

    e.  Quantify the area that will be affected by accelerated soil erosion
        and discuss the environmental impacts caused by the resulting down-
        stream sedimentation.

9.  Page 147, Table XXVII:

    This table includes the item, Land Treatment Credit (sale of crops).

    We did not find any mention in the other sections of the draft EIS con-
    cerning the harvesting of crops from the effluent application areas.

    Therefore, we suggest this topic be discussed throughout the various
    sections of the EIS.  Specifically, we believe the final EIS should
    address the following items concerning this topic:

    a.  When will the crops be harvested?

    b.  What will be the method of harvesting?
                                B-24

-------
    c.  Will the harvesting interrupt the application of effluent?  If so,
        how will this affect the amount of effluent that can be applied
        during the growing season?

Thank you for the opportunity to review and comment on this environmental
impact statement.

Sincerely,
M. D. Burdick
State Conservationist

cc:  Council on Environmental Quality (5 copies)
     R. M. Davis, Administrator, SCS; Washington, D.C.
     Office of the Coordinator of Environmental Quality Activities,
        Office of the Secretary, USDA; Washington, D.C.
                                B-25

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 THE STATE  HISTORICAL SOCIETY OF COLORADO
                 Colorado State Museum, 200 Fourteenth Avenue, Denver 60203
                                                   August 9,  1976
Mr. Philip H. Schmuck
Director
Department of Local Affairs
Colorado Division of Planning
500-C State Centennial Building
1313 Sherman Street
Denver, Colorado 80203

     RE:  Steamboat Springs Regional Service Authority
          201 Wastewater Facilities Plan
Dear Mr. Schmuck:

We have reviewed the above Draft Environmental Statement and
the following comments.

The historical and archaeological overview offered on pages 78-79
of the Facilities Plan establishes clearly that the Steamboat area
is rich in historical associations which delineate the development
of the west in general and of the northwest corner of the state in
particular.  Because of this historical heritage, we feel it is of
great importance to identify any  .ites or structures eligible for
entry into the National Register of Historic Places (FR 800.4) that
may be affected by the construction or operation of the wastewater
treatment plant at any of the proposed locations.

The Society has sent inventory information to both Wright-McLaughlin
Engineers (letter May 20, 1975) and the Environmental Protection
Agency (October 8, 1975).  In both letters it was strongly urged that
further information be gathered because the inventory for that area
was incomplete.  Since there is no inventory listed in the Plan, nor
any mention of future surveys to inventory the study area, we again
reiterate that compliance with the National Environmental Policy Act
entails a description of any  irreversible and irretrievable commitment
(destruction) of resources (including historical and archaeological re-
sources).  Such a description would be preceded by an identification
of any historical and archaeological resources that meet the eligibil-
ity requirements for entry into the National Register.

The description would be followed by a discussion of projected inpacts
upon such resources and also of plans devised to mitigate any adverse
impacts to those found eligible for entry into the National Register.
                          B-26

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Mr. Philip H. Schmuck
Page 2
Furthermore, in order to expedite review of Environmental Impact
Statements both as they relate to the provisions of the National
Environmental Policy Act and the National Historic Preservation
Act, the Council on Environmental Quality has instructed federal
agencies to combine compliance procedures for both wherever pos-
sible (38 FR 20544-20555, August 1, 1973).

If we can be of further assistance to you or if you have any
questions, please contact Joy Farr at 321-7265.

FOR THE STATE HISTORIC PRESERVATION OFFICER
    erely,
    s Edward Hartu
   !ator, Historic Preservation
                           B-27

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          STATE  DEPARTMENT  OF  HIGHWAYS

                JACK KINSTL1NGER                  EXECUTIVE DIRECTOR

                                    STATt OF COLORADO

DIVISION  OF HIGHWAYS                 |""'' '\'"",*" "!'*"1                    DISTRICT 3
E. N. HAASE                          liS  >«*•<»                    R A

CHIEF ENGINEER                         \    ^                         DISTRICT ENGINEER
                                           . .,J.At.
             P.O. BOX 21O7—6O6 SO. 9TH ST. •  GRANd JUKrttVoN, COLO. 815O1 • (3O3) 242-2862

                                 August  10, 1976
   Mr. Richard L. Brown
   Principal Planner
   Colorado Division of Planning
   1313 Sherman Street
   Denver, CO  80203

   Dear Mr. Brown:

   This office has reviewed the Draft Environmental  Impact Statement entitled Steam-
   boat Springs Regional Service Authority 201 Wastewater Facilities Plan  (Identifier
   A-95 76-123) and offer the following comments.

   As noted on pages 96 and 97 of this document, the Division of Highways  is begin-
   ning the process of right-of-way acquisition for the upgrading of U.S.  40 east
   of Steamboat Springs.  Draft and Final Environmental/Section 4(f) Statements  for
   the improvement of ten miles of U.S. 40 east and west of Steamboat Springs were
   prepared and approved in 1974 and 1975.  Right of way will first be acquired  east
   of Steamboat Springs, with construction due to begin during 1977; therefore,  de-
   tailed crossing areas and collector line locations are of particular importance
   to us.  It will be important to closely coordinate these two projects so that new
   highway improvements are not completed and immediately torn up during collector
   line placement or vice versa.

   It might be noted here that any crossings of state highways or requests for new
   plant access points onto a state highway will require that the applicant obtain
   permits from our Craig Maintenance Office, 270 Ranney Street.

   Another area of concern by this Division will be the location of the sewage plant
   treatment facilities, specifically the aeration lagoons.  Location of the plant
   facilities and lagoons near U.S. 40, a major public highway, could present some
   esthetic as well as physical problems.  Therefore, we would request that the  sew-
   age plant plans include a vegetative screening plan which would screen  the plant
   facilities and lagoons from the traveling public.  This office would expect to
   participate by reviewing plans for the location of treatment facilities, the
   plant landscaping plan, and highway crossing and lateral collector line details
   (on highway right of way) on the Steamboat Springs Wastewater Facilities as soon
   as they are developed and available.
                                        B-28

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Mr. Richard L. Brown
August 10, 1976
Page 2
                                                            Identifier A-95 76-123
We appreciate the opportunity to review this Draft Environmental Impact Statement.
If this Division can assist with any additional information or assist in any other
way, please contact this office.

                                      Very truly yours,
                                      R. A. PROSENCE
                                      DISTRICT ENGINEER
                                      By



LRA/bev

cc:  File
                                         Laurence R.  Abbott
                                         District Environmental Manager
 bcc:  ujtfhn A. Green - EPA, Denver
      Capron
      Atchison-Chocol
      Presence
      Pyle-Combs
      Fi 1 e
                                    B-29

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                                      REGION XII


                          NORTH WEST COLORADO COUNCIL OF GOVERNMENTS

                               Holiday Center Building - Suite 200
                                      P. O. BOX 737
                                  FRISCO, COLORADO 80443

                                      (303) 468-5445
EAGLE COUNTY
BASALT
EAGLE
GYPSUM
MINTURN
REDCLIFF
VAIL
                                                       August  10,  1976
John A. Green,  Regional Administrator
U.S.Environmental Protection Agency
1860 Lincoln  St.  - Suite 900
Denver, Colorado   80202
GRAND COUNTY
 FRASER
 GRANBY
 GRAND LAKE
 HOT SULPHUR SPRINGS
 KREMMLING
JACKSON COUNTY
 WALDEN
PITKIN COUNTY
 ASPEN
 ROUTT COUNTY
 HAYDEN
 OAK CREEK
 STEAMBOAT SPRINGS
 YAMPA
 SUMMIT COUNTY
 BLUE RIVER
 SRECK'ENRiDGE"'
 blLLON
 FRISCO   . .	
 SILVERT^ORNE
Dear Mr. Green:

     Thank  you for the opportunity  to  review the Draft
Environmental  Impact Statement for  the Steamboat Springs
Wastewater  Facilities Plan.  Our comments are as follows:

     1.  References to agricultural non-point source
         pollution should be phrased in terms of poten-
         tial  problems associated with agricultural
         management practices which may cause signif-
         icant water quality problems.   At this point
         there is not substantial enough information to
         indicate that any particular  agricultural act-
         ivities in the Yampa Basin cause existing water
         quality problems.  The 208 Program is currently
         inventorying and will later assess the relative
         loadings and impacts from  land management prac-
         tices.   The Routt County Soil Conservation
         District is currently under contract to identify
         significant water quality  problems associated
         with  agricultural practices and will recommend
         best  management practices  where appropriate.
         The institutional analysis of the 208 Program
         will  later identify the appropriate individuals
         responsible for implementing  these management
         practices if and when they are recommended by
         the Soil Conservation District.

     2.  With  regard to the urban runoff problem ident-
         ified in the Draft EIS, it should be referenced
         that  the 208 Program will  identify recommended
         control procedures, financial feasibility, fin-
         ancing requirements and management agencies for
         urban runoff control.

     3.  Reference to the biological conditions in the
         Yampa River places emphasis on the number of
                                       B-30

-------
(John A.  Green continued)
          benthic invertebrates present rather than
          their diversity.   A study conducted by EPA
          in conjunction with the USGS during the fall
          of 1975 would provide a better data base for
          assessing the status of the biological com-
          munity.

      Thank you again for the opportunity to review the
 Draft EIS.
                             Sincerely,
                             Phil Overeynder
                             208 Coordinator
 PO/js
                    B-31

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COLORADO  DEPARTMENT  OF  HEALTH

 421O E.11TH AVENUE        DENVER BO22D             PHONE  3BB 61TI
                    ANTHONY ROBBINS, M.D..M.P. A. EXECUTIVE DIRECTOR
August 10, 1976


Mr. Wes WiIson
EPA, Region VI I I
i860 Lincoln
Denver, CO  80203

RE:  Steamboat Springs EIS and Draft 201

Dear Wes:

We have just a few final comments on the Steamboat Springs EIS and 201 plan.
Primarily, we want to both clarify and confirm our position as expressed at
the meeting in Steamboat on July 23.

We concur with the need for seasonal ammonia limitations for Steamboat
Springs as explained on page 2 of the meeting minutes you sent us.  However,
we will write the permit in terms of pounds of NH,  rather than mg/1 using
plant design flows.

The meeting record also implies that all participants came to agreement
that SO 2dechlorination was necessary at Steamboat  Springs.  For the record,
we would like to reiterate that we do not feel it is clearly necessary to
provide this in  light of the higher coliform limits and the performance of
many similar installations without dechlorination in the State.  Also, we
continue to take issue with Tom Wi11ingham's argument that it is incorrect
to use. the assimalitive capacity of the receiving stream in calculating the
permissable chlorine residual.  We will continue to write chlorine limitations
in permits using the mass balance technique (instantaneous/complete mix)
which does consider stream assimilative capacity.

Finally,  it should be noted that our review of the  EIS and Step I  wi11 not
be complete until we have a chance to review the Financial Consolidation
Plan as noted on page 3 of the meeting record.

Very truly yours,

FOR DIRECTOR, WATER QUALITY CONTROL DIVISION
Jonathan Scherschl igt, P.E./
Planning Engineer
Water Quality Management Planning Section

JS/mb

cc:  James Daber, Technical Services Section


                                  B-32

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COLORADO  DEPARTMENT  OF  HEALTH
 421O E. 11TH AVENUE        DENVER SO22O             PHONE  3BB-61TI
                    ANTHONY ROBBINS, M.D..M.P. A. EXECUTIVE DIRECTOR
July  19, 1976
Mr. Dick Brown
Colorado Division of Planning
Centennial Building
Denver, CO  80203
DECEIVED
  DIVISION OF
   PLANNING
 RE:   DEIS Steamboat Springs RSA 201 Plan

 Dear  Mr. Brown:

 The Colorado Department of Health has the following comments  on  the DEIS:

 AIR POLLUTION CONTROL DIVISION

 The DEIS does not address the impact of emissions discharged  by  the proposed
 project on ambient air quality in the vicinity of the plant site.   Further-
 more, no emissions inventory of expected concentrations  of gaseous  and other
 pollutants generated by the activity are identified in the document.

 Appropriate predictive modeling techniques should also be  selected  and
 identified for use in the air quality impact analysis in  the  DEIS.

 The major components of the facility are described (page  137)  only  in  general
 terms and therefore specific rates of pollutant discharges cannot be  determined.
 It is expected that a more definitive and detailed description of actual
 equipment selected will be made for the final  EIS so that  an  adequate  air
 quality impact assessment can be made.

 The DEIS acknowledges TSP standards are already being violated from fuc tive
 dust  and fireplace sources.  However, it is  not expected  that TSP will  ue  a
 major pollutant discharged from the wastewater treatment  facility proposed.
 From  the general  equipment described (page. 137 and in Appendix B) ,  it  is
 anticipated that a permit for construction of  this facility will be required
 from the Air Pollution Control  Division to demonstrate compliance with appli-
 cable air pollution regulations.

 The Division agrees with the statement  made  on page 77 that "ambient  odor"
will  be the primary effect on air quality-   However,  the statement  does not
 identify odor abatement measures  to be  taken  to meet  the odor requirements
specified in Air Pollution Control C-'imission  Regulation No.  2.  The project
developer should be reminded that he could be  subjected  to violation orders
 if odor emissions exceed regulation requirements  at any  time.
                                  B-33

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Mr. Dick Brown
July 19, 1976
Page 2
ENGINEERING AND SANITATION DIVISION

Page 31, last paragraph:  The sentence starting "Concentration of iron and
manganese ...Federal Register 1975" is not correct because iron and manganese
are not listed in the Interim Primary Drinking Water Standards.

WATER QUALITY CONTROL DIVISION

The Water Quality Control Division reviewed the draft EIS earlier,  and
forwarded comments directly to EPA.  Since all our earlier questions and
concerns have subsequently been answered, those comments  are not repeated
here.

However, we noted on Table 1, page 6, that the wasteload  allocations for  NH,
and Cl2 are not specified.  We are including allocations  of 18.1 pounds NH,
and 0.05 mg/1 total residual chlorine in the permit for Steamboat Springs.
These values should be displayed similar to the values  for BOD.

Very truly yours,

FOR DIRECTOR, WATER QUALITY CONTROL DIVISION
Jon;
    <7-V
  lathan Schersch 1 i gt, P.E.j
Planning Engineer
Water Quality Management Planning Section

JS/mb

cc:   Mary Romero
     Bob Siek
                                  B-34

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                                 Department  of Local  Affairs
                              Colorado  Division  of Planning
Richard D. Lamm, Governor                       Philip H. Schmuck, Director


       August 10, 1976
       Mr. John A. Green
       Regional Administrator
       U. S. Environmental Protection Agency
       Region VIII
       1860 Lincoln Street
       Denver, Colorado  80203
                      SUBJECT:  Draft Environmental  Impact Statement
                                Steamboat Springs  Regional Service Autnernjc/y.,
                                201 Wastewater  Facilities Plan

       Dear Mr. Green:

       The Colorado Clearinghouse has received  and distributed copies of the above-
       referenced statement for review pursuant to the National Environmental Policy
       Act.  Responses from the Colorado Department  of Health and the Department of
       Highways are enclosed herewith.

       In addition, the Division of Planning  has the following comments:

       1.  We are extremely encouraged by the close  coordination between the
           201 Facilities Plan and the Routt  County/Steamboat Springs Compre-
           hensive Plan.  The Statement's adjustments to the Gathers and Associates
           population projections are sound and provide a competent basis for waste-
           water planning.  The Statement makes several references to the logical
           nature of the Comprehensive Plan and general community support for its
           concepts.  However, no explanation is offered for why the Plan has not
           been formally adopted.  Certainly  adoption of the Plan by the Routt County
           Regional Planning Commission would greatly enhance confidence that the
           preferred Midway wastewater treatment site would not be used in a manner
           to promote haphazard and illogical development patterns.

       2.  The Statement apparently does not  contemplate the construction of a con-
           necting line from developments north of the Routt County STOL Airport.  We
           agree that the extension of  sewer  service to that area could encourage
           development in conflict with the local  Comprehensive Plan as stated on
           p. 132 of the Statement.  Plans for  a connector to that area, if they
           should become a part of the 201 program,  should be carefully limited to
           service for the existing subdivisions of  Elk River Estates and Deer
           Mountain Estates with minimal intervening branches.
       3.
The most serious  question unanswered appears to be the selection and organiza-
tion of a management  vehicle for constructing and operating the proposed


                            B-35


  615 Columbine Building, 1845 Sherman Street, Denver, Colorado  80203 (303) 892-2351

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U.S. Environmental Protection Agency
Re:  Steamboat Springs Regional Service Authority,
     201 Wastewater Facilities Plan EIS
August 10, 1976
Page 2

    facility.  The discussion beginning on p. 53 apparently considers only
    the consolidation of existing taxing districts.  The same problem is
    currently being considered by the Pikes Peak Area Council of Governments
    in Colorado Springs concerning implementation of a 208 plan, and joint
    consultation with that entity might prove productive.  Most of the attention
    in the Statement is focused on reconciling varied amounts of bonded indebted-
    ness and other financial disparities.  However, the form of the management
    vehicle is also a significant problem.  Consolidation of districts is hampered
    by the statutory requirement (Section 32-4-122 CRS 1973) that lands within a
    single district be contiguous, and attempts to extend district boundaries to
    include the KOA Campground, Sleepy Bear Mobile Home Park and Steamboat II
    would undoubtedly encourage development contrary to the Comprehensive Plan.
    Even though the term "Regional Service Authority" has been used in Steamboat
    Springs, it is noted that legal service authority machinery is not available
    in this particular case unless the state legislature removes the current
    impediment requiring composition from parts of two counties (see Section
    32-7-104 CRS 1973).  It is possible that a suitable vehicle might be con-
    structed contractually pursuant to Section 29-1-201 et seq. CRS 1973, except
    that private entities (KOA and Sleepy Bear) are involved and financing arrange-
    ments would be awkward at best.  The most promising avenue seems to be investi-
    gation of a Metropolitan Sewage Disposal District (Section 32-4-501 et seq.  CRS
    1973) which would appear to circumvent the contiguous land requirement.  Of
    course, financial disparities would still have to be resolved.

4.  The Statement does not examine the impacts of summer land treatment during
    the late summer months on the maintenance of flows for irrigation, fishery,
    or aesthetic purposes.  I would suggest that the high water loss accompanying
    spray irrigation and the slow return of alluvial water to the river should
    receive special attention in the Final EIS.

We appreciate the concise relevancy of this Environmental Impact Statement and
thank you for the opportunity to comment on it .

Very truly yours,
Philip H. Schmuck
Director, State Clearinghouse

PHS/CGJ/vt
Enclosures

cc:  Jim Monaghan, Assistant to the Governor for Natural Resources
     Colorado Department of Health
     Colorado Department of Highways
     Routt County Regional Planning Commission
                                  B-36

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  STATE OF COLORADO
  Richard D. Lamm, Governor
  DEPARTMENT OF NATURAL RESOURCES

  DIVISION  OF WILDLIFE
  Jack R. Grieb, Director
  6O6O Broadway
  Denver. Colorado 8O216 (826-1192)
August 12,  1976
      Mr.  Philip H.  Schmuck,  Director
      Department of Local  Affairs
      Colorado Division of  Planning
      500-C State Centennial Bldg.
      1313 Sherman St.
      Denver,  Colorado  80203

      Dear  Phil:
              RECEIVED!
              AU
                       OF
                PLANNING •  '
          I have enclosed a copy of a memorandum from Wayne R. Seaman,
      Chief of our Fishery Research Unit,  which states the position of the
      Colorado Division of Wildlife concerning Steamboat Springs Regional
      Service Authority 201 Wastewater Facilities Plan.
                                                 Sincerely,
                                                 P.  T.  Barrows,  Chief
                                                 Environmental Resources
     PTB:lm
     enclosure
     cc:  H. Sherman
          G. Rogers
          W. Seaman
                                         B-37
DEPARTMENT OF NATURAL RESOURCES, Harris Sherman, Executive Director • WILDLIFE COMMISSION, Vernon C. Williams, Chairman
          Thomas Farley, Vice Chairman • Sam Caudill, Secretary • Jean K. Tool, Member •  Roger Clark, Member
                      Jay K. Childress, Member • Dean Hull, Member • Dean Sut»ie, Member

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ivisional Correspondence Only
TO:
                                  STATE OF COLORADO
                            DIVISION   OF   WILDLIFE
                              DEPARTMENT OF NATURAL RESOURCES
                                                           DATE:   July  13,
P. T.  Barrows
FROM:   w- H" Seaman
       The Yampa" River is hurting  from Steamboat Springs development.   Scarcely
       any of the sewage plants  are meeting state effluent standards.

       The Yampa is already water  quality limited for ammonia.   This means either
       growth must be curtailed  or tertiary treatment inaugurated.  Land treatment with
       effluent used for irrigation looks possible here for the  warmer  months.  Due
       to the cold winters, however a combination is indicated or reservoir winter
       storage would be needed.

       I think we should support alternative IV with the summertime land treatment
       and the Midway site.

       This is a good EIS,
       dh
                                        B-38

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                            APPENDIX C

                     EPA RESPONSE TO COMMENTS


1.  Health, Education and Welfare, Rulon Garfield - Regional Director

    Response:  EPA appreciates HEW's comment and its conclusion that
    the alternatives have been adequately addressed.

2.  Colorado Ute Electric Association, John J. Bugas - President

    Response:  EPA appreciates support of Colorado Ute in its 201
    project.  This effort will benefit not only downstream water users
    but also the aquatic life of the Yampa River.

3.  Army Corps of Engineers, George C. Weddell - Chief, Engineering Division

    Response:  This project will not enter into Step 2 which is the
    detailed engineering design portion.  In this phase provisions
    will be made so that any river crossings are designed to pass
    flood flows and that there is sufficient allowance for backfill,
    riprap or other flood protection means.  The Step 2 design engineer
    will be required to contact your agency so that you are assured
    of adequate provisions.

         Regarding reference to the Section 404 permit requirement,
    EPA recommendations on this permit are set forth in Chapter
    VIII on Mitigating Measures.  At such time that Step 2 is
    nearing completion and prior to Step 3 (actual construction),
    appropriate measures will be taken to comply with such
    permit requirements as the Corps and EPA deem necessary.

         Although every effort will be made to control construction
    sedimentation problems, it is likely that some short-term
    erosion will occur.  However, EPA is satisfied that no long-
    term problems will result through proper mitigating measures.

4.  U. S. Public Health Service, Richard O. Hayes - Chief, Water Resources
                                                    Branch

    Response:  EPA appreciates your comments with regard to
    potential disease transmission from the vectors Culex tarsalis
    and Aedes dorsalis.  We have conducted soil tests since the
    printing of the draft EIS and have adopted an application
    rate of 29 inches per year.  This rate is considerably less
    than the 3 to 7 foot range that was proposed in the draft
    EIS.  We believe this new rate will minimize the possibility
    of pooling and insect breeding.  Nonetheless,  monitoring  of
    the site will be made a condition of the grant so that pool-
    ing can be stopped if it is observed.
                                C-l

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5.  Federal Energy Administration, Dudley E. Faver - Regional Administrator

    Response:  EPA appreciates the specific comments by the Federal
    Energy Administration.  The goal of this 201 project is to control
    harmful constituents of sewage plant effluent including ammonia
    and chlorine.  EPA recognizes that the Yampa River is influenced
    by substantial nonpoint sources, however, until the 208 studies
    currently underway are completed, it is impossible to determine
    the likelihood of attaining A-l stream status.  The action pro-
    posed would be necessary even if the Citizens Advisory Committee
    had as its goal a B-l class stream.

         The Water Quality Control Commission may not change the B-l
    status of the Yampa River, despite the desires of the Steamboat
    Springs Citizens Advisory Committee„  Two of three historical
    violations at Milner are believed to be natural in origin, and
    implementation of A-l standards would limit their allowable
    range even more.

         The  treatment of Steamboat's mineral springs would seem  to
    be a.waste of  time and energy.  Their  contribution of salts increases
    background levels of salinity from about 280  to 370 mg. per 1  (ppm)-
    These  concentrations should not harm the ecological quality of the
    Yampa  River.   Additional  studies by the USGS  should clarify their
    impact, especially with regard to individual  constituents added by
    the springs.   These constituents are potentially more harmful than
    the total tonnage of salt added.

         FEA's comment about  the sulfur discharge from the mineral
    springs around Steamboat  is well taken.  Again it is intended
    to consider  this source in the ongoing 208 studies, and there-
    fore no action is contemplated under this Section 201 project.


6.  U. S. Forest Service, S. H. Hanks - Deputy Regional Forester

    Response:  The population projection developed and used by the
    design engineer are felt to be quite realistic and allow for
    phased construction of sewage treatment facilities.  Through
    phased construction, expansion would only occur as growth
    materialized.  Based on all the comments and attitudes of local
    citizens involved in this project, it is concluded that the
    wastewater facilities themselves will not be a growth inducement.
    However, EPA recognizes that the new facilities will facilitate
    growth in the Steamboat Springs area.  This growth places
    numerous demands on the community, including requirements
    for more potable water,  which in turn could affect your agency.
    EPA continually stresses the importance of growth management
    with proper provision for needed utilities.
                               C-2

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         The effulent is to be applied to nearby farmland during
    summer.  Although it would be desireable to use effulent in
    conjunction with strip mine reclamation, such a program is
    not contemplated because of the distances involved and the
    active interest already shown by nearby ranchers.

7.   Department of Interior, John E. Raybourn - Special Assistant to
                                               Secretary

    Response:  EPA appreciates your concern for the  historical
    and cultural factors of the proposed project.  The  final
    EIS contains evaluations of these concerns and refers to
    an archeological investigation that is  currently being im-
    plemented  (see the  response to letter No. 12).   The terres-
    trial  environment of the project site has been extensively
    evaluated by Dr. John  Marr and his students from the Univer-
    sity of Colorado (Wright-McLaughlin Engineers, April 1976;
    see bibliography).  This evaluation has not been included
    in the EIS because  EPA believes it is not a central issue
    of the proposed project.  Central issues are water quality,
    aquatic biology, agricultural soils, land use and financial
    condition of the districts.

         Your comments  on  recreational use of the Yampa is a local
    concern that is handled by the city's Recreational Department.
    They have already developed a trail system, which is not readily
    used,  and they are  conducting a major effort to restore Howelsen
    Hill,  the ski jump  area.  Your comments on threatend or en-
    dangered species have  been implemented.

8.  Routt County Regional Planning Commission, Daniel R. Ellison -
                                               Planning Administrator

    Response:  The draft environmental impact statement characterized
    the Yampa River as being in poor condition.  This subjective
    statement contained on the summary sheet makes no inference
    as to the role agriculture plays in the quality of the Yampa
    River.  EPA recognizes that only the ongoing 208 studies can
    adequately substantiate nonpoint source contribution to Yampa
    River quality.  EPA regrets any misunderstanding of its char-
    acterization of the Yampa River.  It is clear that the river
    is adversely impacted  by sewage plant effluent which is the
    subject of this 201 project.  It is also evident that there
    is a heavy sedimentation load.  It is anticipated that the 208
    studies will differentiate between natural erosion and runoff
    which is the result of man's activities.
                               C-3

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     The conclusions found later in the EIS, referring to agricul-
tural practices, have been quantified by Dr. Robert W. Pennak
of the University of Colorado.  He investigated two areas along
the Yampa River located one and two miles south of Steamboat
Springs.  Six to ten banks were examined at each area and they
were judged to be either stable or unstable.  Those banks that
were labeled unstable were banks that experienced soil sloughing
during the previous year.  Based on this approach, Dr. Pennak
found 61% of the banks were stable and 39% were unstable.  Those
banks that were labeled unstable existed in a condition that
could contribute siltation to the river during future runoff
events.

     These conclusions have been supported by Dr. J. T. Windell
at the University of Colorado.  He floated the Yampa River,
south of Steamboat Springs and also found evidence of unstable
banks.  Such observations have been photographed and could be
provided to interested parties if requested.

     EPA received several comments regarding the proposed appli-
cation rate for the summertime land treatment program.  Clearly,
the rate selected will be a function of the land parcel to be
used.  Please refer to the final Facilities Plan for this project
as those details have now been discussed in sufficient detail
for Step 1 of this project.

     Reference of the growing season in the Steamboat Springs
area of 90 to 100 days was obtained from the draft comprehensive
plan prepared by Charles Gathers and Associates.  EPA notes that
the 59 days pointed out in the Colorado Agricultural Handbook
is for frost-free days and does not necessarily reflect the
actual growing season.  The final Facilities Plan does point
out that provisions have been made to allow for a reasonable
growing season.

     Provisions will be made so that treatment areas will be
adequately dried to allow harvesting.  This will be accomplished
through rotation of areas being irrigated.  EPA appreciates
notation of this element which had been considered in the
original calculations, but was not mentioned in the initial
Facilities Plan.

     EPA notes the exitence of a comprehensive plan for the
West Steamboat area.  The principal of county-wide comprehensive
planning is highly encouraged, particularly when effors are
made to incorporate environmental and natural resource constraints
in growth management policies.
                               C-4

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         The  land  use map  prepared  as  part  of  the  draft EIS  indicated
    that the  land  adjacent to  the existing  lagoon  is  slated  for light
    industrial.  Reference to  future residential development was meant
    to  refer  to buildout of the existing Riverside subdivision.  EPA
    appreciates your comment about  the approach pattern for  the county
    airport and that locating  the regional  sewage  plant at the existing
    location  would be a consistent  and desirable use  of this land.

         Wright-McLaughlin used peak day population estimates prepared
    by  Weiner & Associates.  This peak day  figure  represented capacity
    of  all available facilities.  The  average  of 30 busiest  days was
    only included  in the discussion and in  the projection  to add clarity
    and represent  the active seasons of the year.   In the  population
    forecasts, it  was concluded that new recreational population may
    be, to some degree, overlapped  by  coal  related development.  It
    is  felt however, that  they will tend to overlap such that there
    will tend to be a slight trade-off between development that does
    occur and the  nature of new residents in the area.

         The  financial condition of several of the entities  involved
    in  this project was isolated as an issue in the draft  EIS.  Efforts
    have been completed to develop  a financially sound means of secur-
    ing the local  share and this is reported in this  final EIS.

         EPA  is most appreciative of the action taken by the Routt
    County Regional Planning Commission in  passing a  resolution re-
    garding a plant site growth inducement. What  growth occurs and
    where,  is strictly a function of local  regulatory action and ap-
    proval.   The  strong position taken by the  Commission assures EPA
     that by funding this project it will not create pressure or other
     situations which conflict  with  the goals of local land use agen-
     cies.   In addition» EPA will condition  the grant  to SSRSA to
    limit  new" taps along the proposed  interceptor  (See Chapter VIII).

 9. Federal Highway Administration, F. S. Allison

    Response:  Review  and  comment appreciated.

10. U.  S.  Department of  Interior, Geologic  Survey, Timothy Steele

    Response:  EPA appreciates your most extensive list of comments
     and has- considered each of them for input  into our final EIS.
    You will  note  that  the final statement  characterizes the chem-
     ical water quality as  good and  the aquatic biological  environ-
    ment  as  poor  to fair.   Appropriate statement and  studies are
     provided  to back up  these  contentions.

11. U.  S.  Soil Conservation Service, M. D.  Burdick -  State Conservationist

    Response:  EPA appreciates the  time SCS has taken to review this
     impact statement.   The final EIS  does contain, at your suggestion,
                                   C-5

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     a soils map for the land treatment proposed.   A misunderstanding
     apparent in the description of the land capability classification
     system has been corrected as part of this final EIS.

          The third volume of the Facilities Plan  discusses in detail
     the location size and drainage considerations associated with
     the land treatment site.  This has been summarized in the final
     EIS and as was noted in the draft, was an unresolved  issue at
     the time of the draft.   EPA appreciates SCS pointing  out the
     importance of making adequate provisions for  wastewater appli-
     cation rates and underdrain systems if necessary.

          Comments on nitrogen uptake of reed canary grass have been
     noted and have been considered in preparation for  the final
     Facilities Plan.  EPA agrees that the land treatment  application
     systems and application rates have to be tailored  to  the specific
     parcel proposed and must take into account many factors includ-
     ing plant uptake, soil infiltration, drainage and  needed time
     for haying operations.   This criteria is addressed in the last
     volume of the Facilities Plan and in this final EIS.

          It is recognized that during construction and just after
     soil erosion problems could occur, mitigating measures have
     been proposed and it is felt that the adverse impacts which
     may occur will be temporary in nature.  Although short-term,
     these potential adverse impacts are now listed as  such in the
     final EIS.

          The Routt County Soil Conservation District has  been
     added as a unit of state government dealing with nonpoint
     source pollution.

          Step 2 of the Facilities Planning effort includes detailed
     engineering and development of specific procedures to be fol-
     lowed during actual construction, Step 3.  EPA agrees that
     the items listed under Item 8 of the SCS letter, must be addressed;
     however it is felt that it is appropriate to  do this  as part
     of the Step 2 effort.

          It is anticipated that prevailing methods used in the
     region for harvesting hay will continue to be used at the land
     treatment site.  The final Facilities Plan provides for this
     operation.  It is not contemplated that methods used  will deviate
     from what is common practice in the region.  In this  sense har-
     vesting will occur in August or as conditions dictate.

12.  State Historical Society of Colorado, James E. Hartmann

     Response:  EPA recognizes that the limited information currently
     available in archaeology in the area is not adequate  to consider
                                   C-6

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     right of way selection or the exact site of the plant as well
     as possibly recover any sites of archeological signigicance.
     Therefore a supplemental report on archeological signigicant
     sites is currently being prepared.  Unfortunately,  this report
     will not be completed in time to print as part of this final
     EIS.  Copies of the report will be available by mid September
     1977 and sent to interested parties upon request.  The State
     Historical Preservation Officer will be contacted following
     his review of this report for his recommendation on mitigat-
     ing measures for archaeological sites.

          If archaeological artifacts are discovered during con-
     struction or plowing activities, these activities will be
     stopped.  A qualified archaeologist should then be  summoned
     to investigate the site.  If the findings are significant,
     accomodations should be made to allow proper excavation and
     assessment.  However, these accomodations should be done in
     such a manner that construction delays are minimized.  EPA
     will also condition the Step 2 grant to SSRSA that  construc-
     tion activity include consideration for the results of this
     field survey of archaeological sites.

13.  Colorado State Department of Highways, Laurence R.  Abbott

     Response:  The only anticipated crossing of U.S. 40 would
     be about two miles west of Steamboat Springs, near  the Steam-
     boat 2.  Plans to lay the collector across this section of
     highway will be coordinated with your Denver office and per-
     mits will be obtained from your Craig Maintenance Office.
     Since our recommended plant location should be obstructed
     from public view, we do not anticipate the need for a land-
     scaping screen.  However, landscaping will be employed around
     the completed plant in order to maximize its aesthetic appear-
     ance.

14.  North West Colorado Council of Governments, Phil Overeynder

     Response:  EPA appreciates these comments and acknowledges
     that agriculture's contributions to nonpoint sources of
     pollution are not accurately known.  However, the Routt
     County Soil Conservation District is not the first  group
     to study the potential problem.  Two professors from the
     University of Colorado have studied the situation and have
     concluded that agricultural practices do encourage  river
     siltation, especially upstream from Steamboat Springs.  Al-
     though additional studies by the District may mitigate the
     conclusion of these observations, they are included in the
     EIS for the record.
                                    C-7

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          Your concerns for property delineating the function of the
     208 process are appreciated and are reflected in the final EIS.

          Your concerns for the biology discussion of the draft re-
     flect the concerns of the USGS, which are handled in the previous
     response No. 10.  Here, we acknowledge the diversity studies
     done by Eddy of EPA and Aimes of CSU, and we point out why they
     are not better or worse than previous studies done by Wentz
     of "USGS and Pennak of CU.  Each author uses slightly different
     methodologies that render direct comparisons difficult.  How-
     ever, all four studies contribute to our understanding of the
     biology of the Yampa River and are cited in the final EIS.
15.  Colorado Department of Health, Jonathan Scherschligt

     Response:  EPA appreciates the support of the Colorado Water
     Quality Control Divis-ion for a seasonal ammonia limitation.
     The final EIS will include this limitation and cites specific
     loading rates.  Our stand on dechlorination will remain the
     same despite relaxation of the fecal coliform standard.  The
     S02 system is not capital intensive, representing less than
     1% of the anticipated capital outlay, and it provides additional
     protection for the aquatic environment.  Furthermore, it is
     believed that the cost of proving or disproving the need for
     such a system would represent more than the cost of the system
     itself.

          Your concern for the financial condition of the districts
     is appreciated.  The final EIS contains a report on their
     status and a recommendation on how to proceed.

          Odorous hydrocarbons will periodically eminate from the
     plant site.  There is no practical way to estimate these emis-
     sions as they would only occur during upset conditions.  The
     Facilities Plan deliniates the equipment to be used in the new
     facility.  No exhaust fans or stack emissions other than space
     heating are planned.  A permit may be necessary to insure fug-
     itive dust control during construction.  Health Department of-
     ficials will be contacted prior to Step 3 grant award.  Selec-
     tion of the proposed treatment technology considered the State's
     Odor Regulation No. 2 and compliance seems assured particularly
     at the Midway site with its land buffer.

          EPA appreciates your correction of the statement regarding
     iron and manganese.  It is deleted in the final EIS.
                                C-8

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16.  Colorado Division of Planning, Philip H. Schmuck

     Response:  Review and comment appreciated.

17.  Colorado Division of Wildlife, P. T. Barrows

     Response:  EPA appreciates the support of the Colorado Division
     of Wildlife; we believe that the final EIS reflects your con-
     cerns .
                                   C-9

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           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
   (f                              REGION VIII
I PBOl*-
                                I66O LINCOLN STREET

                              DENVER COLORADO HO2O3
  TO ALL INTERESTED GOVERNMENT AGENCIES, PUBLIC GROUPS AND INDIVIDUALS


  The enclosed copy of the draft environmental impact statement (EIS) for
  the proposed wastewater treatment facility for the Steamboat Springs
  Regional  Service Authority (Routt County, Colorado) is provided for your
  review and comment.  Written comments on this EIS should be sent to the
  above address by August 9th in order to be considered for the final EIS.

  The EIS analyzes the environmental impacts of constructing a new
  regional  sewage treatment for the Steamboat Springs area.  All alterna-
  tives, with the exception of the "no-action" alternative, combine the
  waste loads of the City of Steamboat Springs with six water and sanita-
  tion districts and two private developments.  The recommended alternative
  uses a site two miles downstream of the existing city lagoons, is designed
  for ten years of reasonable growth, and uses a combination of in plant
  treatment and summertime application of effluent to meet water quality
  standards.

  A public hearing on this EIS is scheduled to consider views of interested
  groups, agencies and individuals.  Your attendence and presentation of
  your opinion on this matter is encouraged.  The hearing will be held at
  the Yampa Electric Association Conference Room, 10th and Yampa Streets
  in Steamboat Springs, on Thursday, July 29, at 7:30 p.m.
           areen
  Regional Administrator
                                       c-10

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                             THE DENVER  POST
                        AFFIDAVIT OF PUBLICATION

        STATE  OF COLORADO         ss
   CITY AND COUNTY  OF DENVER

                 E3THER  M.  RIDGEWAY
        I	  of said
   City and County of Denver, of lawful age, being first duly sworn on oath,
   depose and say:
                           ACCOUNTING DEPARTMENT

      That I am the	SUFERVISOR	of THE DENVER POST,

   INC., a Colorado  corporation;  that  said company  Is the  owner and

   publisher of the newspaper, THE DENVER  POST; that I have personal

   knowledge of all  the facts  set  forth in  this affidavit;  that  said  THE

   DENVER POST is a dally newspaper within  the meaning  of Chapter 109,

   Article I, Sections  1  to 8, inclusive, Colorado Revised Statutes of  1953,

   and amendments thereof;  and that  said newspaper had prior to January

   1, 1936, and has ever  since that date, been admitted to the United States

   mails as second-class matter, under  the provisions of the Act of Congress

   of March 3, 1879, and  amendments  thereof; that  said newspaper is

   printed and  published dally  and has its principal office and place of

   business in  said City and County of Denver, and has a general public

   circulation in said  City and County, and  throughout the State of Colo-

   rado; that said newspaper has been so printed, published and circulated

   as a public daily  newspaper of  general  circulation uninterruptedly and

   continuously during the period of more  than six  (6)  months  next prior

   to the first issue thereof  containing the  annexed legal  notice and

   advertisement.


       The annexed  legal  notice  and advertisement  was published  on


      	JULY  27,. 1976	

                                   (Dates)
                                   (Dates)

   In the regular Editions of said Newspaper,  and that, therefore, said legal

   notice and advertisement  were published in a Newspaper duly qualified

   for that purpose within the  meaning of said  above mentioned and all

   other relevant Statutes and Acts of the General  Assembly of the  State

   ofCo.orado.               ^,        J^ £> ^
       Subscribed and sworn to before me this	day of

    	AUGUST	A. D.  19..7&.

   My commission expires. ,?E.BRUA R3T . 13 ,. .1.777.	

   Witness my hand and notarial seal.       ^.s
                                                   C,i/ L.,'.  C / .-,_
                                                     /   Notary Public.
LEGAL NOTICE AND  ADVEBT1SEMENT
         WOT ICE OF CHANGE QFPUBLIC
         .HEARING  ON  DRAFT  EN-
         VIRONMENTAL  IMPACT STA-
         '/TEMENT ON'MtOPOSBB WAS-
         'TevWjTER    r JREA*y\ENT
        ;'J|ACtLlTY *=O«  THE STEAM-
        , .l&AT  SPRINGS REGIONAL
        0;;*ERV«:€ AUTHORITY.

         *orice t« hereby given-mat the pub '
        i., lie hearing previously scheduled
        v-5fr July VI, l»7«, in  sieamboat
        N FSiirin«s, Colorado, by the U, S. En-
        , vironrhental Protection Agency to
         .receive comments on the draft en-
         vironmental impact statement for
         the  proposed waslewater treat-
         ment facility tor the  Steamboat
                egional Service flutnort-
                .CMiniyt Colo
                .       lorado^ has
           en rescheduled al the request of
           e City of Steamboat Springs, the
           w hearing date  is Wednesday.
          August  4, i»7t,  !n Steamboat
        > Springs, Colorado, at  the Routt
        I County   Courthouse,   District
                   7:30 p. m.

            commtht period has been ex-
          tended to .August 1. 1976, for per-
          sons interested in submitting writ-
          ten comments for incorporation
          into the hearing retoHcr _ •
Class.-7

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THE  ROCKY MOUNTAIN  NEWS
                   DENVER, COLO.
                PUBLISHER'S AFFIDAVIT
City and County of Denver, 1
STATIC OP COLORADO,    Jss'
                Mel  G.
    	being  of lawful
line and being first duly sworn upon oath, deposes and  says:

    ««.  .    „  .   .v.           Credit  Manager
    That  .. .he Is the	9	
tit The  Rocky Mountain  News,  a daily  newspaper of general
circulation published and  printed in whole or In  part In  Den-
ver, In the County of Denver and State  of Colorado,  and that
Bald newspaper waa prior to and during all the time hereinafter
mentioned duly qualified for the publication of legal notices and
advertisements within the  meaning of an Art of  the General
Assembly  of the State of  Colorado, approved April 7, 1921,  as
amended and  approved March  30, 1923 ; and  as amended and
approved  March  5, 1936,   entitled  "An  Act  concerning  Legal
Notices, Advertisements and Publications and the fees of printers
and publishers thereof, and  to repeal all acts and parts  of acts In
conflict with the provisions of this Act" and amendments thereto:
That the notice of which the annexed is a true copy, was published in
the said newspaper to wit; (dates of publication)
                         July    28,   1976
  NOT 1C
LIC HE AT
RONM6N
WENT •"
,,
 DRAF
 OF  PUB-
FT ENVI-
  UATE-
 REGIONAL SERVICE AUTHORITY
 Notice Is hereby given that the public
 hearing previously  scheduled for
 July 29, 1974, In Steamboat Springs,
 Colorado, by the U.S. Environmental
 Protection Agency to receive com-
 ments on the draft environmental Im-
 pact statement  for the proposed
 wastewater treatment facility for the
 Steamboat Springs Regional Service
 Authority (Routt County, Colorado),
 has been rescheduled at me request
. of the City of Steamboat Springs. The
 new hearing date Is Wednesday, Au-
 gust 4, 1974, In Steamboat Springs,
 Colorado, at the Routt County Court-
 house, District  Courtroom at 7:30
 p.m.
. The comment period has been ex-
 tended to August 9j 1976, for persons
 Interested In submitting written com-
 ments for Incorporation Into the
 hearing record.        	
                                              30
    Subscribed and sworn to before me this ................ day
of .....    ........          ........ ..., A. n. 19..
                                                    6
                                                      .
                                          Notary Public.
    My commission •expires^.
                  //J.
                                                      C-12

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.
  EPA-908/5-77-005
                             2.
4. TITLE AND SUBTITLt
  Final  Environmental  Impact Statement
  Steamboat  Springs Regional Service Authority
  201 Wastewater Facilities Plan
7. AUTHOR(S)
  Steve  Weiner of Weiner and Assoc.
  Weston W.  Wilson, EPA        	
                                                           3. RECIPIENT'S ACCESSI ON" NO.
                                                           5. REPORT DATE
                                          -_
                              6. PERFORMING ORGANIZATION CODE
                                                           8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
  Weiner  and Associates, Inc.
  Stapleton  International Airport
  Denver,  Colorado 80207
                                                           10. PROGRAM ELEMENT NO.
                              11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
   U.S.  Environmental Protection Agency
   Region  VIII
   1860  Lincoln St.
   Denver, Colorado 80295	
                              13. TYPE OF REPORT AND PERIOD COVERED

                                 Final
                              14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
 This  is  a final  environmental impact  statement (EIS) for proposed construction
 of  additional  wastewater treatment facilities  at Steamboat Springs, within Routt
 County,  Colorado.  The U.S. Environmental  Protection Agency (EPA), Region  VIII,
 Denver,  under the authority of Section  201  of  the Federal Water Pollution  Control
 Act Amendments of 1972, is authorized to  grant 75 percent matching funds for con-
 struction costs  of designated wastewater  treatment facilities.  Sewage  discharges
 as  a  result of area growth and development  together with non-point source  runoff
 and irrigation return flows have degraded  the  water quality of the Yampa River
 and its  tributaries.  Therefor, both  additional  sewage treatment facilities and
 non-point source controls are needed  to meet water quality goals.

 The recommended  action is to construct  a  sewage  treatment plant 2 miles down-
 stream of the existing lagoon system.  The  new plant will combine 5 separate
 districts into a regional system.  Tertiary treatment is required to meet  water
 quality  goals  and will be accomplished  through a combination of in-plant treat-
 ment  and summer  time sewage irrigation.
17.
                               KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.IDENTIFIERS/OPEN ENDED TERMS
                                                                        c.  COSATI Field/Group
  Sewage disposal.
  Sewage Irrigation
  Nitrification
  Water Pollution
  Land  Disposal
  Regional  Planning
  Environmental Impact Statement
Financing
Yampa River Basin
Steamboat Springs,  Co.
13. DISTRIBUTION STATEMENT
  Release  Unlimited
                 19. SECURITY CLASS (This Report)
                                                                        21
                                                   PAGES
                                              20. SECURITY CLASS (This page)
                                                                        22. PRICE
EPA Form 2220-1 (9-73)
                                            C-13

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