VOLUME 1= ISSUES AND ACTIONS
EPA-308/S-23-001A
FINAL
     DENVER  REGIONAL
     ENVIRONMENTAL IMPACT
     STATEMENT FOR
     WASTEWATER  FACILITIES
     AND  THE CLEAN WATER
     PROGRAM
     U.S. ENVIRONMENTAL
     PROTECTION AGENCY
     REGION VIII. DENVER

-------
VOLUME I.   ISSUES AND ACTIONS                       FINAL

EPA-908/5-77-001A


                           DENVER REGIONAL

                   ENVIRONMENTAL IMPACT STATEMENT
                                 for
                       WASTEWATER  FACILITIES
                              and  the
                         CLEAN WATER PLAN
                            Prepared  by

               U.S. ENVIRONMENTAL PROTECTION AGENCY

                        REGION VIII,  DENVER



                            April 1978
                            Approved by:
                                       Alan Merson
                                       Regional Administrator

-------
                          CONTENTS

           SECTION TITLE                                    PAGE


I      SUMMARY                                                1

II     INTRODUCTION AND OVERVIEW                              7

            Actions Covered                                   7
            Overview of EIS                                   8
            EIS Objectives                                   13
            EIS Format                                       14

III    SIGNIFICANT ISSUES                                    15

            Air Quality                                      15
            Water Quality (Stream Classifications)           17
            Wastewater Facilities Organization
               (Siting) and Treatment Processes              23
            Management and Institutional Arrangements        28
            Control of Nonpoint Source Pollution             33
            Depletion of Stream .Flows                        35
            Water Conservation                               37
            Energy Conservation                              41
            Protection of Environmentally Sensitive
               and Resource Areas                            42
            Enhancement of Recreational Opportunities        44
            Growth and Development  in Northern
               Douglas County                                45
            Other Significant Water Quality Problems
               and Study Needs                               46

 IV     EPA PROPOSED ACTIONS AND MITIGATIONS                 49

            Air  Quality                                      49
            Water Quality  (Stream Classifications)           51
            Wastewater Facilities Organization
                (Siting) and Treatment Processes              53
            Management and Institutional Arrangements        56
            Control of Nonpoint Source Pollution             59
            Maintenance of Stream Flows                      60
            Water Conservation                               61
            Energy Conservation                             62
            Protection of  Environmentally  Sensitive
               and Resource Areas                           63
            Enhancement of Recreational Opportunities        65
            Funding of Wastewater Collection and
               Treatment  Facilities for Northern
               Douglas  County                               66

-------
    SECTION TITLE                                    ?AGE


     Other Significant Problems and Study Needs       67

PROBABLE CONSEQUENCES OF PROPOSED ACTIONS             69

Unavoidable Adverse Impacts                           69
Long-Term vs. Short-Term Benefits                     70
Committments of Resources                             71

APPENDICES                                            73

Appendix A                                            73
Appendix B                                            '*
Appendix C                                            y->
                        11

-------
SUMMARY

-------
                           SECTION I
                            SUMMARY
             FINAL ENVIRONMENTAL IMPACT STATEMENT
1.  Name of Action:    (x) Administrative     ( ) Legislative

2.  Description of Action;  The Environmental Protection Agency has
received or is anticipating requests to fund 75 percent of the con-
struction costs for wastewater collection and treatment facilities
for the service areas in the Denver Region under Section 201 of the
Clean Water Act.  EPA is also required to take action on the 208
Clean Water Plan prepared for EPA by the Denver Regional Council of
Governments.  The ten wastewater facility plan service areas are:

     1.  South Adams County
     2.  Englewood and Littleton
     3.  South Lakewood
     4.  Cherry Creek and Goldsmith Gulch
     5.  Lower South Platte
     6.  Clear Creek
     7.  Sand Creek
     8.  Westminster and Broomfield
     9.  Metropolitan Denver Sewage Disposal District No. 1
     10.  Northglenn

 3.   Environmental Impacts  and Actions

     1.  Air  Quality

         The  funding of  additional wastewater  treatment  capacity  sup-
         ports  growth; growth without  implementing commensurate air
         quality  controls  will  result  in continued air pollution  prob-
         lems in  the Denver Region.  EPA's  proposed actions  in response
         to this  issue are:

            EPA's funding  of wastewater  projects will be contingent
            on:

                legally binding  commitments  from local governments
                to participate  in the development and implementation
                of the State  Air Quality Implementation Plan;

                design being  based on DRCOG  population projections (or
                revised projections based on air quality  considerations)
                with 10 years additional  capacity for treatment works
                and 20 years  capacity for interceptor sewers;

                grant conditions to  limit the number of  taps  based on
                a  uniform annual growth rate that is consistent with
                DRCOG population projections.

-------
           additional capacity of facilities to serve contiguous
           development within existing urban service areas.
2.  Water Quality (Stream Classification)

    The Clean Water Plan recommends several changes to the
    existing classifications of several stream segments in the
    Denver Metropolitan area.  The State has not officially
    adopted the Clean Water Plan's recommendations for stream
    classifications, thus causing confusion on what numbers to
    use for reissuing NPDES permits and designing treatment levels
    under the facility plans.  EPA proposed actions in response
    to this issue are:

        .  Until the State officially acts on the Clean Water
           Plan's recommendations for stream classification,
           EPA will use the existing classifications and efflu-
           ent requirements for making decisions on NPDES per-
           mits and construction grants;

        .  EPA will require further documentation to justify the
           Clean Water Plan's recommended downgradings.

3.  Wastewater Facilities Organizations  (Siting) and Treatment
    Processes

    The Clean Water Plan has recommended a regional facility for
    the Clear Creek Basin near Golden while the Clear Creek
    facility plan has not.  The Clean Water Plan has not been
    revised to reflect a facility for Northglenn as recommended
    in the Northglenn facility plan.  EPA's proposed actions on
    this issue are:

           EPA will approve the Clean Water Plan's recommenda-
           tions for wastewater treatment plant siting except
           for Clear Creek and Northglenn where revisions in the
           208 Plan or facility plans are necessary.

           EPA shall give preference to land treatment/reuse pro-
           jects and funding shall be based on compliance with
           NPDES permit requirements and other enforceable pro-
           visions of the Clean Water Act.

-------
4.  Management and Institutional Arrangements

    Fifteen special districts that were recommended as waste-
    water management agencies by the Clean Water Plan were not
    designated by the Governor with the exception of short-
    term designations.  The State preferred to designate general
    purpose governments as management agencies.  EPA's proposed
    actions in response to this issue are:

        .  EPA will endorse the State's certification of general
          purpose governments as management agencies.

        .  EPA will not award construction  grants to those  juris-
          dictions that are not designated as management
          agencies.

 5.  Control of Nonpoint Source  Pollution

    The Clean Water  Plan  recommends that  non-structural  controls
    rather  than  the  more  expensive structural  controls be  im-
    plemented  for managing nonpoint source pollution.  EPA
    proposes  to  require  that:

        .  Prior  to  granting funds  for construction or  expansion
           of  wastewater  facilities, the general purpose  govern-
           ments  within the proposed service area must  show pro-
           gress  towards  implementing the  nonpoint source controls
           recommended by  the Clean Water  Plan.

 6.  Maintenance  of  Stream Flows

    Attainment of the recreational and fishery goals of  the
     Clean Water  Act is dependent on maintaining or providing
     sufficient stream flow to allow these uses.  The imple-
     mentation of the Clean Water Plan and several of the proposals
     recommended in the facility plans could possibly result in
     depleting stream flows and cause injury to downstream
     water right holders.   EPA's proposed actions on this
     issue are:

         .  EPA shall require a regional evaluation of this issue
           by the on-going 208 Program and  shall require each
           facility plan to evaluate its peculiar effect on
           stream flow and water quality objectives.

         .  EPA shall utilize other  agencies (e.g., Colorado
           Department of Natural Resources) to  determine the
           significance of each specific action on stream  flow
           before authorizing construction for  each proposed
           facility.

-------
7.   Water Conservation

    In the semi-arid West, water is a precious commodity, espe-
    cially for Denver and its environs.  To promote better use
    of the scarce water resource, EPA shall require that, prior
    to making a construction grant for design of the waste-
    water treatment works, the applicant demonstrate:

          efforts have been taken to reduce wastewater flows
          within the service area, and

          The design capacity  of the proposed facility reflects
          the reduction in wastewater flows.

8.   Energy Conservation

    The assessment of energy requirements in evaluating alter-
    native wastewater facility concepts and design has been
    limited to date.  To promote greater consideration of
    energy conservation in facility plans, EPA proposes the
    following action:

       .  As a requirement to receiving a grant for planning
          and design of wastewater treatment works, considera-
          tions of energy conservation technology and tech-
          niques must be demonstrated.

9.   Protection of Environmentally Sensitive Resource Areas

    The construction of wastewater treatment works potentially
    could affect environmentally sensitive areas.  The issue
    is determining what EPA's role should be in mitigating
    the impacts of EPA programs on these areas.  EPA proposes
    to adopt the following policies:

          EPA shall limit funding of projects that are located
          in, or indirectly affect, an environmentally sensi-
          tive area unless it can be shown there is no alter-
          native, or hazards and impacts have been mitigated
          in accordance with draft DRCOG Regional Development
          Policies numbered 23 through 41.

          EPA will use DRCOGfs review processes under A-95 and
          the Clean Water Plan as one mechanism for determining
          consistency of proposed wastewater projects with the
          above development policies.

-------
             EPA will  continue  to  rely  on  its  facility  planning
             and NEPA  requirements for  archaeological and  histori-
             cal sites to  provide  protection of  these cultural re-
             sources.

  10.   Enhancement  of  Recreation Opportunities

      The  location  and design of wastewater treatment works  can
      be integrated with existing  and future recreational
      facilities.   EPA proposes the following  action regarding
      this issue.

          .   As  a part of  the A-95 review  process,  DRCOG and the
             State  shall be  requested to make  a  finding that proposed
             facilities are  compatible with recreational facilities.
             Also,  the facility plans must analyze  the  potentials for
             incorporating into the proposed project recreation  and
             open space opportunities.

  11.   Funding of Wastewater Facilities for Northern Douglas County

       EPA has not  evaluated the impacts of growth  and  development
       in  the Northern portion  of  Douglas  County.   This area may
       experience rapid development over the next  20 years and as
       a result, may significantly influence the environment of  the
       Denver region.   EPA proposes the following  action.  EPA will
       not provide  funds for extension of  service  into  Douglas County
       through actions taken on the proposed Cherry Creek  and Little-
       ton/Englewood facility plans until:

             Sufficient study and review of probable effects of
             providing such service has been conducted, possibly
             leading to an environmental impact statement, and

          .  Adequate population,  land use and water quality plan-
             ning for the area to be served is prepared and inte-
             grated in the DRCOG regional  plans and the State's  Air
             Quality Implementation Plan.
12.  Other Problems and Study Needs

     The issues identified are (1) high nitrate levels in domestic
     water supplies; (2) the effects on groundwater resulting from
     increased demand to meet communities domestic water supply needs;
     (3)  the effect on groundwater resulting from septic tank leach
     fields and solid waste disposal sites; and (A) determining a
     level of protection for Barr Lake to protect defined uses.  For
     all of these issues EPA thinks that more needs to be known about
     the problem before recommending a definite set of actions and
     will require such study under the on-going 208 program.

-------
 4.  Alternatives
    Th*ee strategies for wastewater treatment facilities, and the Clean
 Water Plan recommendations were evaluated.  The three strategies are
 termed Local, Regional,  and No-action.  The Local  alternative strat-
 egy  essentially embodies the recommended alternative of each individ-
 ual Facility Plan,  except for the Clear Creek basin.  This alternative
 is very similar to  the Clean Water Plan recommendations for wastewater
 treatment facilities, which recommends construction of local and
 satellite wastewater treatment plants.  However, the Clean Water Plan
 does not call for upgrading the facilities to advanced secondary treat-
 call/?  C™Si?ered ln the Local alternative.   The Regional alternative
 calls for the transport  of areawide wastes to a central regional plant
 for treatment.   The No-action alternative is  the likely result  of no
 EPA grants for  design and construction of wastewater treatment  facili-
 ties.   The No-action alternative closely resembles the Local alter-
 native but involves delays in the construction  of facilities.

 5.  Distribution
  H    -                        °f  V°lume 2 shows the Agencies, groups,
and individuals requested to comment  on the final statement.

5'  Draft  Statement Sent to Council on Environmental Quality: May 27, 1977

    Final  Statement Sent to Council on Environmental Quality: April 11,  1973
                                               "r X^Jt.8**
                                           """•^S^
                                              ^
     £<
      3>
                                               ^ ", '\
                                                • » i'  >
Ml
                                                     \

-------
XI. INTRODUCTION
   AND OVERVIEW

-------
                             SECTION II

                      INTRODUCTION AMD OVERVIEW

Actions Covered

     Within the Denver Metropolitan Region various local agencies have
proposed or are developing proposals to construct, improve and/or
expand municipal wastewater collection and treatment systems for the
following service areas.

     1.  South Adams County
     2.  Englewood and Littleton
     3.  South Lakewood
     4.  Cherry Creek and Goldsmith Gulch
     5.  Lower South Platte
     6.  Clear Creek
     7.  Sand Creek
     8.  Westminster and Broomfield
     9.  Metropolitan Denver Sewage Disposal District No. 1
    10.  Northglenn

     Planning for these municipal wastewater collection and treatment
system modifications has and will be carried out with local agency and
EPA funds under Section 201 of the Federal Water Pollution Control Act
(Clean Water Act).  These facility planning efforts examine a number
of alternative means of achieving effluent standards derived from
water quality goals.  Examination and recommendations of regional water
quality goals and the means of implementation are provided for by Sec-
tion 208 of the Clean Water Act.  The Denver Regional Council of
Governments (DRCOG), designated 208 planning agency, has completed the
draft 208 Plan  (Clean Water Plan) and the Plan has been submitted to
EPA by the State.  As the Clean Water Plan addresses regional water
quality issues, action on the Plan is also addressed in this EIS.

     The Environmental Protection Agency has received or is anticipat-
ing requests to fund 75 percent of the construction costs for waste-
water collection and treatment facilities in the Denver Region under
Section 201 of the Clean Water Act.  EPA is also required to take
some action on the 208 Clean Water Plan.  Each of these funding
requests for proposed projects and the approval of the Clean Water
Plan represents a proposed major federal action by EPA which may have
a significant effect on the quality of the human environment.  Under
the provisions of the National Environmental Policy Act (NEPA), EPA
must prepare an Environmental Impact Statement, and consider the
environmental consequences thus disclosed before making a decision as
to whether to provide the requested funds and approvals.

     The purpose of preparing one EIS for ten project proposals and
the Clean Water Plan, instead of a separate EIS for each project pro-
posal is to provide a framework for examining cumulative regionwide

-------
effects.  Experience has shown that the regionwide environmental
effects of wastewater collection and treatment facilities for urban
areas are linked to the future growth those facilities are designed
to serve.  EPA is concerned that actions it may take to improve
regional water quality goals may jeopardize the attainment of other
environmental goals.

Overview of EIS

     The Environmental Protection Agency decided in the Fall of 1976 to
prepare an environmental impact statement (EIS) for the Denver Metro-
politan Region which addressed EPA's actions in funding wastewater treat-
ment facilities in the area.  Subsequently, EPA also decided to include
in this EIS its review and approval action on the Denver Clean Water Plan
(208 Plan) which was, at that time, under preparation by the Denver Regional
Council of Governments.  Both of these decisions were based on the belief
that future EPA actions in these two water quality program areas could
result in significant impacts to the environment of the Region.

     Major areas of environmental concern dealt with effects of popula-
tion growth, and regional development which would be accommodated, if
not promoted in certain areas, by these EPA actions.  Specifically, EPA
considered the provision of additional wastewater collection and treatment
capacity to be an issue in the Agency's efforts to attain air quality
standards in the Region. However, more questions than answers to this prob-
lem were evident during preparation of the Draft EIS.

                  What could EPA do to make compatible its
          programs to provide additional wastewater facilities
          and to improve air quality in the Region?

                  How could a Federal program involving consid-
          erable funding to support growth and development of
          the Region be best used to also promote the Federal
          and State air quality objectives for which very
          limited Federal financial assistance is available?

     While developing a consistent air quality/201 construction grants
policy was a major problem,  other regional environmental problems were
also identified and addressed.   Such regional environmental problems
included: 1)  the achievement of water quality standards acceptable
for use in fishing and swimming, 2) the control of urban runoff and
other nonpoint  pollution sources, 3) the organizational and managerial
structure ot  wastewater treatment facilities, 4) the preservation of
prime agricultural land,  environmentally sensitive, and unique areas
and sites, and 5)  the conservation of water and its reuse in the
Region, among others.

-------
     The draft EIS was released for public review and comment on June 3,
1977.  To foster greater public review of this document and discussion
of the issues, EPA supplemented the EIS publication with slide presen-
tations, questionnaires and newspaper inserts which briefly cover the
important points addressed in the EIS.  Two public hearings were held
near the end of the EIS review period to provide opportunities for
public discussion and comment in addition to the normal solicitation
of written comments.  The results of this public involvement effort
are highlighted in this section and detailed further in Volume 2 of
this EIS.

     The review period for the draft EIS ended on August 15, 1977.
During the time between the end of the draft EIS review period and
completion of this final EIS, EPA has addressed all comments that we
received with the appropriate additions, changes and discussions con-
tained in Volume 2.  Also during this period, EPA identified major
issues discussed in the comments received on the EIS for which EPA
policies or actions were needed.  Such issues and actions are pre-
sented in Volume 1 of the final EIS.  As presented in this Volume,
the  EPA actions represent proposed policies and actions which EPA
will formalize at the end of the thirty-day EIS review period.  Any
comments'received during this final review period will be evaluated
and  if determined by EPA to change the situation, thereby requiring a
change in the proposed policy or action, EPA will make changes and
notify  the public by distributing a final public notice.

      Subsequent  to  EPA's final  determination,  the individual actions
covered  by  this  EIS  (the wastewater  facility  plans and  the  Clean Water
Plan) will be reviewed  and  acted  upon in conformance with  the final
policy  or  general course of  action outlined  in this  EIS.

      EPA must take action,  under  law,  on the Denver  Clean Water  Plan
 (208 Plan)  by May 11,  1978.   EPA's review of  the Clean Water  Plan
 has been ongoing during the development  of  this EIS.   Formal  action
 on the Plan will consist  of approval,  disapproval or conditional
 approval of  the various elements  of  the  208  Plan.   The 208 Plan  ele-
ments include such items  as;  designation of  wastewater and nonpoint
 source control management  agencies,  recommendation of  nonpoint   source
 controls,  recommendation  of stream water quality classifications,  etc.
 Some of these 208 Plan elements are considered major issues and  are  so
addressed  in this final EIS.   The EPA actions of approval,  disapproval
 and conditional approval  are described on the next page.   These actions
 have various consequences involving funding for future planning, con-
 struction of wastewater treatment works, and issuance of permits for
 point source dischargers.

      If this EIS is not filed in time to complete the 30-day EIS re-
 view period by May 11, 1978, EPA will conditionally approve the Clean
 Water Plan subject to any modifications which result from the EIS re-
 view process.

-------
Possible EPA Actions on 208 Plan        Description of Action

Approval                          Certification that the elements re-
                                  quired of a 208 plan have been fully
                                  satisfied and no more work is
                                  needed to complete the plan.

Disapproval                       A determination that the 208 agency
                                  has not and will not satisfy the re-
                                  quirements of EPA's regulations on
                                  plan content or the conditions of
                                  the approved work plan.

Conditional Approval              A determination that the 208 plan
                                  requirements have not been fully
                                  satisfied, and identifies the steps
                                  that the 208 planning agency must
                                  take in order to achieve full ap-
                                  proval of its plan.

     This EIS does not attempt  to state in final terms the specific
actions EPA will  take in approving or disapproving a wastewater
facilities plan.  Rather,  this  EIS sets the basis for future actions
by EPA in the Denver Region concerning EPA funding and conditions for
funding wastewater treatment and collection facilities.  During the
preparation of  this EIS, some wastewater facility plans were avail-
able for detailed review,  others were known in more general terms and
concepts.  At the end of this EIS process, a formal review and letter
of action or comment will  be prepared for those plans which have been
completed.  This  review will include the consideration of the policies
and actions that  are described  in this final EIS.  Wastewater plans
not yet fully developed will also undergo this same review when sub-
mitted to EPA.  The present status of the wastewater facilities plans
covered in this EIS is given in Table 1.

     In taking action on each project, EPA may decide to: fund the pro-
ject as proposed; refuse to fund the project;  make funding at some
future stage of the project,  subject to the fulfillment of certain
conditions;  fund the project  only with agreement to make certain pro-
ject modifications.   These four types of actions are described
following table 1.
                                  10

-------
             Table 1

STATUS OF DENVER AREA WASTEWATER
         FACILITY PLANS
201 Plan
South Adams County
Englewood and Littleton
South Lakewood
Cherry Creek and Goldsmith Gulch
Lower South Platte
Clear Creek
Sand Creek
Westminster and Broomfield
Metro Denver Sewage Disposal Distric
No. 1 - Central Plant Expansion
Northglenn
Present Status
Plan submitted, calls for two
stage development. Stage 1,
calling for 1.5 MGD expansion,
has been approved and is under
construction. Stage 2, call-
ing for larger expansion, has
not been acted upon by EPA.
Plan has not been submitted
for EPA review.
Plan has been submitted for
EPA review and is undergoing
revision.
The City and County of Denver
has addressed certain por-
tions of the Plan. The Metro
District will complete the
Plan in conjunction with the
planning for central plant ex-
pansion (listed below).
Plan has been submitted for
EPA review.
Plan has been submitted for
EPA review.
Plan has been submitted for
EPA review.
Regional Plan has not been
submitted for EPA review.
Expansion of 1.5 MGD at
Westminster plant is under
construction.
Plan has not been submitted
for EPA review.
Plan has been submitted for
EPA review.
           11

-------
Do not fund
Fund with special conditions
POSSIBLE EPA ACTIONS ON
INDIVIDUAL FACILITY PLANS                       DESCRIPTION

Agree to fund                            75% of the eligible construc-
                                         tion costs of the project will be
                                         funded by EPA.  (After September 30,
                                         1978, 85% for innovative or
                                         alternative technologies)

                                         EPA will not fund the project
                                         as proposed at this time due to
                                         adverse and/or non-beneficial
                                         impacts.

                                         As a requirement to receiving
                                         EPA funds certain special con-
                                         ditions, such as implementation
                                         of water conservation measures,
                                         must be acted upon by the
                                         grantee within a specified
                                         time period.

                                         As a requirement to receiving
                                         EPA funds,  the grantee  agrees  to
                                         make certain project modifica-
                                         tions, such as a reduction  in
                                         additional  treatment capacity.

      Each  facility  plan will be  subject to the requirements of the
 National Environmental Policy Act which established  the EIS process.
 For  each project which is funded, EPA will either prepare an EIS
 or issue a negative declaration  stating that there are no significant
 impacts which have  not been properly mitigated.  As  a result of  this
 EIS,  it is expected that most projects will not require an individual
 EIS and that a negative declaration will be issued.
Fund with project modifications
                                 12

-------
EIS Objectives

     As an overall perspective, the following general objectives were
established for this EIS.

     (a)  To define and assess the environmental impacts of the
          Denver metropolitan wastewater facility plans and the
          208 Clean Water Program.

     (b)  To define EPA policy and decision options for assurance of
          consistency between EPA's Air and Water Programs and the
          goals of NEPA, including the options for mitigation of
          adverse secondary impacts.

     (c)  To stimulate public discussion about "desirable" environ-
          mental goals for the Denver metropolitan area, with em-
          phasis on the relationship of EPA's construction grants
          program to other Federal, State, regional and local govern-
          mental programs.

     The results of EPA's efforts to meet the first two objectives above
are discussed and presented in Volumes 1 and 2 of this Final EIS.  The
results  of efforts to stimulate public discussion, the third objective,
are presented in an EPA reference document entitled Attitudes of Denver
Residents on Environmental Issues, September, 1977.  Some highlights of
our findings about the public's environmental awareness and concern were
that:

     1.   Air quality is perceived as the Denver region's most serious
          environmental problem.

     2.   Air and water pollution, the loss of agricultural land, and
          waste of energy resources are generally attributed to
          regional growth and  to a regional land use pattern characteri-
          zed as "sprawl."

     3.   Significant institutional changes are thought necessary to
          correct these problems.  Consolidation of local  service districts,
          improvements  in land use planning  (strengthened  zoning, state
          assumption of responsibility for agricultural land preservation,
          more caution  in extension of public services), and greater regionali-
          zation of certain functions  (including establishment of regional
          service districts and regional  tax base sharing) are widely seen
          as promising  approaches.

     4.   Federal funding from the Environmental Protection Agency  is
          greatly needed for water  quality improvement; however,  there  is
          disagreement  on whether federal funds should  be  used  to pay for
          wastewater  system expansions to accommodate growth.
                                  13

-------
     5.   Public ignorance and apathy about environmental problems  is an
          obstacle to the solution of those problems.  The education of the
          public, and public involvement in environmental decisions, is
          seen as critical to the success of environmental improvement
          programs.

     6.   The environmental problems the Denver region faces are seen as
          interrelated, and solutions to those problems will require a
          degree of coordination among jurisdictions and levels of  govern-
          ment beyond that now existing in the region.

EIS Format

     This Final EIS does not use the standard EIS format normally used
by Federal Agencies.   The reason for using this modified format is  to
highlight and bring to the readers attention what EPA believes to be the
most important aspects of our proposed actions, while allowing a complete
review if desired.  This Final EIS is broken into two documents. Volume
1 being the smaller of the two, summarizes the major issues, EPA's  pro-
posed actions, reasons for these actions and possible consequences.  In
Section III of Volume 1, twelve major issue categories are discussed and
in Section IV, EPA's proposed policy and/or action regarding each issue is
defined.  Volume 2 of this EIS is a revision of the draft EIS in accord-
ance with comments that EPA has received on the draft and conforms  to the
more generally accepted EIS format and coverage.  All written comments
are reproduced in Volume 2 along with EPA's responses.

-------
111. SIGNIFICANT ISSUES

-------
                          Section III
                      SIGNIFICANT ISSUES
1.  Air Quality
    Denver has a severe air pollution problem.  In the year 1976, for
example, carbon monoxide concentrations exceeded the standard on 108
days and on some of those days levels reached three times the stand-
ard.  Last year ozone concentrations violated the standard 65 days
with levels sometimes twice the standard.  Particulate violations are
also frequent and the annual standard for nitrogen dioxide has been
equalled.

     Like many other urban areas, Denver's air pollution is largely
attributable to private automobiles.  More than 90 percent of the
carbon monoxide, 80% of the hydrocarbons, 50% of the particulates
and 40% of the nitrogen dioxide is auto caused or related. Emission
control devices are proposed to reduce, over time, the amounts of car-
bon monoxide, hydrocarbons and nitrogen dioxides emitted from each car.
Particulates will not be substantially effected by emission control
devices.

     Solutions to the air quality problem will require cleaner emit-
ting cars and less use of the automobile.  In the short-term, reduc-
tions in vehicle miles travelled  (VMT) through carpooling and better
usage of transit and other less polluting travel means (walking,
bicycling, etc.) can reduce air pollution.  This action combined with
more effective emission controls, and an emissions inspection and
maintenance program can reduce pollution even more within the next
ten years.  In the long-term, land use patterns which result in denser
settlement around the core city and activity centers will reduce
future dependence upon the automobile and help maintain reduced pol-
lution levels.

     In the Fall of 1977, Congress made major changes in the way the
Clean Air Act is structured.  Previous reluctance to use conventional
enforcement mechanisms (generally fines but also criminal action) to
force implementation of transportation control measures indicated a
need for a new approach.  This new approach encourages implementation
of air quality improvement measures through the possible use of re-
strictions on federal funding and permits after July of 1979.  In the
interim, for urban areas which cannot, in the near future, attain air
quality standards a revision of the Air Quality Implementation Plan
(State Implementation Plan, SIP)  is due early in 1979.  This plan must
show how the standards will be attained if the measures included in
the plan are implemented.  If it  can be shown that attainment of the
carbon monoxide  or ozone standards is not possible by 1982, then addi-
tional, more stringent strategies must be included in another plan to
be submitted to EPA in 1982.
                                  15

-------
     If after 1979, the Plan is approved  and being implemented,  the
 standards should be attained as quickly as  possible.   If,  however,
 the Plan is not submitted and approved by EPA  or if it is  approved
 and is not being implemented by the State and  local agencies then
 there are sanctions specified in  Section  176 of the recent Clean Air
 Act Amendments which will affect  Federal  assistance programs.   These
 sanctions include  the  elimination of funding for major public  works
 projects like federal  funding for wastewater treatment facilities,
 and limitations on permits  for construction of new stationary
 sources in the area.

     The Clean Air Act also specifies that  the 1979 revisions  to  the
 State Implementation Plan  (SIP) must include provisions for growth
 and still show attainment of  the  standards. In the future,  when  EPA
 receives requests  for  funding wastewater  treatment facilities  it
 should be possible to  determine whether or  not the facility and  the
 service it would provide are allowed for  in the SIP.  If that is  the
 case,  then the project would move forward.  In summary, the new  Clean
 Air Act requires that  any new major federal projects,  which may
 directly or  indirectly affect air quality,  be  consistent with  air
 quality implementation plans and  that these plans provide  for  attain-
 ment of air  quality standards.

     This Environmental Impact Statement  is being published prior to
 revisions to the SIP for the Denver Region. It is then incumbent
 upon the EPA to develop an  effective and  fair  interim policy for
 dealing with wastewater treatment grants  covered by this Environmental
 Impact Statement and any grant request that we might receive prior  to
 anticipated  approval of the Colorado Implementation Plan revisions.
 By July of 1979 the Air Quality Implementation Plan for the Denver
 Region must be developed by the State (in cooperation with DRCOG and
 local governments), approved by EPA and implementation initiated.
 If such action does not occur, then EPA under  provisions of the  recent
 Clean Air Act Amendments may cut  off wastewater treatment  grants
 where EPA believes they contribute  indirectly  to the  present air
 quality problems.

     It is important to note that the role  of  local and regional
 governments and officials in developing and implementing the State
 Implementation Plan will be strengthened as a  result of the  new
amendments to the Clean Air Act.   Planning  for wastewater  treatment
and collection improvements is also  largely a  local and regional
governmental  function as is most other planning  for development and
public  facilities.   Compatibility and  commonality  of more  traditional
planning efforts with the regional plan to  improve air  quality will
become  increasingly important to the  effective  implementation of  all
these plans.

    For a discussion on EPA proposed action regarding  air  quality
see Section  IV-1.
                                  16

-------
2.  Water Quality (Stream Classifications)

        The Clean Water Plan has recommended  several  changes to the
    existing water quality classifications  of stream  segments within
    the Denver Metropolitan Area.  These changes  are  summarized in
    Table 2.  The majority of these changes involve dropping the
    warm water fishery designation for the  South  Platte River down-
    stream of Dartmouth Avenue (Littleton/Englewood)  and Clear Creek
    downstream of Golden.  The Clean Water  Plan identified costs to
    achieve the 1983 National goals of the  Federal Water Pollution
    Control Act Amendments of 1972.  These  costs  are  presented in
    Table 3 and serve as the principle reason for the proposed down-
    gradings.  These costs may be too high  in that they assume
    treatment to control phosphorus which has not been shown to be
    necessary to meet the 1983 goals.

        EPA views these recommended changes as downgradings from
    the present classification.  All such downgradings are subject
    to EPA scrutiny to determine whether or not each  can be justi-
    fied based on the following three criteria:

        1.   The existing designated use for the stream segment is
            not attainable because of natural background water
            pollutants;

        2.   The existing designated use for the stream segment is
            not attainable because of irretrievable man induced
            conditions; or

        3.   Attainment of the existing designated use for  the stream
            segment would result in substantial and widespread ad-
            verse economic and social impact.

        The State, in its certification of  the Clean  Water Plan,
    addresses the problem of downgradings recommended by the Denver
    Regional Council of Governments with, the  following condition:

            "State certification of the plan  does not mean en-
            dorsement of the recommended stream classifications.
            The recommendations included in the plan  will  be con-
            sidered by the Commission to guide water  quality
            decision-making during the period until the Commis-
            sion reclassifies those streams according to the
            revised water quality stream classification system
            currently under consideration.  When  reclassifying
            the waters of the 5-county Denver regional area, the
            Commission will consider:

            a.  recommendations and supporting information in the
                208 plan.
                                 17

-------
                           TABLE 2

      COMPARISON OF EXISTING AND CLEAN WATER PLAN RECEIVING
              STREAM (WATER QUALITY) CLASSIFICATION
Facility
                                  Existing
                               Classification
Clean Water Plan
Classification
Englewood/Littleton
South Lakewood
MDSDD#1
Golden
Sand Creek
South Adams County
Brighton
Big Dry Creek
Boulder
Longmont
Erie
Lafayette
Louisville
Glendale
Lyons
Niwot
Mountains
Plains
                                     J
                                      4.
                                     B

                                     A,
                                     B
 2
 2

 2
 2
 2

\

52
                                        B
2, 3, 8
2, 3, 8
2, 3, 8, A
2, 3, 6, 7, 8, A
2, 3, 8, A
2, 3, 8, A
2, 3, 8, A
2, 3, 5, 8
1, 2, 3, 5, 6, 7, 8
2, 3, 8
2, 3, 8
2, 3, 8
2, 3, 8
2, 3, 6, 8, B
2, 3, 5, 6, 7, 8
2, 3, 8
1, 2, 3, 4, 6, 7, 8
2, 3, 8
Existing -
AI - Cold water fishery and primary contact recreation
A2 - Warm water fishery and primary contact recreation
BI - Cold water fishery and secondary contact recreation
B^ - Warm water fishery and secondary contact recreation
                                       Warm water biota
                                       Water supply - groundwater
                                       Water supply - surface water
                                       Wildlife
 Clean Water Plan -
 1.  Primary contact recreation      5.
 2.  Secondary contact recreation    6.
 3.  Agriculture                     7.
 4.  Cold water biota                8.
 A.  Provided municipal raw water supplies  are not  degraded.
 B.  The existing Master Plan for Cherry  Creek completed by the Urban
    Drainage and Flood Control District, the City  and County of Denver,
    the City of Glendale and Arapahoe  County concluded that channel
    improvements will increase the  creek's environmental suitability
    for wildlife and aquatic life habitats.  Therefore, the classi-
    fication may be modified to include  a  warm  water  biota classifica-
	tion following the channel improvements.	__
 Source:  "Clean Water Plan," July 1977,  DRCOG,  page  11.
                                 18

-------
                      TABLE 3

  SUMMARY OF COSTS TO ACHIEVE THE 1983 NATIONAL GOAL

Pollution
Source
Present Worth
Costs
($x!06)
Annual.
Costs^'
($x!0b)
Point Sources
  Municipal                   407                       37

Nonpoint Sources
  Urban Runoff
Structural
Nonstructural
Agricultural
Irrigated
Dryland
Grand Total
Cost ($/PE/Yr)(2)
1,861
348

133
24
2,773
-
183
29

12
2
263
146
(1)  Annual costs include operation and maintenance of treatment
     facilities, the amortized capital costs  (6-3/8% for 20 years)
     and the costs for implementing and operating the nonstruc-
     tural controls.

(2)  Assumes a population equivalent  (PE) of  1,802,500 people
     (1985).
Source:  "Technical Report," October 1977, DRCOG, page 9-89.
                              19

-------
       b.  testimony presented at public hearings on the issue.

       c.  recommendations and requirements of 208 plans for
           adjoining regions.

       d.  goals, objectives, and requirements of appropriate
           State and Federal statutes and regulations."
     The State through this condition has decided  to wait before
passing judgment on the adequacy of  the documentation  for down-
gradings.  In order to assist the State in its evaluation, DRCOG
has been requested to prepare an Addendum to the Plan  which con-
solidates all the information that relates to the  Plan's recom-
mended stream classifications (see Appendix A).

     The State on January 31, 1978 and February 6,  1978 held
public hearings on proposed revisions to the existing  water
quality standards and classification system.  Once the proposed
revisions are adopted by the State,  classification of  individual
stream segments will be accomplished through a subsequent set of
public hearings.  The State does not have an established schedule
for reclassifying streams after adoption of the revised water
quality standards.

     Stream classifications determine the levels of treatment
required for discrete dischargers and serve as a basis for de-
fining effluent limitations that are found in NPDES permits.
Table 4 shows the difference in effluent requirements  for muni-
cipal dischargers between the existing stream classifications
and those proposed by the Clean Water Plan.

     The State's certification of the Clean Water Plan recog-
nizes that failure to adopt the Plan's recommendations for stream
classifications would result in different discharge requirements
than those presented in the Plan.   The State addresses this
potential problem with the following conditions:

     1.   DRCOG,  with State assistance,  is to revise the waste
         load allocations  as necessary following  stream classi-
         fications by the  Commission.  Such revisions shall be
         included  in the first annual plan update provided that
         the  streams are reclassified in time for this to be
         accomplished.
                             20

-------
                           TABLE  4

      COMPARATIVE  EFFLUENT LIMITATIONS  -  Clean Water Plan
                 versus  Existing Classifications
                  (Municipal  Dischargers Only)

                                           Parameters
Discharger
Englewood/Littleton
South Lakewood
MDSDD#1
Golden
Sand Creek
South Adams County
Brighton
Big Dry <5reek
Boulder
Longmont
Erie
Lafayette
Louisville
Glendale
Evergreen
Genesse
Kittridge
Lake Eldora
Lyons
Morrison
Mountain W fit S
Nederland
Niwot
West Jefferson
Wheatridge
Arvada
Broomfield
BOD52
(mg/1)
Clean
Water Exist-
Plan ing
30
30
30
30
30
30
30
20
20
30
30
30
30
30
20
20
20
30
30
20
30
20
30
20
-
-
-
20
20
20
-
20
20
20
30
30
30
30
30
30
20
30
-
30
30
-
30
-
30
20
30
20
20
30
NH3-N3
(mg/1)
Clean
Water Exist-
Plan ing
-
-
-
-
-
-
-
1
1
-
-
-
-
-
9
9
9
-
-
9
-
1
-
9
-
—
-
3.0
3.0
1.5
-
3.0
3.0
3.0
2.5
4.3
6.8
1.5
1.5
1.5
3.0
11.0
—
11.0
15.0
-
15.0
-
15.0
15.0
11.0
3.0
3.0
2.5
<
(mg/1)
Clean
Water Exist-
Plan ing
.5
.5
.5
.5
.5
.5
.5
.02
.02
.5
.5
.5
.5
.5
.02
.02
.02
.5
.5
.02
.5
.02
.5
.02
—
—
—
-
-
-
-
-
-
—
—
—
-
—
—
—
-
—
—
—
—
—
—
—
y
—
—
—
••
—
Notes:
1.  The parameters listed are those which are critical to maintaining
    minimum levels of dissolved oxygen in stream or are critical from
    the perspective of fish toxicity and which are commonly found in
    municipal wastewater effluents.
2.  30 day average
3.  7 day average
4.  instantaneous
                                  21

-------
     2.  The State will revise all NPDES discharge permits upon
         their expiration to conform with the waste load alloca-
         tions (upon State adoption) referred to in the above
         condition and other pertinent constraints called for
         in the plan and State regulations.

     For a discussion of EPA's proposed action regarding attain-
ment of water quality goals and stream classification in the
Denver region see Section IV-2.
                            22

-------
3.  Wastewater Facilities Organization (Siting) and Treatment Processes

         The issue of facilities siting addresses the question of
    where should wastewater treatment plants be located to best
    satisfy environmental, economic, and social criteria.  The criteria
    chosen and the emphasis placed on each will determine the best
    location for a wastewater facility within any specified study
    area.  For example, the water quality plan that preceded the Clean
    Water Plan used economics as its principle criterion for evalu-
    ating the best location for wastewater treatment plants.  Based
    on this criterion the 1974 plan recommended a configuration of
    eight facilities as the best economic mix to minimize the cost
    for collection, treatment, and disposal of wastewater in the five
    county study area excluding the mountain communities.  Since the
    time when the Denver Regional Council of Governments (DRCOG) adopted
    the 1974 Plan, several events have occurred to modify this plan.

         In the early stages of the development of the Clean Water
    Plan it became apparent that the eight facilities configuration
    was not politically acceptable and also, based on other criteria
    besides economics, this recommendation would not provide an
    optimum configuration that would satisfy the complete set of
    criteria.  The most notable example of political and social fac-
    tors modifying a portion of the 1974 Plan  is the experience sur-
    rounding the proposal for sludge disposal  in Weld County.  The
    Weld County site was to serve as a regional sludge disposal site
    for three regional wastewater facilities:  the St. Vrain, Big Dry,
    and Denver Metro  (MDSDD#1).  Attempts to implement this proposal
    proved to be unacceptable to the residents of Weld County.

         The Clean Water Plan reflects a DRCOG policy to encourage
    reuse of wastewater wherever feasible.  This policy  did not
    influence the decision making of the  1974  Plan.  Consequently,
    the recommendations for facility siting in the Clean Water Plan
    differ from the  1974 Plan.  The Clean Water Plan identifies the
    continuation of  sixteen facilities as opposed  to the eight
    facilities recommended in the 1974 Plan.   With the designation of
    Northglenn as a management agency, the number in the  Clean Water
    Plan probably will increase to  seventeen.  Table 5 identifies
    the facilities as recommended in each plan.

         The individual facility plans considered  in this EIS  are
    consistent with  the Clean Water Plan  except for two  cases:   (1)
    the Clean Water  Plan  recommends a facility be  located in  the Clear
    Creek drainage while  the  Clear  Creek  facility  plan recommends  that
    all flows from this drainage be treated at the Metro facility
     (MDSDD#1); and  (2)  the Clean Water Plan identifies the  Northglenn/
    Thornton flows being  treated at the Metro  facility while  the Lower
                                  23

-------
                         TABLE 5

   RECOMMENDED WWTP'S:  Clean Water Plan versus 1974 Plan
Clean Water Plan

Englewood/Littleton
1974 Plan

Englewood/Littleton
South Lakewood
MDSDD#1
Glendale
MDSDD#1
Clear Creek  (Golden)
 Sand Creek
Clear Creek


Sand Creek
 South Adams  County
 Brighton
 Big Dry  Creek
 Northglenn
 Boulder
Big Dry/South  Platte
Big Dry Creek
                                    Boulder
 Longmont
 Erie
 Lafayette
 Louisville
 Lyons
 Niwot
 St.  Vrain
 1.   The Clean Water Plan has not been revised to reflect a
     WWTP to treat Northglenn's wastewater separate from
     Metro.
                                24

-------
South Platte facility plan recommends that all flows north of
100th Avenue (Northglenn and portions of Thornton) be treated at
the Big Dry Creek facility or at Brighton.  The Northglenn facility
plan recommends treatment of Northglenn's and Thornton's flows at
a different site located in Weld County.  DRCOG and the State Water
Quality Control Commission have accepted the Northglenn proposal.

     The draft EIS discussed three basic alternatives for munici-
pal point sources:   (1) the No-action alternative; (2) the
Regional alternative; and (3) the Local alternative.  The salient
features of these alternatives are summarized in Table 6.  Gen-
erally, the Regional alternative most closely resembles the eight
plant configuration recommended in the 1974 Water Quality Manage-
ment Plan for the Denver area.  The Local alternative is generally
a composite of the recommended alternatives of the ten facility
plans being considered by this EIS except for the Clear Creek
service area, where the facility plan recommends transporting all
waste to MDSDD#1 instead of using a satellite facility.

     The issue of treatment processes involves the question of
what type of treatment should be implemented to best achieve
desired goals.  Treatment processes generally fall into the fol-
lowing categories: biological treatment, physical/chemical treat-
ment, and land treatment/reuse.  All of the facility plans
covered by this EIS recommend a biological or physical/chemical
treatment process for final treatment.  Two facility plans, West-
minster and Northglenn, have reuse features whereby the effluent,
after treatment, is discharged to an irrigation canal or storage
reservoir for use by farmers.  Presently, these reuse features
are considered separate from the treatment process itself.  The
Colorado Water Quality Control Division has defined irrigation
canals as water of the State which would require a minimum of
secondary treatment before discharge to the canal would be
allowed.

     EPA has a policy of not funding unnecessary pretreatment
requirements for those treatment processes where land application
or reuse are considered part of the treatment process.  In order
for EPA to determine what is necessary pretreatment for a land
application system, the total treatment system will need to be
predesigned.  Because land application is site specific, EPA does
not have any criteria, which can be applied nationally, to deter-
mine the necessary pretreatment requirements for a land applica-
tion system.

     On October 3, 1977, Douglas Costle, the Administrator of EPA,
issued the following policy:  "(EPA) will press vigorously for
publicly owned treatment works to utilize land treatment processes
to reclaim and recycle municipal wastewater."  EPA's rationale for
                             25

-------
                                                                      Table  6
                                  SUMMARY  OF  ALTERNATIVES
to
                                   Servlci Area

                                 South Mama




                                 Englewood/Ltttleton





                                 South Lakewood
                                 Cherry Creek/
                                   Coldsmlth <;ulc.h
                                 Lower South Platte
                                 (Hear Creek
                                 Sand Creek
                                 Bloomf leld/
                                   Westminster
                                 Northglenn
                                 HOSUO II
                                                                    Local  Alternative
                                                     Regional Alternative
                                                                                                                                                        No-Action Alternative
Maintain existing plant, add 1.75 mgd
1978, and final 1.75 mgd capnclty
addition In 1986 for a total capacity
of 6 ngd.

Addition of ammonia and chlorine
removal for 20 mgd capacity by 1979.
Further expansion of |olnt plant to
total capacity with AWT to 30 mgd In
1982 and 40 mgd In IV'U.

Enlarge existing plnnt, Improve
sludge handling fad lit Ice; capacity
expanded from 2 mgd to 1 mgd.
System of Interceptors to carry
expected 1985 flow from upper Cherry
Creek to Norths I de/HOSIM) II complex.
Provision for AWT satellite plant
In 1985.

New plant for flows from Brighton,
1st, 2nd and 3rd creeks.  Flows from
lower Thornton used by Northglenn In
agricultural exchange.  Remainder of
area flows to MOSDD II and South Adun«
County Water Sanitary District.

New Plant with 6.5 mgd cnpuclty In
1983 on Clear Creek.  AWT for reuse.
Additional flows to MOSDI) #1.

Expansion of existing Aurora plimt
to 2 mgd with reuse.  Remainder of
flows to MDSDD II.
Expansion of existing Big Dry Creek
plant to 9 mgd by 1985 with land
application/agriculture reuae.

Flows to Bull Canal Reservoir for
pretreatment and storage/use In
agricultural exchange of 5 mgd by
1982.

Addition of ammonia removal for total
plant capacity of 190 mgd by 1983.
Option for reuse and successive use.
Add 1.25 mgd activated sludge  capacity
In 1977, abandon plant in 198S,  all
flows to MDSDD II.


SHIM as local alternative except flows
over 20 mgd transported to MDSDD 11.
                                                                                                        Abandon existing plant and transport
                                                                                                        nil  flow  to NorthsIde/MDSDD 11
                                                                                                        complex.
Same an local alternative except
additional  Interceptors added  In  1985
In tleu of  AWT Cherry Creek satellite
plant.
All flows transported to MDSDD II
except flows I rum Brighton,  1st,
2nd and Ird creeks to new plant.
Parallel Clear Creek Interceptor to
transport all basin flow to MDSDD 11
fur treatment.

Parallel Sand Creek interceptor to
transport flow from entire basin to
MDSDD II.  Abandon existing Aurora
plant.

Maintain existing plants with excess
flow lu MDSDD II.
                                                                                                        Al I  flows  to MDSDD  II,
Plant expansion with ammonia removal
for total capacity by 1990 of 260-
270 mgd.
Add 1.7} mgd capacity  In
1978,  final 1.7} ORd added
in 1990.
Addition of ammonia and
chlorine removal  delayed
until 1982.  Expansion to
30 mgd delayed to 1986.
Maintain existing plant,  and
service area,  transport
effluent to Northslde/MDSDD
II complex.

Same as local  alternative
except construction of
interceptors delayed two
years, plans for satellite
plant abandoned.

Same as local  alternative
except delayed four years,
and lower Thornton flows  to
Westminster.
                                                                                                                                                     Same as regional  alternative
                                                                                                                                                     except delayed three yeury.
Same as regional alternative
except delayed three years.
Expansion of existing Big
Dry Creek plant from 2.5 mgd
by 1985.

Same as regional  alternative
Addition of ammonia removal
facilities delayed until
1985.

-------
   3 policy is that "land treatment processes are capable of achiev-
ing removal (of pollutants at) levels comparable to  the best
able advanced wastewater treatment technologies while  achieving
                                        i-     	•_. . 	\    T7T1 A ' «
                                                       EPA's
ciU-Lc du.v am-c.u »vt*i_» w.-
additional benefits"  (e.g., recycling of nutrients).
preference for land treatment  is  emphasized  in  the  October
policy paper by the following  statement:
         "...if  a method that encourages water conservation,
         wastewater  reclamation,  and reuse is not recommended
          (for  implementation), the applicant (will) be required
         to provide  complete justification for the rejection
         of land treatment."

      For a discussion of EPA's proposed action regarding waste-
water facilities organization and treatment see Section IV-3.
                                21

-------
4.  Management and Institutional Arrangements

         The draft EIS addressed in some detail the issue of govern-
    mental arrangements in terms of their effectiveness in implement-
    ing environmental programs to mitigate the adverse impacts of
    growth and development.  The public apparently also understands
    the need to introduce institutional changes in order to adequately
    address some existing environmental problems in this Region (see
    EIS Objectives in Section II).  Government and the public have
    recently been struggling with this issue in considering the for-
    mation of a Metropolitan Council to replace DRCOG with strengthened
    regional planning powers and, under some proposals, direct authority
    over certain services, such as wastewater treatment.

         The Clean Water Plan addressed consolidation of wastewater
    treatment authorities.  The July, 1977 Clean Water Plan recommended
    to the Governor that 33 management agencies be designated to imple-
    ment the point source aspects of the Plan that affect municipal
    government.  At the December, 1977 meeting of the Denver Regional
    Council of Governments this number was increased to 34 when the
    Council approved Northglenn's request to be recommended as a
    management agency for designation by the Governor.  Of the 34
    agencies recommended for designation, 19 are special purpose dis-
    tricts.

         The Clean Water Plan proposes that the 34 agencies eventually
    be reduced to eight organizations.  This Plan suggests a time frame
    of five years from the date when EPA approves the Plan to implement
    the proposal.  The Plan promotes the formation of water quality
    associations to serve as the management agency for eight geo-
    graphical areas (basins) within the 5 county Denver metropolitan
    area.  These associations would be organized initially based on
    memorandums of understanding among the members of each association.
    The agencies recommended for membership in each association are
    identified in Table 7.  The proposed boundaries for each associa-
    tion are shown in Figure 1.  To date, none of the associations
    have been organized.

         In certifying the Clean Water Plan the State designated the
    15 general purpose governments and the Metropolitan Denver Sewage
    Disposal District #1, as recommended by DRCOG, without conditions.
    South Lakewood Sanitation District, South Adams County Water and
    Sanitation District, Erie Water and Sanitation District, and the
    St. Vrain-Left Hand Conservancy District were temporarily desig-
    nated for a two year period.  The State did not act upon the Plan's
    recommendation to designate the 15 other special districts.  The
    management agencies designated by the State are identified in
    Table 7.
                                   28

-------
 PAGE NOT
AVAILABLE
DIGITALLY

-------
                            TABLE 7

        PROPOSED AREA OR BASIN ASSOCIATION AND DESIGNATED
                       MANAGEMENT AGENCIES
Basin or Area Association
Designated Management Agencies
Littleton-Englewood Water
  Quality Association
Littleton*
Englewood*
Metro Water Quality
  Association
Aurora*
Arvada*
Denver*
Glendale*
Brighton*
South Lakewood Sanitation District
Northwest Lakewood SD  ,
South Adams County W&SD
Hi-Land Arces W&SD
Clear Creek Valley W&SD
Wheat Ridge Sanitation District
Metropolitan Denver Sewage Disposal
  District Number One (MDSDDtfl)*
Big Dry Water^Quality
  Association
Broomfield*
Westminster*
Northglenn*
Coal Creek Water Quality
  Association
Erie Water and Sanitation District
Lafayette*
Louisville*
Boulder Water Quality
  Association
Boulder*
Nederland*
Lake Eldora W&SD
St. Vrain Water Quality
  Association
St. Vrain-Left Hand Water Conservancy
  District
Jefferson County Mountain
  Water Quality Association
Evergreen Sanitation District
Genesse W&SD
Kittredge W&SD
Morrison Sanitation District
Mountain W&SD
West Jefferson County SD	
Plains Water Quality
  Association
Deer Trail*
Bennett Sanitation District
Byers W&SD
Strasburg W&SD	
Notes:
* Designated by the State
1.  Temporary designation received from the State for two years.
2.  Northglenn does not appear in original table
Source:  "Clean Water Plan," July, 1977, DRCOG, page 27.
                                  31

-------
      The State has requested DRCOG to reevaluate the management
 agency recommendations for the Jefferson County Mountain Area,
 Boulder County, and special districts.  According to the State;
"the reevaluation should focus on establishing an active manage-
 ment role for general purpose governments for point source manage-
 ment in these areas.  The following criteria should be used in
 establishing revised management agency recommendations:

     a.  have management jurisdiction over the entire area and
         replace the provision for temporary management agencies
         contained in the plan.

     b.  have capabilities to relate decisions between growth and
         development and associated services.

     c.  provide for coordinated management over both point and
         nonpoint sources.

     d.  incorporate management responsibilities over package
         treatment plants and septic tanks."

      Other conditions placed on the designation of management
 agencies are in the State's January 10,  1978 certification letter
 as found in Appendix A.

      Subsequent to the Governor's certification of the Clean
 Water Plan, legal counsel for several of the special districts
 that were not designated as management agencies have written  the
 Governor and EPA to express disagreement with  the action  taken by
 the State.  The controversy surrounding  the designation of special
 purpose districts as management agencies stems from an effort
 within State government to promote agencies with broader  author-
 ity than just wastewater collection,  treatment, and disposal.  As
 indicated in a. through d. above.

      The Clean Water Plan did not recommend any management agencies
 for implementing the nonpoint source  sections  of the Plan.  The
 State's certification letter called for  a process which will  define
 nonpoint source management agencies as part of the first  plan
 update and which is consistent with the  State's nonpoint  source
 framework plan.  To the extent possible, the State expects the
 plan update to recommend agencies for the control of nonpoint
 sources.

      For a discussion on EPA's proposed  action regarding  manage-
 ment and institutional arrangements  see  Section IV-4.
                                32

-------
5.  Control of Nonpoint Source Pollution

         Nonpoint sources of pollution contribute significantly to the
    degradation of the Region's water quality.  In order to meet, year
    around, the water quality standards which may be required for fish-
    able and swimable waters, significant controls of nonpoint sources
    will be needed.  Urban runoff is the major nonpoint source problem
    within the Denver Metropolitan Region.  The Clean Water Plan indi-
    cates that phosphate and coliform pollution are the most serious
    problems caused by urban runoff.  However, phosphate pollution
    should be examined on a site specific basis and such an evaluation
    has not occurred which would justify phosphorous removal at this
    time.  Urban runoff also introduces toxics, detergents, pesticides,
    and industrial chemicals, etc., into the water environment.  Gen-
    erally, less is known about the effects ojE nonpoint pollution given
    the many substances which are washed, periodically and in large
    quantities, to the Region's streams and creeks.

         The Clean Water Plan makes the following general recommenda-
    tions for controlling urban runoff.

         1.  "The Urban Drainage and Flood Control Manual" should
         '   be used in the review of development plans and con-
             formance with site plans during construction should
             be enforced.

         2.  For already developed areas, it is recommended that
             governmental agencies initiate or improve on the
             following types of urban runoff control practices:

             a.  Catch Basin Maintenance

             b.  Street sweeping and parking cleaning

             c.  Improved leaf collection

             d.  Eliminate unnecessary street salting; minimize
                 sanding

         3.  For developing areas it is recommended that governmental
             agencies implement the following controls:

             a.  Environmental ordinances with a view to improving
                 water quality

             b.  Site plans with sediment and erosion control features

             c.  Performance standards such as:  (1)  natural features
                 such as trees, groves, natural terrain and waterways
                 shall be  preserved wherever possible; (2)  wherever
                 feasible  natural vegetation shall be retained and
                 protected, etc.
                                 33

-------
         d.   Grading ordinances

         e.   Littering ordinances

         f.   Zoning ordinances with incentives for using water
             pollution control measures in design

         g.   Subdivision regulations with water pollution control
             components

         h.   Economic incentives

     The cost for implementing a full scale non-structural,
nonpoint sources control program would be approximately equal to
the $29 million per year cost identified for non-strutural urban
runoff controls in Table 3.

     Other nonpoint source control recommendations of the Clean
Water Plan include  (1) a permit system to control water quality
problems associated with individual waste disposal systems and
(2) endorsement of  the soil conservation practices that are im-
plemented by various agricultural institutions.

     The State's certification of the Clean Water Plan includes
the following condition relative to non-point sources:

              The first annual plan update is to include a
         definition of the processes that are being or will
         be followed in identifying and controlling nonpoint
         sources resulting from urban runoff, construction,
         irrigated  and dry-land agriculture, and septic
         tank systems consistent with the State's nonpoint
         source framework  (scheduled to be completed in
         early 1978).  That definition of processes is to
         include the objectives, long and short-term reme-
         dial measures, management agencies and functions
         and possible regulatory controls.  A draft of this
         work should be made  available to the State for its
         review and comment prior to its inclusion in the
         first annual plan update.

     The above condition is process oriented; that is, it  is
requesting DRCOG to define how they intend to arrive at the
appropriate answers for defining and controlling nonpoint  source
pollution.  At the  same time, it suggests that  the State has  no
clear  idea of how  to  arrive at those answers or determine  what is
an adequate nonpoint  source program.

     For  a discussion about EPA's proposed action  regarding non-
point  pollution control see Section IV-5.
                               34

-------
6.  Depletion of Stream Flows

     The issue of depletion of stream flows is a very broad one involving
water availability and water usage by municipalites, industry and agri-
culture through their exercise of water rights.  However, the issue
which must be examined in  the context of  the actions before EPA, is
much more narrow in  scope, although  still complex.  EPA is concerned
about the potential  effects of funding some wastewater facilities which
remove water from the stream and may result in lowering in-stream bene-
ficial uses  (fishing, swimming, etc.) or  non-attainment of those uses
where presently proposed.

     In general terms, stream flows  determine, along with the quality
of the water and the stream habitat, the  in-stream  uses which the river
or creek support.  The diversion of  water for uses  outside the aquatic
environment may significantly alter  the stream flow.  The importation
of water from the Western  Slope has  increased supplies of water to the
Denver Region and resulted in increased stream flows in this area in
some streams during  certain times of the  year.  The use of this water
has dewatered streams in the Region, especially during the summer
irrigation season.

     The goals of EPA's water quality program are to attain a level of
water quality needed to provide fishable  and swimmable streams and to
eliminate the discharge of pollutants to  these streams.  These goals
may not always be achieved, for a variety of reasons, but this must be
evaluated and determined for each stream  reach.  In the Denver Region,
most streams are presently classified for fishery uses but not for
swimming.  The Clean Water Plan generally recommends that the the South
Platte River and its tributaries in  the Denver Metropolitan area be
downgraded to remove the fishery designation  (See Water Quality, Section
III).  One important factor in the attainability of a viable fish
population in the streams  of the Denver Region is the amount of flow
maintained in the stream throughout  the year.

     It is clear that present water  diversions dewater many of the
streams in this region and reduce the potential for in-stream uses.
This is not  the issue which EPA is addressing directly here, although
it is an important consideration.  Wastewater facilities which propose
to either centralize treatment, or to discharge to  an irrigation ditch,
thereby eliminating  existing discharges to streams, have the potential
of carrying  away the water resource  necessary to provide for stream
flows adequate to maintain or attain in-stream uses.  Where such in-stream
benefits are not achievable, because of existing water diversions,
habitat conditions or excessive costs for control of nonpoint pollution
sources, then the impact of a change in the discharge of treated
wastewater may not be of great concern.

     In the  Denver Region, proposals for  centralization of wastewater
treatment at the Denver Northside/Metro Complex may affect future stream
flows in Clear, Sand and Cherry Creeks.   Presently, of these three streams
                                 35

-------
only Clear Creek  is  classified by  the State as  a warm water fishery
and for  secondary contact  recreation  (boating,  asthetics,  etc.,  but
not swimming).  The  Clean  Water  Plan  does  not recommend any of these
three  South Platte tributaries for classification as a fishery,  but
all are  recommended  for  secondary  contact  recreation.   However,
this plan does recognize the  existence of  a warm water fishery in
Clear  Creek with  flow augmentation.   In Sand Creek the proposal  to
convey the largest portion of wastewater to the central complex  for
treatment and to  recycle a smaller portion may  jepardize secondary
contact  recreation.   It  is presently  not known  to what extent  conveyance
of wastewater to  the Northside/Metro  Complex from these areas  will
affect the stream flows  and the  designated or potential in-stream uses.

     In  the Big Dry  Creek  basin  (Broomfield and Westminster) proposals
for exchange of treated  wastewater for municipal use of agricultural
water  may result  in  depletion of flows in  this  Creek.   Historically,
flows  in Big Dry  Creek have been augmented by discharges from  wastewater
treatment plants  in  that area.  As a  means to gain additional  water
for domestic use  and to  preserve irrigated agriculture, communities
in the Northern Denver area have made water exchange agreements  with
irrigation companies.  These  agreements would require that the discharge
point  for treated wastewater be moved from the  Creek to irrigation
ditches  resulting in reduced  stream flows.   These proposals have the
benefit  of removing  pollutants from the stream  but may still adversely
affect in-stream  uses due  to flow  depletion.  The Big  Dry  Creek  is
presently not classified by the State for  any beneficial use.  The
Clean Water Plan  has  recommended that Big  Dry Creek be classified as a
warm water fishery.   The impact of  the proposals to discharge  to
irrigation ditches rather  than to  the Creek on  this recommended  classifi-
cation is presently  not  known.

     Another potential problem which  may result from a change  in the
discharge of treated wastewater is  a  conflict over water rights.  The
establishment of water rights is a  judicial process in which EPA is not
involved.  However, EPA  must protect  the federal investment in these
projects, should  a water rights conflict exist.   This  does not mean
that EPA would in any way  get involved in  a water rights dispute.
Rather,  in funding a wastewater treatment  project,  EPA's concern over
water  rights is that  there be reasonable assurances that any dispute
can be settled so  as not to jeopardize the  usefulness  of the project.
Such assurances should occur during the planning process and certainly
prior  to providing funds for project  construction.

     For a discussion about EPA's proposed  action  regarding depletion
of stream flows,  see Section IV-6.
                                  36

-------
7.  Water Conservation

     Encouraging water conservation is a position that EPA supports.
Conservation of water use can benefit the environment by maintaining
present stream conditions which support our natural environment.  In
the semi-arid West, where Denver is located, the easily developed
sources of water are being heavily utilized.  Additional water sources
will require the development of more remote, expensive sources, which
may include significant environmental impacts, unless conservation and
reuse of our water resource is increased.  Water conservation can also
result in reduced public expenditures for water supply and wastewater
treatment facilities. In funding the proposed wastewater treatment
facilities, the benefits of water  conservation  can  be directly achieved
through a reduced need for excess  capacity,  if  sizing reflects  the
effects of water conservation.

     The Clean Water Plan for  the  Denver region assumes  increased
sewage flows from residential  uses as  follows:

              1975     53  to  65 gallons/person/day
              1980     56  to  68 gallons/person/day
              1990     61  to  73 gallons/person/day
              2000     66  to  78 gallons/person/day

These  figures do not  reflect per capita sewage generation for the indus-
trial,  commercial  or  public  sectors.   When all sources are considered,
per capita wastewater flows  are projected to increase principally due
to residential  water  use as follows:

               1975    122 gallons/capita/day
               1985    130 gallons/capita/day
               2000    132 gallons/capita/day

 Figured in terms of total wastewater treatment capacity, this increase
 in per capita wastewater production will require an additional capacity
 of 13 million gallons per day in  1985 and 23 million gallons per day in
 2000   In the year 2000, this is  an increase of 8  percent over a
 required treatment capacity of 272 million  gallons/day assuming the
 existing rate of wastewater production.

      In a draft report prepared by the  Denver Regional Council of
 Governments on the Regional Water Supply Plan,   (January, 1978) the
 effects of assuming an increasing residential water demand  and of
 assuming no increase  in demand  is evaluated.   In  this draft report the
 difference in  total water demand  for  these  two assumptions  (increasing
 demand per person vs.  static  demand) was not  sufficient  to  preclude  the
 need for  additional water in  the  Denver region, but did reduce total
 demand by  23,000 acre feet  per  year  or  about  4 percent  by  the  year
  2000.  In the  year 2010,  this reduction amounted  to 6  percent  of  the
  total demand.  Quoting from this  draft  report:
                                   37

-------
                "In an analysis  of per capita water use rates of the
                Denver Water Board system for the years 1960 to 1974,
                the Denver Research Institute found that residential
                water use in the City and County of Denver showed no
                definite trend and that the commercial, industrial
                and public water use rates were virtually constant.
                The analysis did,  however, indicate that per capita
                water use for residential units outside the City of
                Denver was increasing.

                Whether suburban residential units continue to use
                more water or whether per capita water  use begins to
                approach a constant rate may depend on  several factors
                already mentioned  in Section III:  a trend toward
                greater density  in housing patterns in  condominum and
                apartment  developments,  a leveling off  in real income
                and increasing awareness of the need for conservation.
                Another significant consideration is that most newer
                homes are  equipped with a full range of appliances in-
                cluding washing  machines,  dishwashers and garbage
                grinders and are unlikely to be adding  more water-
                using appliances."

     Water conservation can and is,  in some communities,  being used as
a means to supplement or  extend existing  water supplies while reducing
wastewater treatment capacity requirements.   In a review of studies and
reports dealing with the  effects  of  water conservation,  (Fact sheet,
Encouraging Flow Reductions  Under  Construction Grants  Program",  1977)
EPA estimated that:

     1.  Retrofit  of water  saving  devices  such as toilet  dams and fine
         spray  shower  heads  could  reduce  community wastewater flows by
         15 to  20  percent.

     2.  Laws or ordinances  requiring installation of  water saving  plumb-
         ing fixtures  and appliances in new homes  and  other habitations
         could  reduce wastewater flows  from new developments  by  30  to 35
         percent.

     These reductions  in wastewater  generation can be  achieved  through
the use of water-saving devices, appliances, and  plumbing  fixtures, such
as fine spray shower heads,  low flush toilets, washers with suds  savers,
and flow restrictors.  Also, water metering and pricing will  promote water
conservation, although  they are most effective in  reducing  usage  during
the lawn irrigation season which does not affect wastewater generation.
Tables 8 and 9 give a  summary of the potential benefits for both  retrofit
and new home water conservation programs.

     For a discussion of EPA's  proposed action regarding water conserva-
tion see Section IV-7.
                                   38

-------
                    TABLE 8 - RETROFIT  SAVINGS  FOR  INSTALLING  DEVICES  IN TYPICAL HOUSEHOLD (SUBURBAN)
                                                 (60 GPCD3*  3.5 PERSONS = 210 GAL./DAY)
VD
FUNCTION
AND
FIXTURES
TOILETS (5 GAL.)
BATHING (1/4 Bath
tub - 3/4 shower)
LAUNDRY
CULINARY,
MISC.
TOTAL
PERCENT WATER SAVINGS
ASSUME
% TOTAL
USE
40%
30%
20%
10%


DEVICE
DIS-
PLACE-
MENT DAM
(1 GAL.)
FINE SPRAY
SHOWER HEADS
NONE ASSUMED
NONE ASSUMED


ASSUME
SAVINGS
20%
50% of
SHOWER
0%
0%


USE
WITHOUT
DEVICE
84 gal.
63 gal.
42.0
gal.
21.0
gal.
210 gal

USE
WITH
DEVICE
67.2
gal.
39.4
gal.
42.0
gal.
21.0
gal.
169.6
"• gal.
19%
COST
OF
DEVICE
2 
-------
         TABLE 9 - POTENTIAL COSTS/SAVINGS FOR INSTALLING WATER SAVING DEVICES IN NEW HOMES  (SUBURBAN)
                                      (60 GPCD x 3.5 PERSONS - 210 GAL/DAY)
FUNCTIONS
AND
FIXTURES
TOILETS
(5 GAL.)
BATHING
(1/4 BATHTUB—
3/4 SHOWER)
AUTOMATIC
CLOTHES
WASHER
KITCHEN AND
LAVATORY
FAUCETS
AUTOMATIC
DISH WASHER
TOTALS
ASSUMES %
TOTAL
USE
40%
30%
35
GAL/ LOAD
17%
7%
12
GAL/LOAD
6%

DEVICE
3.5
GAL.
FLUSH
TANK
FINE
SPRAY
SHOWER
HEADS
18
GAL/LOAD
WASHER
SPRAY ON
LAVATORY
FAUCETS
7.5
GAL/ LOAD

ASSUMES
SAVINGS
30%
50% OF
SHOWER
USE
50%
20%
38%

USE WITHOUT
DEVICES
(GAL)
84,0
63.0
35.7
14.7
12.6
210
USE WITH
DEVICES
(GAL)
58.8
39.4
18.0
11.8
7.8
135.8
INCREASED
COST OF
DEVICE
0
0
0
$10.00
0
$10.00
ANNUAL
COST OF
DEVICE*
0
0
0
$1.82
0
$1.82
IN-HOUSE
ENERGY
SAVINGS
NO
YES
YES
YES
YES

*Assumed 7 year life and 6 3/8% interest   % Savings  35%

Analysis:  1.  Annual savings per household = $2.00/1000 gal. x 74.2 gal, x 365 days - $1.82 - $52.35
                                                                  day         year
           2.  Annual savings per 100,000 persons (28,570 households) = $1,496,000 + energy savings

-------
8.  Energy Conservation

     The Draft EIS addressed the wastewater treatment facility energy
requirements, and the future energy demands of the Denver metropolitan
area.  The majority of the comments received during public review of
the draft EIS pertained to the energy demands associated with waste-
water treatment, and the energy tradeoffs of various treatment processes.
The issue remains as to what action, if any, EPA should take to promote
energy conservation.

     The U.S. Congress is now developing energy legislation which will
address at the federal level the energy demands and supply issues discus-
sed as indirect consequences of wastewater  treatment facility support of
forecasted Denver region growth.  This fact plus policies developed else-
where in this EIS which favorably affect energy demand indicate that EPA
should not take further action at this time to mitigate indirect growth-
related energy impacts.  However, there remain feasible options for EPA
to consider for mitigating direct energy impacts of wastewater treatment
facilities.

     This EIS indicates that the No-action  alternative represents the low-
est demand for electricity and natural gas.  However, as discussed else-
where in this EIS,  (See Section IV-1) this  alternative strategy has
been deemed unacceptable.  Of the remaining two strategies,  the
Local strategy , as discussed in Section III-3, results in a higher demand
for electricity and natural gas.  The most  significant impact is the fore-
casted shortfall in natural gas supplies which may  adversely affect
the operation of wastewater treatment facilities.   Most facility plans
to date include assessments of the  energy implications of various al-
ternatives as part  of the overall evaluation.  However, these assess-
ments have usually  been limited in  scope to a comparison of  the local
energy consumption  for each alternative.  A complete analysis would
require the inclusion of other factors such as energy consumed in the
management of sludges and manufacture and transport of chemicals used
in the treatment process.  For land application/agricultural reuse
alternatives, energy credits would  be given for any savings  in the
manufacture, transport and application of fertilizers.  Other energy-
saving design factors such as use of solar  energy,  waste heat recovery
and other energy conservation concepts would  also  be included as a
consideration in facility siting and design.

     For a discussion on EPA1s proposed action regarding energy
conservation see Section IV-8.

-------
9.   Protection of Environmentally Sensitive and  Resource Areas


     Environmentally sensitive areas are generally of two types,  land
areas representing resources and those posing a hazard.  Resource areas
include deposits of sand, gravel, coal and other  mineral resources;
prime agricultural soils; areas of significant wildlife habitat,  rare
and endangered species of flora and fauna; areas  and sites of cultural
resources; and recreation, parkland and open space.  Hazard areas in-
clude areas posing hazards such as wildfire, flooding, subsidence,
expansive soils, slope failure or landslides, seismic activity,  high
wind, radioactivity, noise and explosions.  The importance of protecting
valuable resources and avoiding hazards is not at issue.  The issue is
rather what should EPA's role be in mitigating impacts in these areas
which are a partial consequence of funding wastewater treatment facili-
ties.

     These land areas have been studied and identified to various de-
grees in a number of efforts in addition  to this EIS.   (See Growth
Induced Impacts in the Region's Environmentally Sensitive Areas, Volume
2.)  Most notable is the Denver Regional  Council of Governments' Draft
Regional Growth and Development Plan for  the Denver Region. (July, 1977).

     This Draft Plan identified and mapped 16 different  types of environ-
mentally sensitive or significant areas,  as they are referred to in the
Plan.  These 16 special  land forms or resource area classifications are:
1) Floodplains;  2) Wildfire hazard areas;  3) Landslide hazard areas;
4) Subsidence hazard areas;  5) Shrink-swell soil hazard;  6) Faults;
7) Wildlife habitat areas;  8) Sand, gravel, and quarry  aggregate re-
sources;  9) Coal resources;   10) Oil and natural gas  resources;  11)
Aquifier recharge areas;  12)  Prime agricultural land;   13) Park, recre-
ation and open space;  14) Historical places;  15) Archaeological sites;
16)  Special situations  (such as radiation hazard area).   In addition,
the  Draft Plan enumerated 19 Regional Development Policies which would
prohibit, restrict, or otherwise manage development  in these identified
areas to reduce significant adverse impacts  to the environment and  to
development.  All of the Plan  Policies and  draft Regional Development
Policies, including those which address environmentally significant  areas,
are  listed  in Appendix B.

     Comments  received during  public  review of the draft EIS pertained
 to the  definition used in classifying prime agricultural land and poli-
 cies EPA may employ to preserve  it  and the  necessity for recreation,
 parkland and open space. EPA also  received comments regarding  the  pro-
 cedures needed to provide adequate  protection of cultural resources.
                                  42

-------
     The definition for areas of prime agricultural soils used in the
EIS was all land meeting the U.S. Soil Conservation Service criteria
for prime agricultural land except availability of moisture.  The
intent was to identify potential as well as existing agricultural re-
sources.  Land is an in-place resource whereas the water required to
fully use the land resource for agriculture is transportable.  The
EPA recognizes that a higher priority should be given to the protec-
tion of areas where prime agricultural soils are under irrigation and
thus highly productive, than to land that  is not now nor never may be
exploited at its highest agricultural potential.

     Disagreements over future requirements for recreation, park-
land and open space for the Denver region  are  largely resolved if it
is recognized that projected deficiencies  within the urbanized areas
are the main problem.  This aspect was reinforced  in the Denver Metro-
politan Region Environmental Assessment  (October 1977) and  by comments
on this EIS from the City and County of Denver Parks and Recreation
Deaprtment. (See comments and responses, Volume 2).  EPA believes
that most of the existing and potential recreational resources in the
urban area are and will be centered on the region's  streams and  lakes.
The Bureau of Land Management's Foothills  EIS  reinforces this belief.
Therefore/ instream water quality, land availability and public  access
will largely determine the potential use and  development of these bodies
of water for recreational purposes  (See Enhancement  of Recreational
Opportunities, Section 111-10).

     EPA is required under the National  Environmental Policy Act, the
National Preservation Act of  1966, Executive  Order 11593,  and  the
Historic Preservation Act of  1974  to  evaluate the  impact of the  pro-
posed projects on archaeological and  historical  resources.   Through
coordination with the State Historic  Preservation  Officer  and  the
President's Advisory Council  on Historic Preservation,  EPA must  min-
imize harm to cultural resources  through consideration  of  all  prudent
and  feasible alternatives.  Such historic  and cultural  properties
include those that  have been  identified  and  included in the National
Register of Historic Places as well  as  those  unidentified  properties
which may be eligible  for  inclusion.

      EPA's projects are  generally  located in areas surrounding streams
of the  region and,  therefore, may  impact known cultural sites  from
early  settlement days  as well as unknown sites from prehistoric or more
recent  times.  Recent  experience with projects involving the construc-
tion of sewer  interceptor  lines indicates  that excavation in floodplain
areas may  uncover previously  unknown sites which must be evaluated  for
significance under the National Register criteria.  Therefore, not  only
must the impact  on listed sites be considered but also the direct ef-
fects  on potential sites not  yet evaluated and which may be buried.

      For a discussion on EPA's proposed action regarding the protection
of environmentally sensitive and resource areas see Section IV-9.
                                   43

-------
10.  Enhancement of Recreational Opportunities

     The location and design of major interceptors, pump stations,
treatment plants and other wastewater collection and treatment facil-
ities is most frequently determined by demands for efficiency and low
cost.  One factor infrequently or minimally considered is compatibility
with and enhancement of the recreational opportunities of proposed sites
and locations.  Wastewater treatment and collection facilities are
often located in low lying areas along streams, where a high degree of
recreational potential exists.  Therefore, above-ground structures
and access and maintenance roads should be located so that public ac-
cess to existing, planned, or potential recreational areas is not re-
stricted and should be visually compatible.  Preservation of existing
vegetation, landscaping, architectural treatments and facility layout
are all techniques which can be effectively employed to minimize in-
trusiveness upon recreational experiences.  Easements, or rights-of-way
for interceptors can at times also serve as walkways and bikeways con-
necting centers of recreational and urban activity.  The need for re-
creational facilities within the Denver urban and suburban setting has
been established.  However, the mechanism for assuring that wastewater
facility planning and design is compatible with  the efforts of local
and regional agencies to meet that need has not  been established.

     For a discussion of  EPA's proposed action regarding enhancement
of recreational opportunities, see Section  IV-10.
                                   44

-------
11.  Growth and Development in Northern Douglas County


     In comments made on the draft EIS, it was noted that the EIS did
not address the impacts of growth and development in the Northern por-
tion of Douglas County. The Cherry Creek and Littleton/Englewood
service areas include portions of Douglas County.  Presently, only the
Littleton/ Englewood treatment facilities provide service to small
areas in Douglas County.

     The exclusion of Douglas County  in the draft EIS is in part due to
the lack of adequate information on the expected development of the
Northern area of the County nearest Denver.  This is not to say that
information does not exist on the population growth and land use for
Northern Douglas County, but it  is not complete and may be inaccurate,
especially with the recent proposal for developing the Highland Ranch.
This informational problem makes it nearly  impossible to accurately
evaluate the future impact of growth  and  development  in Northern
Douglas County in a regional context.  For  example,  it is not known
what the impact of extensive development  of  this  area will be on the
region's a/r quality. Development  in  this area may be such that it  is
dependent upon jobs in  Denver and  therefore will  require  long commuter
distances, or  it may be self-supporting,  significantly reducing commuter
distances.  The air quality  impact of either type of  development has not
been evaluated.

     Since Douglas County  is not a member of the  Denver Regional
Council of Governments, the  Northern portion of the  County has  not  been
included  in  the  Clean Water  Plan nor in other regional  studies  such as
the Regional Growth and Development Plan.  Douglas  County is outside
the area  for which air  quality modeling is performed for the Denver
region and  therefore  the evaluation of future air quality,  as contained
in this EIS,  does  not  apply  for Douglas County.   Regional services,
such as bus  service  provided by the Regional Transportation District,
are presently  available to Douglas County on a limited basis.

      This EIS  has continued the policy of exclusion of Douglas County from
active consideration in planning for growth and development in this Region.
 For whatever reasons,  this situation does not appear acceptable,  given the
 probable  growth of the area and the environmental effects which may result
 in the Region.  However, this EIS is not the mechanism to plan for and
 evaluate  the impacts of growth  in Douglas County.  As stated earlier,
 the regional planning for water quality, air quality, land use, popula-
 tion growth and other services  does not presently consider Douglas County.
 This  EIS  cannot change this situation, but it should bring it to the readers
 attention.

      For a discussion  of EPA's  proposed action regarding Douglas County,
 see Section IV-11.

-------
12.   Other Significant Water Quality Problems and Study Needs

          Recent developments have heightened EPA's concern with
     ground-water quality of the aquifers underlying the Denver area.
     Since the passage of the Safe Drinking Water Act in December,
     1974 EPA has been increasingly concerned about the water quality
     of domestic potable supplies, including ground water.  In the
     Denver area the communities of Brighton, Northglenn, and Thornton
     depend entirely, or partly, on the shallow aquifer along the
     South Platte River for their potable water.  Although the Clean
     Water Plan identifies several chemical parameters which exceed
     the recommended limits for some uses along the South Platte Valley
     aquifer,  the Plan does not identify any sources of these pollutants
     or discuss, in detail, other groundwater problems.

          Three factors contributed to EPA's decision to include ground
     water as an issue in this EIS.  They are:

          1.   The publicity given to high nitrite levels in
              Thornton's and Northglenn's water supply.

          2.   Development pressure, such as Phipp's Ranch, to
              increase usage of the area's ground water for do-
              mestic purposes.

          3.   The potential for ground-water contamination resulting
              from solid waste disposal sites and septic tank sys-
              tems.

          Other agencies have recognized the importance of this prob-
     lem.  In particular, the U. S. Geological Survey has proposed a
     $700,000 study of the Denver Ground-water Basin.  The purpose of
     the study would be to collect sufficient quantity and quality
     data about the Denver Basin which would serve as the basis for
     developing a computer model of this basin.  This model would
     allow the State and local governments to evaluate the impact of
     different growth patterns and water development schemes.  In
     addition, the State Department of Health is conducting a detailed
     investigation of the water supply problems being experienced in
     the South Platte aquifer.

          Another issue which has not received much attention but
     which EPA believes should be indentified in this EIS is the
     recreational status of Barr Lake versus the discharge of MDSDD#l's
     effluent  to the Burlington-01Brian Canal/Barr Lake System.  The
     Clean Water Plan identified a range of costs for discharge to
     Burlington Ditch ($45.7 million to $140.3 million) depending on
     the level of treatment that would be needed to protect the
     recreational status of Barr Lake.  However, the State has not
     identified a level of protection needed for this lake and con-
                                  46

-------
sequently, the Clean Water Plan does not make any specific recom-
mendations for controlling the discharge of effluent to the Barr
Lake system.

     EPA, under the National Lake Eutrophication Program, evaluated
the trophic level of Barr Lake.  In the report, "Barr Lake, Adams
County, Colorado, Region VIII, Working Paper No. 766," (published
in July, 1977) the EPA concluded that Barr Lake was the 12th
worst out of 13 Colorado lakes investigated by EPA.  This ranking
was based on the overall quality of the lake in comparison to
others using a combination of six parameters.  The report also
concluded that Barr Lake is nitrogen limited in regard to its
eutrophic condition.

     For a discussion of EPA's proposed action on these issues,
see Section IV-12.
                             47

-------
IV. PROPOSED EPA ACTIONS
   AND MITIGATIONS

-------
                          SECTION IV
             EPA PROPOSED ACTIONS AND MITIGATIONS

1.  Air Quality

     EPA believes that the funding of wastewater treatment and col-
lection facilities which involve the addition of capacity to serve
future population growth should be done in a manner which encourages
the implementation of measures to reduce the existing air pollution
problem.  Population growth is going to occur in the Denver metro-
politan area and unless strategies to reduce air pollution, princi-
pally from automobiles, are implemented, air quality will not sig-
nificantly improve and may get even worse.  Funding of additional
wastewater facilities does not cause air pollution, but it does sup-
port growth, both economically and locationally, by providing readily
available services for sewage treatment and reducing development costs.
Therefore, EPA believes that funds should be made available only where
reasonable actions are being taken to deal with the air quality impacts
of growth.  However, until 1979, actions to reduce air pollution may
be limited due to the absence of the then required air quality Imple-
mentation Plan.

     Accordingly, EPA proposes to take  the following action.

     EPA will continue to participate in funding wastewater treat-
     ment and collection projects which involve additional capacity
     where:

     1.  Each general purpose government  included  in the  service
         area for which a grant  is requested,  enters into a written
         agreement with EPA and  the  State of Colorado  to  participate
         in developing and implementing local  air  pollution control
         measures as an enforceable  portion of  the State  Implementa-
         tion Plan  (SIP).

     2.  Growth  projections are  consistent with the DRCOG popula-
         tion allocations for urban  service areas  or as revised
         during  the  State Implementation  Plan  process.

     3.  Additional  capacity  is  limited to  serve the population pro-
         jection for 10 years  for  treatment works  and  20  years for
         interceptor sewers.

     4.  Development which will  be served by  the additional capacity
         is within  the adopted  regional urban  service  area boundaries
         and  contiguous  to  existing  development as stated in  DRCOG's
         Regional Plan Policy #5 (See Appendix B).

     5.   For  a  general purpose government grantee a condition to  the
          grant would limit  the number of taps  permitted each  year to
          accommodate a uniform annual growth rate which is consistent
                                  49

-------
         with DRCOG population allocations for the service area.
         Taps not used in any year may be carried over to the next
         year.

     6.  For a special purpose district grantee a condition to the
         grant that  it  enter into legally enforceable agreements
         with each general purpose government in the service area to
         limit the number of taps permitted each year to accommodate a
         uniform annual growth rate which is consistent with DRCOG
         population allocations for the service area.  Taps not used
         in any year may be carried over to the next year.

     The grant conditions relating to tap limitations in 5 and 6 above
may be waived by EPA after two years from the date of the grant,
if it is demonstrated to EPA's satisfaction that the general purpose
governments in the service area are making good faith progress towards
implementing the SIP in accordance with item 1 above.

     In proposing this action, EPA considered the need to continue to
improve and expand wastewater treatment facilities in order to im-
prove the water quality of the streams in this Region.  Also, this
action is considered necessary in order to limit the potential urban
sprawl effects of EPA's wastewater facilities construction grants
program.  Urban sprawl often results in increased vehicle miles
traveled (VMT), leading to increased emissions of auto-related air
pollutants.  Sprawl is also associated with accelerated physical decline
and disinvestment in the core city, increased municipal service costs,
loss of prime agricultural land and increased energy consumption.

     EPA did consider the option of not providing grants for addi-
tional wastewater treatment and collection capacities until the State
Air Quality Implementation Plan is revised (January-July 1979) and
being implemented.  EPA rejected this option at this time because we
think it would unreasonably delay the attainment of regional water qual-
ity goals.   This option must be considered by EPA under requirements of
the Clean Air Act if the State Air Quality Implementation Plan is not
adequately developed and being implemented by July, 1979.
                                 50

-------
2.  Water Quality (Stream Classifications)

         EPA's action on the Clean Water Plan is confined to approval,
    disapproval, or conditional approval as defined earlier in this
    report.  The State has conditionally certified the Plan's recom-
    mendations for stream classifications and related recommendations
    for discharge limitations.  EPA's proposed actions on the Clean
    Water Plan for stream classifications and corresponding discharge
    requirements are presented below.  Rationale for these actions is
    presented in the discussion that follows these three action items.

         1.  EPA shall conditionally approve the Clean Water Plan by
             accepting the general  conditions numbered 1 through 6
             in the Governor's January 10,  1978 certification letter
              (see Appendix A).

         2.  EPA shall approve reissued  permits which are based on  the
             existing stream classifications  and which are  in accord
             with  the existing effluent  limitations  presented in
             Table  4 of  this report for  municipal  dischargers.  For
              those  municipal dischargers not  in compliance  with the
              existing discharge  requirements  listed  in Table 4, com-
             pliance dates  shall be based on  the availability of  con-
              struction  grant funds.

          3.   EPA,  shall  notify the State that sufficient documentation
              has  not been presented in the Clean Water  Plan for EPA
              to accept  any of the Plan's recommended stream segment
              downgradings.   This notification will inform the State
              that EPA intends to testify to this fact at a public
              hearing which considers the Clean Water Plan's recom-
              mended downgradings, unless documentation is presented
              beforehand which meets EPA's criteria.  DRCOG's compliance
              with Condition #1 of the January 10, 1978 certification
              letter may satisfy EPA's requirements for downgradings.

          The documentation presented in the Clean Water Plan con-
     flicts with the recommended stream classifications for those
     segments where the fishery designation is to be deleted.  The
     Clean Water Plan presently does not demonstrate that background
     conditions, irretrievable man  induced  conditions, or widespread
     adverse economic/social impact will prevent attainment of a
     water quality suitable  for protecting  and maintaining aquatic
     life.  DRCOG is preparing an addendum  to the Plan which may
     provide adequate justification for  the proposed downgradings.
     EPA will review that addendum  to determine whether or not it
     provides adequate justification for  the downgradings.
                                    51

-------
     Costs have been identified in the Clean Water Plan for achiev-
ing the 1983 objectives of the Clean Water Act (see Table 3).   These
costs serve as the principle basis for the recommended downgradings.
Examination of those costs reveal that approximately 14.76. of  the
total present worth costs is for point source control.  Discus-
sions with the DRCOG staff indicate that the aquatic life objec-
tives can be met through point source control alone.  If this  is
true, then the per capita cost to achieve this objective equals
approximately $20 per year for a period of 20 years.  This figure
represents the additional costs to achieve the aquatic life objec-
tive given the existing controls for municipal point sources.   EPA
considers this figure to be within the means of the metropolitan
community.  The Clean Water Plan has not provided evidence that
this money could be better spent elsewhere or that the expendi-
ture of these monies would result in a "widespread adverse economic
and social impact."

     EPA views the State's role in setting water quality standards
and a corresponding classification system as one of its primary
functions.  Despite the fact that the existing standards and
classification system are being revised, EPA believes that it is
reasonable to implement the existing State/EPA requirements for
permits and construction grants.
                              52

-------
c.
3.  Wastewater Facilities Organization (Siting) and Treatment Processes

         The following criteria were used to evaluate facilities siting-
    issues:

         a.  Does the proposed facility(ies) provide in-stream flow
             and quality benefits to meet the enforceable portions
             of the Clean Water Act  (i.e., NPDES and pretreatment
             requirements)?

         b.  Does the proposed facility(ies) have  State 208 Plan and
             local endorsement?

             Does the proposed facility(ies) further the  land  treat-
             ment/reuse  goals of  the law in accord with EPA's  Octo-
             ber  3,  1977 Policy on  Land  Treatment  of Municipal Waste-
             water  (see Appendix  C).

              Is  the  proposed facility(ies)  cost effective,  or  has  the
              facility plan  identified the cost effective  solution  which
              could  serve as the basis for establishing EPA's partici-
              pation in  the  project, if other  compelling reasons  exist
              to  implement  an alternative which is not  the cost effec-
              tive proposal?

              Does the  proposed facility(ies)  conform with other EPA,
              State, and local requirements relating to water rights,
              recreation, water supply,  and the environment?

          Approval of the Clean Water Plan's recommendations for waste-
     water treatment facilities would mean that EPA could not fund any
     projects that are inconsistent with the approved Plan.  The recom-
     mendations contained in the Clean Water Plan  for treatment facilities
     are not the same as recommended in  the Clear  Creek and Northglenn
     Facility Plans.  Recognizing these  two discrepancies and given the
     five criteria listed above, EPA proposes the  following actions on
     the issues surrounding  facility siting:

          1   EPA shall approve the  Clean Water Plan as it relates to
              siting for all the  communities listed in Table 5 under
              the column headed,  "Clean  Water Plan," except  for Clear
              Creek  (Golden, Wheat  Ridge, etc.) and Northglenn.  EPA
              actions on these two  issues are:
e.
                          53

-------
    a.   Clear Creek - EPA prefers  a sub-regional facility  be  con-
        structed in the Clear  Creek Basin below Golden and
        Coors which would serve to maintain in-stream water
        quality and flows.   Therefore,  EPA will not act on
        the Clear Creek facility plan or the Clean Water
        Plan (as it relates  to locating a sub-regional facility
        in the Clear Creek Basin downstream from Golden) until
        this conflict is resolved.  EPA will reserve judgment
        on whether the remainder of the basin should receive
        treatment at the Metro facility until such time as
        the State decides on the Clean  Water Plan's proposed
        classification for Clear Creek  and further analysis
        is made to determine the feasibility of discharging
        effluent from these  facilities  to Clear Creek or to
        downstream irrigation  ditches on a full or part time
        basis.

    b.   Northglenn - EPA endorses  the water resources concept
        being proposed by Northglenn as a rational approach
        to managing the scarce water resource in the arid
        West.  Based on this factor and Northglenn's need for
        an upgraded water supply,  EPA is willing to fund
        Northgelnn's proposal.  It is EPA's understanding
        that the Clean Water Plan  and the Lower South Platte
        facility plan will be  revised to be made consistent
        with the Northglenn  Plan.   While DRCOG and the State
        have designated Northglenn as a management agency
        and approved their plan concept, analysis and recom-
        mendations contained in the Clean Water Plan does
        not reflect this action.  Thus  an amendment to the
        Clean Water Plan will  be required.

2.  The above approval and conditions are contingent upon
    other issues relating to water rights, recreation, water
   " supply, and the environment being satisfactorily resolved
    for each of the projects under construction.

Regarding the issue of treatment processes, EPA proposes the
following actions:

1.  EPA shall approve only those projects which use treat-
    ment processes that result in  meeting NPDES permit
    requirements and other enforceable portions of the Clean
    Water Act.

2.  EPA shall give strong preference to land treatment/reuse
    systems and shall require  applicants to provide complete
    justification for the rejection of land treatment alter-
    natives.
                         54

-------
     EPA is  concerned  that  a site which  is  selected  for
a new wastewater  treatment  be environmentally,  socially
legally,  and economically acceptable.  Sites for facili-
 :ies considered in  this  EIS have not been evaluated  in
 my detail.  Some site locations have not yet been selected
by the grantee.  This  EIS provides  the framework for evalu-
ating sites  during  the detailed review of each  facility
 >lan.  If it is determined  that a facility may  be located
  > as to cause a significant  adverse impact, considering
environmentally sensitive areas, historical and archaeolo-
gical sites, stream flow, surrounding land uses and energy
requirements, then  an  individual EIS on  that project would
be required.


-------
4.  Management and Institutional Arrangements

         EPA's action on wastewater management agencies is confined
    to approval, disapproval, or conditional approval of the agencies
    designated by the Governor in the certification of the Clean
    Water Plan to EPA.  On September 6, 1977 EPA issued, in the form
    of regulations, criteria for evaluating the acceptability of man-
    agement agency designations.  These regulations set forth guidance
    "to ensure (1) that management agencies designated to implement
    the plan possess adequate authority and capability to carry out
    applicable portions of the plans, (2) that plans identify certain
    responsibilities assigned to designated management agencies, and
    (3) that plans include indications of the management agencies
    willingness to carry out such responsibilities."

         Based on the guidance cited, EPA's review of the Clean Water
    Plan, and EPA's review of the Governor's certification, EPA pro-
    poses the following actions relative to the Clean Water Plan and
    the facility plans covered by this EIS:

         1.  EPA shall accept the management agencies certified
             by the State.  EPA shall accept all the conditions,
             (including general condition #8 as it relates to
             nonpoint management agencies) placed on that certi-
             fication by the State (see Appendix A).

         2.  EPA shall not award any wastewater construction grants
             to those geographical areas covered by the Clean Water
             Plan for which a designated management agency was not
             certified by the State and approved by EPA under Item 1
             above.  Under this condition, all those agencies that
             were recommended for designation by DRCOG, but were not
             designated by the State, would not be eligible to receive
             EPA construction grants for wastewater facilities.

         3.  EPA shall not award any wastewater construction grants to
             the St. Vrain-Left Hand Conservancy district until such
             time that the contractual arrangements referred to in the
             State's certification letter are executed.  This means
             that grants will not become available to Longmont, Lyons,
             Niwot Sanitation District and any other community or dis-
             trict included within the jurisdiction of the St. Vrain-
             Left Hand Conservancy District as defined by the Clean
             Water Plan.
                                56

-------
     EPA realizes that these actions do not satisfy the special
districts desire to receive wastewater construction grants.  EPA
also realizes that these proposed actions do not support the
Clean Water Plan's recommendation to organize eight water quality
associations, each one of which would serve as the management
agency for its area of jurisdiction within five years of EPA
taking formal action on the Clean Water Plan.  Nationally, EPA
does not have any policies or guidance which would favor the
designation of general purpose governments as opposed to special
purpose districts.  However, EPA believes that there are advan-
tages to the objectives being promoted by both the State and the
Clean Water Plan.

     The following is EPA's assessment of what these objectives
are:  (1) The State is attempting to  link directly together the
decision making  for a broad range of  activities into a  single
organization that has responsibility  for those activities, and
(2)  the Clean Water Plan  is attempting to link closer together
geographical areas that have  common water quality problems and
needs, while indirectly trying  to improve the coordination
between districts and general purpose governments regarding
water quality matters as  they affect  land use decisions.   From
EPA's perspective there is a  need  to  accomplish both objectives
(that is,  consolidation of responsibility  for environmental pro-
grams geographically as well  as functionally) in  the Denver
metropolitan area.  This  need stems from the fact that  EPA
administers  numerous environmental  programs, many of which have  a
legislative  mandate to  assure that  actions  taken  under  one program
are consistent  with other programs.  The question of  consistency
among EPA programs  is best illustrated by the relationship of  air
quality  to the  construction of  wastewater treatment facilities
which  is discussed  elsewhere in this report.

     EPA agrees with  the effort of the State to promote manage-
ment agencies  that  have a broad range of authorities in addition
 to their responsibility for wastewater collection, treatment,  and
 disposal.  Therefore,  EPA advocates the following actions regard-
 ing management and institutional arrangements for the Denver
metropolitan area:

      1.   EPA encourages the formation of a metropolitan council
          or similar form of government which consolidates re-
          sponsibility for planning and implementation of EPA
          related environmental programs at the regional level.

      2.  In the absence of a Metropolitan Council or similar form
          of government, EPA supports the designation of general
          purpose governments as wastewater management agencies in
          order  to promote more comprehensive responsibility for
          environmental management, including wastewater treatment.
                              57

-------
               EPA does not believe that the above positions  are  opposed to
           the recommendations found in the Clean Water Plan.   Rather, EPA
           believes that the Plan's long-range objective of  establishing a
           metropolitan form of governance should be promoted  in a manner
           consistent with the State's objectives for management agencies.
WA67&
                                                    Today's Complex System of Shared
                                                    Water Resources
                                      58

-------
5.   Control of Nonpoint Source Pollution

     The Denver Regional Council of Governments recommended in the
Clean Water Plan that urban runoff pollution be controlled by non-
structural controls listed in Section III-5.  The use of structural
pollution controls to collect and treat urban runoff was believed to
be too expensive to justify at this time.  The Clean Water Plan recom-
mended further study of nonpoint pollution to identify site specific
problems and control measures prior to considering structural controls.

     The following actions are proposed by EPA relating to the approval
of the Clean Water Plan and the facility plans covered by this Environ-
mental Impact Statement.

1.   EPA shall accept the State's  general condition #8 which requests
     that DRCOG better  define the  nonpoint  source control program for
     urban  runoff, construction, irrigated  and dry-land agriculture,
     and septic tank systems, as part  of  the first plan update.  EPA
     shall  further condition approval  of  the Clean Water Plan  requiring
     that within  two years DRCOG address  all nonpoint  source categories
     including  irrigated  agriculture,  non-irrigated agriculture,  live-
     stock  grazing,  feedlots, mining (coal  and non-coal),  silviculture,
     home disposal,  urban runoff,  solid wastes,  residuals,  hazardous
     materials, groundwater,  construction,  and hydrologic  modification.
     In  addressing nonpoint  sources DRCOG must  state,  based on best
     available existing information, whether or  not  each category causes
     a water quality problem.   For each nonpoint source problem category
     DRCOG must state the type of controls  necessary to solve the prob-
      lem.

 2    EPA shall approve the regionwide assessment of nonpoint sources.
      This assessment was based on assuming loading factors for various
      urban and non-urban land use types (e.g., single family residential,
      dry land agriculture, etc.) and placing this information into a
      computer model for analysis.  This analyses indicated that nonpoint
      sources are a regionwide problem.  This assessment is adequate to
      promote the implementation of the type of control measures being
      recommended in the Clean Water Plan.

      In order to promote the implementation of nonpoint source controls
  for urban  runoff EPA proposes the  following action.

      Prior to granting funds for  construction or expansion of wastewater
       facilities, the general purpose  governments within the proposed ser-
      vice  area must show progress,  in the  form  of ordinances  adopted or
       recent  efforts taken, towards implementing the nonpoint  source  con-
       trols recommended by the Clean Water  Plan.
                                     59

-------
 6.   Maintenance of Stream Flows

     The potential Impact  on stream flows  from a change in the point
 of  wastewater  discharge needs  to  be more  thoroughly evaluated on both
 a regional and project  basis.  Such an evaluation on a regional basis
 should consider,  for some future  year,  the impact of all water and
 wastewater programs and projects  on the attainability of water quality
 classifications for instrearn uses (fishing,  swimming, boating, etc.).

      The Clean Water Program has  identified  stream reaches with prob-
 lems where the attainment of a fishery  may be restricted by  low flow
 conditions.  Given the  increasing level of interest in the Denver Region
 on  wastewater  reuse and exchange  projects  as a means of supplementing
 existing water supplies,  future water and  wastewater projects  may
 further  affect stream flows.  These  effects  can have a beneficial or
 adverse  effect on existing stream flows and  thereby greatly  influence
 the future attainability  of  water quality  classifications for  fishing
 and recreation.

      EPA action on the  issue of stream  flow  depletion which  may result
 from wastewater projects will be:

 1.   To expect  as  part of  the continuing 208  program,  a regional  eval-
     uation of  this  flow depletion issue which  considers  the  commula-
     tive effects  of  all wastewater treatment projects  also consider-
     ing  changes in water supply requirements and methods  of  supply.

 2.   To require  as  part of  each wastewater facilities  plan an evalua-
     tion of the likely impacts of the project on seasonal stream flows
     and  thus on potential and designated stream uses.

3.  For each proposed facility, which will alter stream flows, the
    grantee will be required to consult with the Colorado Department
    of Natural Resources,   (Parks and Outdoor Recreation Division and
    Wildlife Division) to determine the significance of this proposed
    change on existing or potential recreation and wildlife resources.

4.  Where a proposed project may involve a water rights dispute, EPA
    will require reasonable assurances by the grantee that the dis-
    pute can be settled so as not  to jepardize the usefulness of the
    project, including documented  consultation with the State Engineer,
    prior to providing any funds for project construction.
                                 60

-------
7.  Water Conservation

    The Denver Metropolitan area is . located in the semi-arid West where
water is naturally scarce.  In order to protect  existing water uses
as well as to provide for future development, the water resources
available to this area must be carefully used, conserved and reused,
wherever possible.  The peak  demand for water in the Denver region
occurs during the summer lawn and  farm irrigation season.  Water con-
servation and reuse of wastewater  can reduce this peak demand and may
result in a reduction in the  need  for additional water supply facil-
ities.  Also, year-round conservation of water used  in the home can
benefit the total water supply situation and reduce  needs for addit-
ional wastewater treatment  capacity.  This  later savings is what EPA
proposes to strongly encourage by  the following  proposed action.

     EPA will require prior to making a  grant  for design of  the waste-
water facility  that  the applicant  demonstrate  that:

     1.  Metering, pricing  and other  regulatory  and  incentive
         measures  (such as  changes in plumbing code, or  a
        , program to  retrofit plumbing fixtures)  have or
        ' are being  taken  to reduce wastewater  flows  within
         the  service area,  and

     2.  The  design  capacity or  other features of the facility
         reflect the reduction in wastewater flows.

         Wherever the  dry weather wastewater base flow (excluding
          industrial  flows)  to be used for planning a treatment works
          exceeds 70 gallons/capita/day,  EPA proposes that the appli-
          cant plan and implement a water conservation program and
          use the reduced flows as the measure of design capacity
          for new treatment facilities.   As a guide, a 15 percent
          reduction in wastewater flow may be expected from the
          Implementation of an in-house water conservation program.
                                   61

-------
8.  Energy Conservation

    The EPA has the option of taking no action and assuming  that  the
realities of energy pricing and availability will exert sufficient
pressures so that energy conservation and recovery becomes a higher
priority.  Other policies regarding water conservation, reuse and
land application, and effluent quality and treatment levels  may also
tend to reduce treatment facility energy demands.  However,  available
technology and innovative techniques to use solar heat, and  energy
conservation and waste heat recovery in wastewater treatment facili-
ties provide the potential for more immediate payoffs.  Such technol-
ogy has also been shown to improve facility reliability, and in many
cases, reduce costs.  It therefore appears reasonable and prudent that
consideration of this technology be incorporated in facility planning
and design.

    The EPA proposes to adopt the following policy regarding energy
conservation.

     As a requirement for receiving a grant for planning or  design of
     any wastewater treatment works, the consideration of solar
     energy and energy conservation technology and techniques must
     be demonstrated by showing that energy requirements, particularly
     for natural gas, have been reduced as much as possible.
                                 62

-------
9.  Protection of Environmentally Sensitive and Resource Areas

    The EPA proposes to protect  environmentally sensitive areas which
may be impacted, directly or  indirectly, by funding wastewater pro-
jects.  Environmentally sensitive areas are defined by the 16 cate-
gories discussed in the Draft Regional Growth  and Development Plan for
the Denver Region  (DRCOG, July 1977).  Protection of  these areas shall
be required by EPA to be in accordance with the 19 Regional Develop-
ment Policies listed in Appendix B  (RDP 23 through RDP 41), with addi-
tional requirements for the protection of  archaeological  and historical
resources.

     The EPA proposed to adopt  the  following  policies:

1.  No treatment facility will  be  eligible for grant  funds  if  sited
    in an environmentally  sensitive area,  unless

    a.  there  is no  feasible  alternative,  and

    b.  hazards  and  impacts  have been mitigated in accordance with
        item  3 below and  EPA's  requirements  for protection of archeo-
        Ifigical  and  historical  resources  stated below.

 2.  No grant  for the portion of treatment capacity to serve develop-
    ment  in an environmentally sensitive area(s)  will be given unless
    hazards and  impacts will be mitigated in accordance with item 3
    below.

 3  Facility siting and development served through EPA construction
     grants  will be in accordance with the draft Regional Policies 23
     through 41 which deal with protection of environmentally sensi-
     tive, resource and hazard areas, as published by the DRCOG, until
     such time as final policies and any subsequent revisions are adopted
     by DRCOG and agreed to by EPA.

 4   EPA will use DRCOG's review of facility plans under  its A-95 and
     208 process, as one mechanism  for determining consistency with
     the above established policies.

     Additional efforts to protect  archaeological and historical re-
 sources which shall be required for  each  project are:

 1   An on-site cultural resource survey  to be performed  by a quali-
     fied professional archaeologist/historian to determine if  the
     proposed project may directly  impact  previously  undiscovered or
     unrecorded  sites with results  presented  in the  facilities  plan.
                                   63

-------
2   A literature search for known, designated or undesignated sites
    to be conducted by the grantee arid reported in the facilities
    plan.

3   Review and comment by the state Historic Preservation Officer
    on the adequacy and results of activities described unde
    2 above.

4.  For projects located in areas of high potential  for finding
    buried cultural resources, as determined by 1, 2 or
    shall require an on-site construction monitor who has authority
    to halt construction should a find of potential  significance
    made.

 5   If a property or site which is  listed or  determined  to  be eligible
    for  listing  in  the National Register of Historic Places,  upon whi<
    the  project  will have an adverse  effect,  EPA  shall consult wi
    State Historic  Preservation Officer  and  the Advisory  Counci
    Historic  Preservation  to determine  a feasible and prudent alterna-
    tive to avoid or  satisfactorily mitigate  the  adverse  effect.

                                   64

-------
10.  Enhancement of Recreational Opportunities

     The Clean Water Act amendments  of  1977  added  language  to the ef-
fect that the EPA shall not make grants  from funds authorized after
September 30, 1978 unless  the  grant  applicant has  satisfactorily de-
monstrated that  the applicant  has  analyzed  the  potential  recreation
and open space opportunities  in the  planning of proposed  treatment
works.

     To insure that 201 facility plans  comply with the Clean Water Act
amendments of 1977, and to ensure  that  facility location  and design is
compatible with  and enhances  the recreational opportunities of  pro-
posed sites  and  locations, EPA proposed the following procedure.

     As part of  the A-95  review process, DRCOG  and the State shall be
     requested to make a  finding that proposed  facilities are  compatible
     with existing, planned and proposed local  and regional recreation
     facilities.  Also the facility plans must  analyze the potential
     for incorporating into the proposed project recreation and open
     space opportunities.   EPA shall review the facility  plans to
     determine if  consideration of recreational aspects are adequate.
                                   ,:•

-------
11.  Funding of Wastewater Collection and Treatment Facilities for
     Northern Douglas County

     EPA has not evaluated the Impacts of growth and development in
the Northern portion of Douglas County.  This area may experience rapid
development over the next 20 years and as a result, may significantly
influence the environment of the Denver Region.  The service areas for
the Cherry Creek and Littleton/Englewood facility plans extend into
Douglas County.  In order to adequately address the effects of funding
any extension of service into Douglas County, beyond what presently
exists, EPA proposes the following action.

     EPA will not provide funds for extension of service into
     Douglas County through actions taken on the proposed Cherry
     Creek and Littleton/Englewood facility plans until:

         1.  Sufficient study and review of the probable effects
             of providing such service has been conducted, pos-
             sibly leading to an environmental impact statement, and

         2.  Adequate population, land use and water quality plan-
             ning for the area to be served is prepared and inte-
             grated into the Denver Regional Council of Govern-
             ments regional plans and the State's Air Quality
             Implementation Plan.
                                 66

-------
12.  Other Significant Problems and Study Needs

         The ground-water issue is divided into the following three
     categories and EPA's recommended action is presented under each:

         a.  High nitrate levels in Thornton's and Brighton's domestic
             water supplies.

                EPA shall require as part of the first 208 Plan update
                a more thorough analysis of the causes and recommended
                solution to this problem including a revised waste
                load allocation for MDSDB#1 if needed.

         b.  Effects on ground water with continued increased use for
             domestic water supply in the Region.

             1.  EPA shall expect the work plan that is developed for
                 future 208 planning to include an activity that
                 addresses ground water.  Within this  activity, pri-
                 ority should be placed on the relationship between
                 continued use of these ground-water supplies to sur-
                 face and ground-water  quality.

             2.  EPA shall not participate in wastewater  projects
                 which are believed  to  involve adverse impacts  to
                 water quality  from  increased  ground-water use.

          c.  Water quality effects,  especially on  ground  water, of
             present and projected solid waste disposal practices and
             septic tanks.

              1.  EPA shall require as  part  of  the  first plan  update  a
                 more  thorough  analysis of  the relationship between
                 solid waste  disposal,  septic tanks,  and  ground-water
                 quality.

             2.  EPA shall  require  DRCOG to coordinate the Clean Water
                 Plan with planning  conducted under the Resources  Con-
                 servation  and  Recovery Act.

          Regarding the  issue of Barr Lake the following action is
     recommended:

               EPA  shall  request from the State a definition of the
          desired water quality for Barr Lake.   EPA shall  also request
          that  the  State,  in cooperation with DRCOG, establish a pri-
          ority for Barr  Lake relative to other planning activities.
                                  67

-------
     These action items fall in the category of continuing plan-
ning and future studies.  EPA believes that it is not reasonable
to require more, given the limited amount of existing information
on the nature and extent of the problems.
                             68

-------
V. PROBABLE CONSEQUENCES
  OF PROPOSED ACTIONS

-------
                          SECTION V

          PROBABLE CONSEQUENCES OF PROPOSED ACTIONS

Unavoidable Adverse Impacts

     1. The region will continue to grow in both population and urban-
        ized area at the expense of about 10,000 acres of prime agri-
        cultural land which is presently farmed within the adopted
        (year 2000) regional urban service areas.

     2. Even with EPA's approval of the designated general purpose
        governments as wastewater management  agencies, the existing
        and complex framework of governmental agencies, will continue
        to hinder coordination needed  for  implementing effective solu-
        tions to regional  environmental problems like air quality,
        water quality, and water supply  (conservation).

     3. Development of the urban fringe  is  expected  to continue with
        migration of the affluent and  advantaged to  the suburbs.
        Additional capacity  for wastewater treatment facilities will
        serve these developing areas.  Although there are some signifi-
        cant signs of neighborhood  revitalization  in the urban core,
        general physical and economic  decline of the urban  core is pro-
        jected.

     U. Until  such time  as population, land use  ana environmental
        planning for Douglas County is integrated  into  regional plans
        leading to the  provision of regional services for  the Northern
        portion of the  county,  services such as  water supply and waste-
        water  disposal  will be supplied locally.   The use  of septic
        tanks  for wastewater disposal and ground water for water  supply
        in Northern Douglas County may adversely impact groundwater
        quality and quantity, depending upon the extent of such prac-
        tices .

      5 Overuse of urban parks and recreational facilities indicated by
       ' a decreasing park acreage per capita ratio will result in dam-
         age to some facilities and a lower valued recreational
         experience.  The apparent difficulty and high cost associated
         with achieving year around the fishable and swimable water
         quality goals will further inhibit recreation in the Denver
         Region.

      6. Particulate air pollution concentrations can be expected to
         increase in future years resulting in continued violation of
         the National Ambient Air Quality  Standards  and more frequent
         occurances of poor visability.  The  major sources for particu-
         lates  will continue to be related to construction activities
         and materials on  the streets  thrown  up by vehicular traffic.
                               69

-------
    7.  Even with the implementation of a vehicle emissions inspec-
        tion and maintenance program, carbon monoxide concentrations
        will exceed ambient standards, in 1985.  Peak ozone concentra-
        tions will continue to violate standards in the same year.  In
        order to further reduce air pollution levels to. within the
        National standards prior to 1985j significant reductions in
        vehicle miles traveled are expected to be required.

    8.  Implementation of the Local Alternative, advanced waste-
        water treatment  (which is needed to meet existing water
        quality classifications) and non-structural controls for
        nonpoint pollution sources will result in an improvement
        in  existing stream quality, but not to a degree sufficient to
        meet the fishable and swimable goals year around.

    9.  The cost of implementing non-structural nonpoint pollution
        controls recommended by the Clean Water Plan will  cost local
        governments, land developers and ultimately the general public
        an  estimated 29  million dollars  annually over the  next 20 years.
        The proposed improvements  in wastewater treatment  levels needed
        to  meet the  existing water  quality  classifications will cost
        26  to 29 million dollars annually, which will be subsidized
        by  federal grants for construction  costs  (75 percent).

    10.  In  the  absence of a regional authority with broad  powers to
        implement programs for water quality management, water supply
        and attainment of air quality  standards, additional  responsi-
        bilities will  fall on local governments and  sanitation dis-
        tricts  to coordinate and/or implement the  proposed actions
        involving air  quality,  nonpoint  pollution  controls and water
        conservation.

Short-Term vs.  Long-Term  Benefits

     In general the actions proposed by EPA are  intended to produce
long-term benefits while  not  jepardizing the more  immediate benefits
resulting  from continuing to  support the improvement  and expansion of
wastewater treatment facilities.   Efforts to obtain the long-term
benefits associated with proposed actions on air quality, wastewater
reuse, nonpoint pollution control,  water conservation, protection of
environmentally sensitive areas, and recreation enhancement may cause
a short, immediate delay in implementing the proposed wastewater treat-
ment improvements.   However,  EPA believes that the integration of all of
these potential benefits is vital to the improvement and maintenance
of the Region's environment.

          EPA will pursue the achievement of immediate water quality
improvements through enforcement of effluent permit requirements and will
expect compliance with the more stringent effluent requirements, based
                              70

-------
on availability of EPA construction grant funds.  Where waste-water
treatment improvements are needed to meet water quality standards,
EPA will expect the applicant to move expeditiously in meeting
the grant requirements.

Commitments of Resources
     Implementation of the proposed wastewater facilities expansion
and improvement will require an irretrievable consumption of construc-
tion materials, fuels, labor and federal grant funds.

     The proposed actions will support planned future growth in the
Region, with its implied commitment of resources.  Specifically, the
proposed actions will have the following resource implications.

     1.  Air Quality-Requires additional commitment by local govern-
         ments to participate and  implement measures needed to improve
         the Region's air quality.  Reduced urban sprawl and depend-
         ance on the automobile reduces energy requirements while some
         air quality controls (e.g. emission control) require addi-
         tional resources.

     2.  
-------
 8.   Energy Conservation - Results  in reduced requirement for
     externally supplied energy in  vastewater treatment.

 9.   Protection of Environmentally  Sensitive and Resource Areas -
     Results in many land based resource "benefits including; pro-
     tection of development from flooding and geologic hazards,
     protection of ground-water quality, protection of significant
     wildlife habitats, and greater utilization of resources
     (e.g. sand and gravel, coal, prime agricultural soil) from
     productive lands.  Reduces resource requirements for altering
     or supplementing naturally occurring resources vith man
     induced resources (e.g. fertilizers).

10.   Enhancement of Recreation Opportunities - Requires additional
     resources and efforts by the grant applicant, to integrate
     project into any existing or -proposed recreational sites.
     Enhances existing recreational resource.

11.   Funding of Waste-water Facilities for Northern Douglas
     County - Shifts resource requirements from federal and local
     governments to land developers.

12.   Other Study Needs - Requires additional efforts by DRCOG in
     evaluating these special problems under the on-going Clean
     Water Program.
                           72

-------
APPENDICES

-------
                                      Appendix  A
                                EXECUTIVE  CHAMBERS
RICHARD 0. LAMM
   Governor
                                     January 10, 1978
                                                                                    -••s
                                                                 £-',''; JAN 13 1978

                                                                 ll^C'vV.vOJiSii:
Afr. Alan Merson
Regional Administrator
Environmental Protection Agency
1860 Lincoln
Denver, CO  802Q3

Dear Alan:

     It is my pleasure to notify you of the State's approval of the 208 water quality
management plan developed by the Denver Regional Council of Governments for the desig-
nated area  of Adams, Arapahoe, Boulder, Denver, and Jefferson Counties and my condi-
tional certification of that plan as the official State water quality management plan
for that region.  Attached are a copy of a letter to Mr. Donald DeDecker, Chairman of
DRCOG, notifying him of our actions, a list of  conditions of plan certification, and
a briefing paper which summarizes the basis of  our review and approval decisions.  The
State certification of this plan is consistent  with the terms of certification con-
tained in the program regulations, 40CFR Part 131.

     The State congratulates DRCOG and its staff on the actions and basic information
contained in the initial plan.  The State is particularly supportive of the efforts
made in defining regional population projections and allocations of those projections;
in emphasizing the decentralization of wastewater facilities in the interest of total
water management; in determining  the general locations, timing, and capacities of fu-
ture wastewater facilities; in  taking  the initial steps to  define management agencies
and responsibilities for those  point sources; and in making initial assessments of the
impacts of  urban runoff on water  quality.

     In  the interest of strengthening  and expanding the basic  features of  the initial
plan during the ongoing program,  I have  approved  the attached  conditions to this plan
certification including a more  detailed  definition  of  my  actions with respect to man-
agement  agencies.   Those general  conditions  are intended  to provide supporting infor-
mation regarding future stream  classifications, future nonpoint source activities, and
related more technically oriented water quality management aspects of the  Program
DRCOG  is also being asked  to  coordinate the various projects being proposed for  the
 northern suburban  area communities for combined compatibility  and effectiveness.

      The actions which I am taking on the management system reflect  a strong State in-
 terest in having plan implementation build upon the ^™^*^^J?™?^


                                           73

-------
Mr. Alan Merson                                                      January 10,  1978


the municipalities listed in the plan (including Northglenn, which was added by DRCOG
at its meeting of December 21, 1977J and the Metropolitan Ztenver Sewage Disposal  Dis-
trict Number 1 as management agencies.  In addition, I am designating those special
purpose districts that are in the process of receiving construction grant assistance
or are scheduled to receive grant assistance in the near future and the St, Vrain-Left
Hand Conservancy District as management agencies for a two-year period,

     Finally, I am designating the Denver Regional Council of Governments as the  on-
going planning agency for this program for the 5-county area.  We believe that DRCOG
has provided an excellent beginning for this program and will maintain the momentum
created,  fie are aware that the extent of meeting the conditions contained herein will
depend to a large degree upon the availability of ongoing program funds.  We trust
that adequate program funds for Colorado are forthcoming to permit the continuation  of
the overall 208 program.

     The position taken herein has been developed with a broad base of assistance and
support from pertinent State agencies and the Statewide 208 Policy Advisory Group and
with close coordination of the DRCOG staff and officials.  We are sensitive to the
need to proceed promptly, especially in view of the linkage between the 208 plan  and
the Denver EIS and associated grant assistance for municipal wastewater facilities.
Although the Attorney General's Office has recently advised the Water Quality Control
Commission that it needs to hold a public hearing on the plan, we believe that it is
prudent to certify the plan.  I have asked the Commission to conduct the hearing  as
soon as practical.  Following the the hearing, the State position as contained herein
will be reviewed and revised as necessary to reflect the hearing results.

     We hope that you will concur with our actions and promptly approve the plan  as
submitted.  Please feel free to call on Jim Monaghan or Gary Broetzman should you or
your staff care to discuss this further.  We have appreciated the help provided by
your office and trust that the cooperative effort underway with this program will
continue.
                               Si ncerel y ,      _

                               *^^^^*"     A \ /  %. ^"^\
                                y\ UJ-cX. » ^c*/^-^-^-^
                               Richard D.
                               Governor

attachment
                                       74

-------
                      STATE CONDITIONS OF PLAN CERTIFICATION

                               FOR THE DRCOG 208 PLAN


GENERAL CONDITIONS

     1.  DRCOG is to prepare a report in accordance with the attached outline which
shall  become an official part of the 208 final Clean Water Technical  Report.   The  pre-
paration shall be coordinated with the Water Quality Control Commission.

     2.  State certification of the plan does not mean endorsement of the recommended
stream classifications.  The recommendations included in the plan will be considered
by the Commission to guide water quality decision-making during the period until  the
Commission reclassifies those streams according to the revised water quality stream
classification system currently under consideration.  When reclassifying the waters  of
the 5-county Denver regional area, the Commission will consider:
         a.  recommendations and supporting information in the 208 plan.

         b.  testimony presented at public hearings on the issue.
         c.  recommendations and requirements of 208 plans for adjoining regions.

         d.  goals, objectives, and requirements of appropriate State and Federal
             statutes and  regulations.

     3.  DRCOG, wity State assistance,  is to  revise the waste  load allocations as ne-
cessary following stream ^classifications by the  Commission.  Such revisions shall  be
included in the first annual plan update provided  that  the  streams are  reclassified in
time for this  to  be accomplished.

     4  DRCOG is to  include a  time-phased strategy for achieving  those adopted stream
classifications by  no  later than  the  year 2000,  if feasible,  in  the first annual plan
update, provided  the  streams are  reclassified in  time  for  this to  be  accomplished.

      5  DRCOG is to  redefine,  as  necessary,  the  list  of  projects  and their  priorities
set forth  in  the  plan  in the first  annual .plan  update  to  conform to  the construction
grants priority system  established  by the Commission.   Any projects  considered of pri-
ority  to the  region but not recognized as such  by the  Commission's priority  system  are
 to be  brought to  the  attention  of the Commission.

      6  The  State  will  revise  all  NPDES discharge permits upon  their expiration  to
 conform with  the waste load  allocations (upon State adoption)  referred  to  in condi-
 tion  3 and other pertinent constraints called for in the plan and State regulations.

      7   DRCOG is to  give  priority to assisting  the pertinent municipalities and the
 Water Quality Control Commission in resolving the apparent conflicting  wastewater
 treatment proposals in the Broomfield, Westminster, Nort hglenn,  and  Thornton area to
 assure that the final solution for that area best meets the goals of P.L.  92-500.
              s
 lei TTearW 1978)   That definition of processes is to include the objectives  long-
  nd  hoft-l^'r^edill measures, management agencies ^.{^^"^^SS1^ Us
 latorv controls   A draft of this work should be made available to the State for its
 review anS comment prior to its inclusion  in the first annual plan update.
                                        75

-------
State Conditions of Plan Certification for the DRCOG 208 Plan                   page 2
    9.   Although the population projections and allocations are compatible with the
projections currently published by the Divison of Planning, Department of Local  Af-
fairs, these have not been completely analyzed yet under the air quality and transpor-
tation planning programs within the region.  Consequently, as air quality and transpor-
tation plans are developed and refined, the region's 208 plan will have to be reviewed
and perhaps revised.

   10.   DRCOG is to meet with the elected officials of city and county governments
within 6 months of the date of State certification to explain the principal features
of the 208 plan and how local plans can best be modified to support this regional pro-
gram.  In conjunction with the first annual plan update, DRCOG will assess the prog-
ress of local plan revisions to reflect the region's 208 plan.

   11.   The State will review and revise  its overall position on this plan as neces-
sary to reflect the results of a public hearing to be  conducted by the Water Quality
Control Commission.

ACTIONS ON MANAGEMENT AGENCIES

    1    The municipalities  included in the plan as amended  (Aurora, Arvada, Brighton,
Denver, Glendale, Deer Trail, Lafayette, Louisville, Littleton, Englewood, Broomfield,
Westminster, Boulder, Nederland, and Northglenn) and the Metropolitan Denver Sewage
Disposal District Number  1 are designated  as management agencies.

    2.   In  conjunction with the first annual plan  update,  the management  agency sta-
tus for Northglenn  is to  be  reviewed in relation to State and Federal actions on the
Northglenn project.

    3.   The South  Lakewood  Sanitation District, South Adams County Water  and Sanita-
 tion  District,  and  the  Erie  Water  and Sanitation District are designated as management
agencies for their  defined  201  facilities  planning  area for a two-year  period.  The
St. Vrain-Left Hand Conservancy  District  is also designated as  a  management agency  for
 the  portion  of the  St.  Vrain basin within  Boulder County  for a  two-year period  condi-
 tioned upon  the development of  contractual arrangements between the District and the
municipalities to  be served.

     4.   Within one year of plan certification, DRCOG,  in close working cooperation
 with  appropriate counties and  the major  cities  not  identified as management agencies,
 is to reevaluate the management agency  recommendations  covering:

          a.  Jefferson County Mountain Area
          b.  Boulder County Area
          c.  Special Purpose Districts

          The reevaluation should focus on establishing  an active management role for
 general purpose governments for point source management in these areas.  The following
 criteria  should be used in establishing revised management agency recommendations:
          a. have management jurisdiction over the entire  area and replace the  provi-
             sion for temporary management agencies contained in the plan.
          b. have capabilities to relate decisions between growth and development and
             associated services.
                                        76

-------
State Conditions of Plan Certification for the DRCOG Plan
page 3
         c.  provide for coordinated management over both point and nonpoint sources.
         d.  incorporate management responsibilities over package treatment plants  and
            septic tanks.

         In the evaluation of alternative proposals for determining management agencies,
the principal consideration should be the identification of those entities that can  best
implement the broad goals and objectives and comply with the requirements of P.L.  92-500.
Identification of management agencies in this process is to be completed within one  year
and submitted to the State for approval.  At the end of the second year, the necessary
agreements and contractual arrangements need to be in effect to permit operation of  the
management system.
                                         77

-------
               OUTLINE OF ADDENDUM OF TECHNICAL REPORT TO DRCOG 208 PLAN
  I.   INTRODUCTION

      A.   Overview of  the  DRCOG Clean Water Program
      B.   Purpose of the Report
      C.   Use  of the Report

 II.   CHERRY CREEK BASIN

      A.   Existing Situation in the Basin

          1.   Water Quality  Conditions
          2.   Point Source Discharges
         . 3.   Nonpoint Sources of Pollution
          4.   Water Supply Intake  (surface and groundwater)
          5.   Existing Groundwater Conditions

      B.   Environmental Considerations  in the  Basin

          1.   General  Environmental Aspects
          2.   Impacts  on Stream Classifications

      C.   Financial Considerations of Alternative Stream Classifications

          1.   Costs to Meet  the 1983 Goal
          2.   Alternative  Stream Classifications
          3.   Required Facilities  and Associated Costs
          4.   Recommended  Stream Classifications
          5.   Criteria for Classification Recommendations
          6.   Financial Plan for Attaining the Recommended Classifications
          7.   Recommended  Solutions for Groundwater  Problems

      D.   Public Involvement Considerations  (only where such documentation clarifies
          the basis for the  recommendations)

          1.   General  Public and Citizen Group Meetings
          2.   Water Quality  Management  Task Force Recommendations
          3.   Public Hearing Comments

III.  OTHER BASINS  UTILIZING THE CHERRY CREEK BASIN  OUTLINE

      St. Vrain Creek Basin
      Clear Creek Basin
      Bear Creek Basin
      Sand Creek Basin
      -etc-

 IV.  REGIONAL PERSPECTIVE

      A.   Stream Classification Recommendations
      B.   Point Source Recommendations
      C.   Nonpoint  Source  Recommendations
      D.   Groundwater  Improvement  and Maintenance Recommendations

                                          78

-------
                        APPENDIX B

                      PIAN POLICIES
1.   A POPULATION LEVEL BELOW 2,350,000 SHOULD BE ENCOURAGED
    FOR THE FIVE-COUNTY DENVER METROPOLITAN AREA BY THE YEAR
    2000.  IN ALL PLANNING ACTIVITIES CONDUCTED BY THE DENVER
    REGIONAL COUNCIL OF GOVERNMENTS, A YEAR 2000 FORECAST OF
    2,350,000 PEOPLE FOR THE FIVE-COUNTY DENVER  METROPOLITAN
    AREA WILL BE USED.

2.   A STABLE AND DIVERSIFIED ECONOMY, WHICH PROVIDES ADEQUATE
    EMPLOYMENT OPPORTUNITIES FOR THE REGION'S POPULATION,
    SHOULD BE ENCOURAGED FOR THE DENVER REGION. IN ALL PLAN-
    NING ACTIVITIES CONDUCTED BY THE DENVER REGIONAL COUNCIL
    OF GOVERNMENTS, A YEAR 2000 FORECAST OF  1,130,500 JOBS FOR
    THE FIVE-COUNTY DENVER METROPOLITAN AREA WILL BE USED.

3.   THE CENTRAL BUSINESS DISTRICT OF  DENVER WILL BE ENCOURAGED
    AS THE MAJOR HIGH DENSITY CORE OF BUSINESS,  CULTURAL,
    GOVERNMENTAL, COMMERCIAL AND RESIDENTIAL  ACTIVITY.

4.  REGIONAL ACTIVITY CENTERS, WITH AN INTENSIVE MIX OF URBAN
    ACTIVITIES, SHOULD BE ENCOURAGED IN THE  DENVER REGION AND
    SHALL BE DESIGNATED AND  IMPLEMENTED IN ACCORDANCE WITH
    ADOPTED POLICIES AND CRITERIA.

5.  NEW DEVELOPMENT SHOULD BE ENCOURAGED ONLY IN LOCATIONS
    CONTIGUOUS TO EXISTING URBAN AREAS WHILE RECOGNIZING
    LOCAL ECONOMIC, ENVIRONMENTAL AND SOCIAL CONCERNS AS
    THEY MIGHT AFFECT THE LOCATION OF A SPECIFIC DEVELOPMENT.

6.  MAJOR NEW EMPLOYMENT CONCENTRATIONS OF ANY TYPE SHOULD
    BE CLOSELY ANALYZED AS TO THEIR TOTAL REGIONAL IMPACT,
    WHICH ANALYSIS SHOULD CAREFULLY CONSIDER TRANSPORTATION,
    URBAN FACILITIES AND SERVICES, ECONOMIC AND SOCIAL CON-
    SIDERATIONS AND ENVIRONMENTAL IMPACTS.

7    PRESENT FREESTANDING COMMUNITIES WITHIN THE DENVER REGION
    WILL BE ENCOURAGED  TO REMAIN FREESTANDING AND TO RETAIN
     THEIR SEPARATE IDENTITIES AND UNIQUE CHARACTERISTICS.

 8    NEW DEVELOPMENT SHOULD OCCUR ONLY IN LOCATIONS WHERE
    ALL THE  NECESSARY SERVICES REQUIRED TO SUPPORT URBAN
     DEVELOPMENT ARE  PRESENT OR WILL BE PROVIDED.
                              79

-------
 9.   DEVELOPMENT WITHIN ENVIRONMENTALLY SIGNIFICANT AREAS
     SUCH AS ENVIRONMENTAL HAZARD AREAS ,  ENVIRONMENTALLY
     SENSITIVE AREAS, AND NATURAL RESOURCE AREAS SHOULD BE
     PROHIBITED, RESTRICTED, OR APPROPRIATELY MANAGED SUCH
     THAT THE DEVELOPMENT WILL NOT HAVE SIGNIFICANT, ADVERSE
     IMPACTS ON THE ENVIRONMENT AND THE ENVIRONMENT WILL
     NOT POSE SERIOUS HAZARDS TO THE DEVELOPMENT.

10.   THE PROTECTION, PRESERVATION, AND CONSERVATION OF OPEN
     SPACE AS A NATURAL RESOURCE, AN ENVIRONMENTAL HAZARD TO
     DEVELOPMENT, A RECREATIONAL OPPORTUNITY AND A SHAPER OF
     DEVELOPMENT SHOULD BE ENCOURAGED.

11.   NEW DEVELOPMENT SHOULD BE ENCOURAGED IN LOCATIONS AND
     IN  PATTERNS WHICH CONSERVE AND MAKE THE MOST EFFICIENT
     USE OF ENERGY AND SHOULD BE CAREFULLY ANALYZED AS TO THE
     IMPACT ON ENERGY CONSUMPTION . PROPOSALS FOR THE DEVELOP-
     MENT OF ENERGY RESOURCES IN THE REGION SHOULD BE CARE-
     FULLY EXAMINED AS TO THEIR SOCIAL, ECONOMIC AND ENVIRON-
     MENTAL IMPACTS.

12.   THE REGIONAL HOUSING PLAN DIRECTED AT THE PROVISION OF A
     DECENT HOME FOR EVERY FAMILY, AND IN PARTICULAR, THE LOW
     AND MODERATE INCOME GROUPS, SHALL  BE AN INTEGRAL COM-
     PONENT OF ALL DENVER REGIONAL COUNCIL OF GOVERNMENTS'
     LAND USE PLANNING ACTIVITIES AND PARTICULARLY IN RELATION
     TO TRANSPORTATION, EMPLOYMENT OPPORTUNITIES, AND SOCIAL
     SERVICES.
                                80

-------
              REGIONAL DEVELOPMENT POLICIES
AREAWIDE POLICIES

A.  Urban Development

    1.  URBAN DEVELOPMENT SHOULD OCCUR ONLY IN DEFINED
        URBAN DEVELOPMENT AREAS—URBAN SERVICE AREAS, RURAL
        TOWN CENTERS AND MOUNTAIN DEVELOPMENT AREAS. MOST
        REGIONAL GROWTH WILL BE ACCOMMODATED IN URBAN SER-
        VICE AREAS, WHILE SMALL AMOUNTS OF REGIONAL GROWTH
        WILL BE ACCOMMODATED IN RURAL TOWN CENTERS AND
        MOUNTAIN DEVELOPMENT AREAS.

    2.  URBAN DEVELOPMENT SHOULD NOT OCCUR IN THE NON-
        URBAN AREAS OF THE REGION.

    3 .  NON-URBAN DEVELOPMENT IN NON-URBAN AREAS SHOULD
        TAKE PLACE ONLY IF:

             (1)  THE DEVELOPMENT WILL NOT HAVE A SIGNIFICANT
                ADVERSE IMPACT UPON REGIONAL SYSTEMS AND WILL
                NOT REQUIRE THE USE OR EXTENSION OF REGIONAL
                SERVICE1 SYSTEMS.

             (2)  THE DEVELOPMENT WILL NOT HAVE AN ADVERSE
                 IMPACT ON THE NATURAL ENVIRONMENT.

             (3)   IT CAN BE DEMONSTRATED BY THE COUNTY AND
                 OTHER AFFECTED LOCAL GOVERNMENTS AND DIS-
                 TRICTS THAT THE PRESENT CAPACITIES OF ROADS AND
                 SCHOOLS ARE ADEQUATE, ADEQUATE COUNTY LAW
                 ENFORCEMENT AND RURAL FIRE PROTECTION ARE
                 AVAILABLE, AND THE PROPOSED DEVELOPMENT CAN
                 BE ADEQUATELY SERVED BY ON-SITE WATER AND
                 SEWER ACCORDING TO LOCAL AND STATE REGULA-
                 TIONS.

     4.  URBAN SERVICE AREAS SHOUII) ACCOMMODATE.MOST OF THE
UKBAJN O£iKV J.V-/ii nruunv uj.j.v^ w —	             ,-.„
FUTURE GROWTH AND DEVELOPMENT IN THE DENVER REGION.

URBAN SERVICE AREAS SHOULD BE DEFINED OR MODIFIED BY
LOCAL GOVERNMENTS BASED ON THE FOLLOWING CRITERIA:
                             81

-------
        (1)  AN URBAN SERVICE AREA IS AN AREA IN WHICH A
            LOCAL GOVERNMENT PLANS TO SUPPORT URBAN
            DEVELOPMENT AND RENEWAL WITH URBAN SERVICES.

        (2)  AN URBAN SERVICE AREA SHOULD BE DEFINED BASED
            ON THE ABILITY AND CAPACITY OF LOCAL GOVERN-
            MENT TO SERVE THE AREA WITH SERVICES NECESSARY
            TO SUPPORT URBAN DEVELOPMENT.

        (3)  AN URBAN SERVICE AREA SHOULD MAXIMIZE THE USE
            OF EXISTING INVESTMENT IN WATER AND SEWER FACIL-
            ITIES, HIGHWAYS, PARKS, TRANSIT SERVICE, AND OTHER
            REGIONAL AND LOCAL SERVICES, AND MINIMIZE THE
            COST OF PROVIDING ADDITIONAL SERVICES.

        (4)  AN URBAN SERVICE AREA SHOULD INCLUDE ENOUGH
            DEVELOPABLE LAND TO ACCOMMODATE FORECASTED
            DEMANDS IN THE SHORT AND LONG RANGE DEVELOP-
            MENT PERIOD.

        (5)  AN URBAN SERVICE AREA SHOULD BE DEFINED IN TERMS
            OF TIME AND IS POSSIBLE THE BOUNDARY OF THE AREA
            SET TO MEET FORECASTED NEEDS IN THE SHORT RANGE
            TO 1985/1990 AND THE LONG RANGE TO THE YEAR 2000.

 6.   THE EXTENT AND STAGING OF DEVELOPMENT WITHIN AN URBAN
     SERVICE AREA SHOULD BE BASED TO A LARGE EXTENT ON THE
     ABILITY OF LOCAL GOVERNMENT TO PROVIDE THE NECESSARY
     URBAN SERVICES WITHIN THE URBAN SERVICE AREA.

 7.   REGIONAL SYSTEMS AND THE FULL RANGE OF URBAN SERVICES
     SHOULD BE PROVIDED ONLY WITHIN URBAN SERVICE AREAS,
     LOCAL OR COMMUNITY SERVICES SHOULD BE PROVIDED IN
     MOUNTAIN DEVELOPMENT AREAS AND RURAL TOWN CENTERS,
     AND ONLY LIMITED COUNTY AND RURAL SERVICES SHOULD BE
     PROVIDED IN NON-URBAN AREAS.

 8.   EXISTING SERVICE SYSTEMS SHOULD BE USED TO FULL  CAPACITY.

 9.   THE MAINTENANCE AND REPLACEMENT OF SYSTEMS AND SER-
     VICES SUPPORTING EXISTING DEVELOPMENT SHOULD HAVE
     PRIORITY OVER THE EXPANSION OF SYSTEMS AND SERVICES TO
     NEW DEVELOPMENT.

10.   PROVISION OF EXCESS SERVICE CAPACITY SHOULD BE LIMITED
     TO THE PROJECTED NEED IN THE SHORT-TERM  (10 YEAR) PERIOD
     UNLESS APPROPRIATE ANALYSIS DETERMINES SUCH SERVICE
     CAPACITY TO BE COST EFFECTIVE.
                              82

-------
11.   RESIDENTIAL DEVELOPMENT SHOULD BE LOCATED WITH CON-
     VENIENCE AND CHOICE IN ACQUIRING GOODS AND SERVICES.

12 .   RESIDENTIAL DEVELOPMENT SHOULD BE LOCATED IN CLOSE
     PROXIMITY TO REGIONAL ACTIVITY CENTERS AND OTHER
     ACTIVITY CONCENTRATIONS OF RETAIL SHOPS, COMMERCIAL
     SERVICES AND EMPLOYMENT OPPORTUNITIES.

13.   NEW RESIDENTIAL DEVELOPMENT SHOULD OCCUR THROUGH-
     OUT THE REGION WITH A DIVERSITY OF HOUSING TYPES AND
     COSTS.

14.   EMPLOYMENT AREAS SHOULD BE LOCATED CONVENIENT TO
     THE TRANSPORTATION SYSTEM.

15.   A MORE BALANCED DISTRIBUTION OF EMPLOYMENT IN RELATION
     TO POPULATION DISTRIBUTION SHOULD BE ENCOURAGED
     THROUGHOUT THE REGION.

16.  HIGH LEVELS AND MIXES OF EMPLOYMENT OPPORTUNITIES
     SHOULD BE ENCOURAGED AT CENTERS OF ACTIVITY.

17.  REGIONAL ACTIVITY CENTERS ARE  AREAS WITH AN INTENSIVE
     MIX OF URBAN ACTIVITIES.  REGIONAL ACTIVITY CENTERS ARE
     MULTI-PURPOSE CENTERS IN THAT THEY MAY INCLUDE RESI-
     DENTIAL,  EMPLOYMENT, COMMERCIAL, RECREATIONAL,
     MEDICAL, CULTURAL, GOVERNMENTAL AND EDUCATIONAL
     ACTIVITIES. EACH CENTER SHOULD CONTAIN AT A MINIMUM
     SIGNIFICANT LEVELS OF INTENSE RESIDENTIAL, EMPLOYMENT
     AND COMMERCIAL ACTIVITY.  AN ACTIVITY CENTER SHOULD
     COVER A RELATIVELY SMALL GEOGRAPHICAL AREA.

 18   THE PRIMARY RESPONSIBILITY FOR THE PLANNING AND IMPLE-
     MENTATION OF REGIONAL ACTIVITY CENTERS RESTS WITH
     LOCAL GOVERNMENTS AND THE PRIVATE MARKET. LOCAL
     GOVERNMENTS SHOULD FACILITATE THE DEVELOPMENT OF
     REGIONAL ACTIVITY CENTERS  THROUGH ACTIONS CONSISTENT
     WITH ADOPTED REGIONAL POLICY AND CRITERIA. LOCAL
     ACTIONS SHOULD INCLUDE:

          (1)  ADOPTION OF THE ACTIVITY CENTER CONCEPT AND
              THE SPECIFIC DESIGNATION OF CENTERS IN THE
              OFFICIAL COMPREHENSIVE  PLAN FOR THE LOCAL
              JURISDICTION.
                           83

-------
         (2)  PREPARATION OF SPECIFIC PLANS AND PROGRAMS
            FOR THE DEVELOPMENT OF DESIGNATED REGIONAL
            ACTIVITY CENTERS.  SUCH PLANS AND PROGRAMS
            SHOULD DEFINE THE GEOGRAPHIC AREA, THE TYPES
            AND LEVELS OF ACTIVITIES, THE ANTICIPATED STAGING
            AND TIMING OF DEVELOPMENT,  THE GENERAL DESIGN
            CHARACTERISTICS, AND REQUIRED PUBLIC AND PRI-
            VATE ACTIONS FOR IMPLEMENTATION.

         (3)  PROVISION OF ADEQUATE GROWTH MANAGEMENT
            TOOLS TO PROMOTE DEVELOPMENT OF THE ACTIVITY
            CENTER.

         (4)  ENCOURAGING PRIVATE MARKET DECISIONS WHICH
            PROMOTE THE DEVELOPMENT OF ACTIVITY CENTERS.

19.   THE DENVER REGIONAL COUNCIL OF GOVERNMENTS SHOULD
     SUPPORT LOCAL PLANNING AND DEVELOPMENT OF REGIONAL
     ACTIVITY CENTERS THROUGH APPROPRIATE ACTIONS TO:

         (1)  INCORPORATE THE ACTIVITY CENTER POLICY AS A
            MAJOR ELEMENT IN REGIONAL TRANSPORTATION
            PLANNING AND REGIONAL FACILITIES PLANNING.

         (2)  PROVIDE URBAN SYSTEMS FUNDS TO PROJECTS WHICH
            INCREASE THE ACCESSIBILITY TO AND THE MOBILITY
            WITHIN ACTIVITY CENTERS.

         (3)  ENCOURAGE THE PROVISION OF HIGH LEVELS OF
            PUBLIC  TRANSPORTATION TO ACTIVITY CENTERS.

         (4)  ENCOURAGE THE PROVISION OF STATE AND FEDERAL
             HOUSING FUNDS TO PROJECTS WITHIN ACTIVITY
            CENTERS.

         (5)   PROVIDE TECHNICAL PLANNING ASSISTANCE TO AID
            LOCAL GOVERNMENTS IN THE PLANNING AND IMPLE-
             MENTATION OF ACTIVITY CENTERS.

         '6)   CONTINUOUSLY MONITOR AND APPRAISE THE DEVELOP-
             MENT OF DESIGNATED REGIONAL ACTIVITY CENTERS.

20.  THE DRCOG HAS DESIGNATED 12 REGIONAL ACTIVITY CENTERS
     WHICH HAVE THE POTENTIAL TO BECOME CENTERS OF" INTENSE,
     MULTI-PURPOSE REGIONAL ACTIVITIES.  THE DESIGNATED
     CENTERS SHOULD BE PERIODICALLY EVALUATED BY THE DRCOG
     IN COOPERATION WITH LOCAL GOVERNMENTS TO DETERMINE
                              34

-------
     IF THESE AREAS ARE IN FACT DEVELOPING AS REGIONAL CENTERS.
     AND STILL REMAIN AS VIABLE ELEMENTS OF THE REGIONAL PLAN.
     NON-VIABLE CENTERS SHOULD BE DELETED FROM THE REGIONAL
     PLAN.

21.   NEW REGIONAL ACTIVITY CENTERS SHOULD BE ADDED TO THE
     REGIONAL PLAN IF IT CAN BE DEMONSTRATED THAT THEY ARE
     CONSISTENT WITH REGIONAL POLICY AND CRITERIA.  THE
     DESIGNATION AND LOCATION OF ADDITIONAL ACTIVITY CEN-
     TERS SHOULD BE BASED ON THE FOLLOWING CRITERIA:

         (1) A REGIONAL ACTIVITY CENTER SHOULD BE LOCATED
            IN AN AREA WHICH HAS AN EXISTING NUCLEUS OF
            ACTIVITY AND WHICH HAS THE POTENTIAL FOR
            DEVELOPING INTO AN INTENSIVE  MULTI-PURPOSE
            CENTER AS DEFINED.

         (2) THE SITE OF A REGIONAL ACTIVITY CENTER SHOULD
            BE ACCESSIBLE BY MAJOR THOROUGHFARES AND
            SHOULD BE SERVED BY HIGH LEVELS OF PUBLIC
            TRANSPORTATION SERVICE TO THE CENTER AND
            WITHIN THE CENTER.

         (3) REGIONAL ACTIVITY CENTERS SHOULD BE LOCATED
            SUCH THAT ADVERSE IMPACTS ON THE ENVIRONMENT
            ARE MINIMIZED.

         (4) REGIONAL ACTIVITY CENTERS SHOULD NOT BE LOCATED
            IN CLOSE PROXIMITY TO EACH OTHER  SUCH THAT THEY
            COMPETE FOR A LIMITED AMOUNT OF HIGH DENSITY
            ACTIVITIES.

         (5) REGIONAL ACTIVITY CENTERS SHOULD BE LOCATED
            IN AREAS WHICH CAN BE MOST EFFECTIVELY PRO-
            VIDED WITH HIGH LEVELS OF URBAN SERVICES AND
            UTILITIES.

         (6) THE DESIGNATION OF REGIONAL ACTIVITY CENTERS
            SHOULD BE BASED IN PART ON THE MARKET POTEN-
            TIALS FOR SUCH CENTERS.

         (7) THERE SHOULD BE A DEMONSTRATION OF LOCAL
            COMMITMENT TO THE SUCCESSFUL DEVELOPMENT
            OF THE CENTER.
                          85

-------
   22.   SUBREGIONAL AND COMMUNITY ACTIVITY CONCENTRATIONS
        SHOULD BE ENCOURAGED TO DEVELOP WITHIN THE REGION
        AS LONG AS THEY DO NOT DETRACT FROM OR COMPETE
        WITH REGIONAL ACTIVITY CENTER DEVELOPMENT.

B. Environmentally Significant Areas

   23 .   DEVELOPMENT SHOULD NOT OCCUR WITHIN THE LIMITS OF
        THE 100-YEAR FLOODPLAIN NOR SHOULD ANY FILLING IN OF
        THE FLOODPLAIN THAT WOULD REDUCE ITS FLOOD CARRYING
        CAPACITY. PARKS, RECREATION AND OPEN SPACE USES ARE
        ENCOURAGED IN FLOODPLAIN AREAS.

   24.   DEVELOPMENT SHOULD NOT OCCUR IN WILDFIRE HAZARD
        AREAS UNLESS ADEQUATE WILDFIRE HAZARD MITIGATION
        MEASURES HAVE BEEN IMPLEMENTED.

   25.   DEVELOPMENT SHOULD NOT OCCUR ON IDENTIFIED LAND-
        SLIDE DEPOSITS OR POTENTIAL LANDSLIDE HAZARD AREAS
        UNLESS THE HAZARD CAN BE MITIGATED THROUGH ENGI-
        NEERING DESIGN AFTER A CAREFUL SITE AND SUB-SURFACE
        INVESTIGATION AND EVALUATION BY A QUALIFIED ENGI-
        NEERING GEOLOGIST.

   26.   DEVELOPMENT SHOULD NOT OCCUR IN SUBSIDENCE HAZARD
        AREAS UNLESS THE HAZARD  CAN BE SAFELY MITIGATED OR IT
        CAN BE PROVEN THAT LITTLE OR NO RISK OF DAMAGE EXISTS
        ON THE SPECIFIC SITE.  FEDERAL, STATE AND LOCAL AGEN-
        CIES ARE ENCOURAGED TO MAKE A BETTER DETERMINATION
        OF THE EXTENT OF SUBSIDENCE HAZARD RISK IN IDENTIFIED
        SUBSIDENCE HAZARD AREAS.

   27.   DEVELOPMENT IN AREAS OF SHRINK-SWELL SOIL HAZARD
        SHOULD OCCUR ONLY AFTER APPROPRIATE AND EFFECTIVE
        MITIGATION MEASURES, AS DETERMINED BY QUALIFIED
        SOIL ENGINEERS, HAVE BEEN TAKEN TO LESSEN THE POTEN-
        TIAL FOR  STRUCTURAL DAMAGE.

   28.  DEVELOPMENT SHOULD NOT OCCUR OVER ACTIVE FAULTS.
        DEVELOPMENT ADJACENT TO INACTIVE FAULTS SHOULD BE
        DESIGNED SUCH THAT SEPTIC SYSTEM LEACH FIELDS ARE
        LOCATED FAR ENOUGH AWAY  FROM THE FAULTS TO AVOID
        THE POSSIBILITY OF LEAKAGE  OF CONTAMINANTS THROUGH
        THE FAULTS TO THE GROUNDWATER SUPPLY.
                                  86

-------
29.  DEVELOPMENT IN SIGNIFICANT WILDLIFE HABITAT AREAS
     (AREAS OF VERY HIGH DENSITY AND PRODUCTION) SHOULD
     OCCUR ONLY AFTER AN EVALUATION OF THE SITE HAS BEEN
     MADE BY THE COLORADO DIVISION OF WILDLIFE AND IT IS
     DETERMINED THAT  THE IMPACT ON WILDLIFE HABITAT IS NOT
     ADVERSE OR THE ADVERSE IMPACT IS MITIGATED.

30.  DEVELOPMENT IN AREAS WHICH CONTAIN COMMERCIALLY
     FEASIBLE DEPOSITS OF SAND, GRAVEL AND QUARRY AGGRE-
     GATE SHOULD NOT OCCUR UNTIL THE DEPOSITS ARE EXTRACTED
     OR IT CAN BE SHOWN THAT EXTRACTION WOULD CAUSE
     SERIOUS, ADVERSE  IMPACTS ON EXISTING DEVELOPMENT.

31.  DEVELOPMENT IN AREAS WHICH CONTAIN COMMERCIALLY
     FEASIBLE DEPOSITS OF COAL SHOULD NOT INTERFERE WITH
     THE PRESENT OR FUTURE EXTRACTION OF THE COAL DEPOSITS,
     UNLESS IT CAN BE SHOWN THAT EXTRACTION WOULD HAVE
     SERIOUS, ADVERSE  IMPACTS ON EXISTING DEVELOPMENT.
     FEDERAL, STATE AND LOCAL GOVERNMENTS  ARE ENCOURAGED
     TO MAKE A BETTER DETERMINATION OF THE  LOCATIONS AND
     EXTENT OF COMMERCIALLY FEASIBLE COAL DEPOSITS WITHIN
     THE DENVER REGION.

32.  DEVELOPMENT QVER KNOWN OIL AND GAS FIELDS SHOULD
     OCCUR ONLY AT NON-URBAN DENSITIES AND IN USES WHICH
     DO NOT INTERFERE WITH THE EXTRACTION OF THESE  RESOURCES.

33.  DEVELOPMENT SHOULD NOT OCCUR ALONG THE IDENTIFIED
     AQUIFER RECHARGE AREAS OF THE  LARAMIE-FOX HILLS BED-
     ROCK AQUIFER. LAND USES SUCH AS WASTE INJECTION WELLS
     AND  SANITARY LANDFILLS  SHOULD NOT BE PERMITTED OVER
     ALLUVIAL AQUIFERS OR ABOVE RECHARGE AREAS TO SHALLOW
     BEDROCK AQUIFERS.

34.  THE PRESERVATION  OF PRIME FARMLAND SHOULD  BE ENCOUR-
     AGED IN THE DENVER REGION BASED UPON A WELL DEFINED
     PROGRAM(S) THAT IS EQUITABLE TO BOTH THE AGRICULTURAL
     COMMUNITY AND THE REGION AND WHICH INVOLVES THE
     PARTICIPATION OF ALL UNITS AND LEVELS OF GOVERNMENT.
     PRIME FARMLANDS SHOULD  BE DEFINED AND DESIGNATED FOR
     THE DENVER REGION.

35.  DEVELOPMENT SHOULD NOT BE PERMITTED  IN PRESENTLY IDEN-
     TIFIED AREAS OF PRIME AGRICULTURAL SOILS WHICH ARE
     LOCATED IN THE NON-URBAN AREAS OF THE DENVER REGION.
                           87

-------
  36.  EXISTING AND PROPOSED PARK, RECREATION AND OPEN SPACE
       AREAS THAT HAVE BEEN DESIGNATED IN THE ADOPTED DRCOG
       REGIONAL PARKS, RECREATION AND OPEN SPACE DEVELOPMENT
       PLAN SHOULD NOT BE DEVELOPED IN OTHER USES.

  37.  THE DEVELOPMENT OF OUTDOOR RECREATION FACILITIES THAT
       SERVE THE VARIETY OF IDENTIFIED NEEDS AND MAXIMIZE
       ACCESSIBILITY AND USE SHOULD BE ENCOURAGED IN THE
       DENVER REGION.

  38.  THE ACQUISITION OF OPEN SPACE SHOULD BE ENCOURAGED IN
       ADVANCE OF URBANIZATION WHEREVER POSSIBLE TO PRESERVE
       OPEN SPACE, PROTECT THE ENVIRONMENT AND TO SHAPE URBAN
       DEVELOPMENT.

  39.  HISTORICAL PLACES WHICH HAVE BEEN DESIGNATED ON EITHER
       THE STATE OR NATIONAL REGISTERS SHOULD  BE PRESERVED.

  40.  THE IDENTIFICATION AND PRESERVATION, RESTORATION OR
       REHABILITATION OF SIGNIFICANT HISTORIC STRUCTURES, SITES
       AND DISTRICTS BY LOCAL COMMUNITIES SHOULD BE ENCOUR-
       AGED.

  41.  DEVELOPMENT IN A DESIGNATED ARCHAEOLOGICAL RESOURCE
       AREA SHOULD PROVIDE FOR THE PERMANENT PRESERVATION OF
       THE RESOURCE OR PROVIDE FOR THE COMPLETION OF THE
       NECESSARY AND APPROPRIATE STUDY AND WORK AS SPECIFIED
       BY THE OFFICE OF THE STATE ARCHAEOLOGIST BEFORE ANY
       ASPECT OF DEVELOPMENT BEGINS.

C. Regional Activity Allocations

  42.  ADOPTED REGIONAL SUBAREA POPULATION AND EMPLOYMENT
       ALLOCATIONS SHALL BE USED FOR ALL PLANNING ACTIVITIES
       OF THE DRCOG, AND ADDITIONAL ALLOCATIONS CONSISTENT
       WITH THE ADOPTED SUBAREA ALLOCATIONS FOR SUCH GEO-
       GRAPHIC AREAS AS MAY BE NECESSARY AND APPROPRIATE TO
       THE CONDUCT OF REGIONAL PLANNING ACTIVITIES SHOULD
       BE PREPARED.

   43.  AN ANNUAL ASSESSMENT OF THE REGIONAL POPULATION AND
       EMPLOYMENT FORECASTS AND ALLOCATIONS BASED ON THE
       FOLLOWING CRITERIA SHALL BE CONDUCTED:

            (1) ALL LOCAL PROJECTIONS AND POLICIES AND RELEVANT
               TECHNICAL STUDIES AND INFORMATION PROVIDED BY
                LOCAL GOVERNMENTS.
                                  88

-------
        (2)  CURRENT REGIONAL POPULATION AND EMPLOYMENT
            ESTIMATES FOR CENSUS TRACTS, COUNTIES, MUNI-
            CIPALITIES AND URBAN SERVICE AREAS .

        (3)  CHANGES IN POPULATION, EMPLOYMENT AND OTHER
            MEASURES OF DEVELOPMENT SINCE THE LAST U.S.
            CENSUS.

        (4)  ANY SURVEYS, STUDIES OR ASSESSMENTS OF PRESENT
            AND FUTURE GROWTH AND DEVELOPMENT MADE BY
            THE DRCOG DURING THE PRECEEDING YEAR.

        (5)  FEDERAL AND STATE POLICIES WHEN ESTABLISHED BY
            LAW OR ADMINISTRATIVE REGULATION.

     THIS ASSESSMENT WILL PROVIDE  THE  BASIS  FOR CONSIDERING
     CHANGES  TO THE REGIONAL POPULATION AND EMPLOYMENT
     FORECASTS AND ALLOCATIONS. A CHANGE  IN REGIONAL SUB-
     AREA POPULATION AND EMPLOYMENT  ALLOCATIONS SHALL BE
     CONSIDERED WHEN THE CHANGE CAN BE DEMONSTRATED TO
     HAVE SIGNIFICANT IMPACT ON PROJECTED SERVICE NEEDS
     USED IN PLANNING REGIONAL FUNCTIONAL SYSTEMS, OR
     WHEN AN  ADOPTED PLAN OR POLICY, OR PLAN ELEMENT(S),
     IS SIGNIFICANTLY CHANGED.

44   THE APPROVED REGIONAL SUBAREA POPULATION AND EMPLOY-
     MENT ALLOCATIONS SHALL BE USED FOR THE PURPOSE OF
     REVIEWING PROJECTS SUBMITTED TO  THE DRCOG UNDER THE
     PROVISIONS OF FEDERAL OR STATE LAW, OR ADMINISTRATIVE
     REGULATIONS.  THE FOLLOWING STANDARDS SHALL BE USED
     IN REVIEWING PROJECTS:

         (1)  IF THE PROJECTED RESIDENT POPULATION AND/OR
             EMPLOYMENT WHICH A PROPOSED PROJECT IS
             DESIGNED TO SERVE IS WITHIN 15% OF THE DRCOG
             REGIONAL SUBAREA POPULATION ALLOCATION,
             REGARDLESS OF THE SIZE OF THE NUMERICAL DIF-
             FERENCE  BETWEEN THE PROJECTION AND THE ALLO-
             CATION,  THE DRCOG STAFF WILL  FIND THE PROJECTED
             RESIDENT POPULATION  "CONSISTENT WITH REGIONAL
             POPULATION FORECASTS AND ALLOCATIONS" AND WILL
             SO COMMENT;

         (2)  IF THE PROJECTED RESIDENT POPULATION AND/OR
             EMPLOYMENT WHICH A PROPOSED PROJECT IS
             DESIGNED TO SERVE IS WITHIN 6,000 TO 20,000 PER-
             SONS AND/OR 3,000 TO 10,000 JOBS OF THE APPROVED
                          89

-------
           REGIONAL SUBAREA ALLOCATION (S) AND THE NUMERICAL
           DIFFERENCE BETWEEN THE PROJECTION AND ALLOCATION
           IS MORE THAN 15% OF THE ALLOCATION, DRCOG STAFF
           SHALL REQUEST A TECHNICAL JUSTIFICATION OF THE
           PROJECTED RESIDENT POPULATION AND/OR EMPLOYMENT
           FROM THE APPLICANT AND SHALL INCLUDE AN EVALUA-
           TION OF SUCH JUSTIFICATION IN ANY COMMENT ON THE
           PROPOSED PROJECT.  THE APPLICANT MAY APPEAL TO THE
           COUNCIL FOR A REVIEW OF THE COMMENTS ON THE PRO-
           POSED PROJECT PREPARED BY THE DRCOG STAFF; AND

        (3)  IF THE PROJECTED RESIDENT POPULATION FOR WHICH A
           PROPOSED PROJECT IS DESIGNED TO SERVE IS MORE THAN
           20,000 PERSONS  AND/OR THE PROJECTED EMPLOYMENT
           IS MORE THAN 10,000 JOBS HIGHER THAN THE APPROVED
           REGIONAL SUBAREA ALLOCATION (S) AND THE  NUMERICAL
           DIFFERENCE BETWEEN THE PROJECTION AND ALLOCATION
           IS MORE THAN 15% OF THE ALLOCATION, THE DRCOG
           STAFF SHALL REQUEST A TECHNICAL JUSTIFICATION OF
           THE RESIDENT POPULATION AND/OR EMPLOYMENT  PRO-
           JECTION FROM THE APPLICANT.  THE DRCOG STAFF SHALL
           INCLUDE AN EVALUATION OF THE TECHNICAL JUSTIFICA-
           TION  IN COMMENTS ON THE PROPOSED  PROJECT AND
           FORWARD THE COMMENTS TO THE COUNCIL PRIOR TO
           TRANSMITTAL OF THE COMMENTS TO THE APPLICANT.

DEVELOPMENT AREA POLICIES

A.- Denver Central Bit slug ss District


   45.  RESIDENTIAL DEVELOPMENT SHOULD  BE ENCOURAGED WITHIN
        THE CBD.

   46.  RESIDENTIAL NEIGHBORHOODS ADJACENT TO THE DENVER CBD
        SHOULD BE IMPROVED AND MAINTAINED.

   47.  CONTINUED EMPLOYMENT GROWTH SHOULD BE ENCOURAGED
        IN THE  DENVER CBD.

   48.  THE ACCESS TO THE  DENVER CBD AND INTERNAL CIRCULATION
        WITHIN THE CBD SHOULD BE IMPROVED PRIMARILY THROUGH
        INVESTMENTS IN PUBLIC TRANSPORTATION .

   49   THE ENVIRONMENTAL QUALITY WITHIN THE DENVER CBD
        SHOULD BE IMPROVED BY REDUCING AIR AND NOISE POLLUTION
        AND PROVIDING MORE OPEN SPACE GFPGPTJN'JTrES.

-------
B. Central City - City and County of Denver

   50.   THE HIGH LEVELS OF RESIDENTIAL QUALITY IN STABLE NEIGH-
        BORHOODS SHOULD BE MAINTAINED AND THE RESIDENTIAL
        QUALITY IN DECLINING AND DETERIORATING NEIGHBORHOODS
        SHOULD BE IMPROVED WITHIN THE CITY OF DENVER.

   51.   THE INVOLUNTARY CONCENTRATIONS OF LOW INCOME PER-
        SONS, ELDERLY, HANDICAPPED AND ETHNIC MINORITIES
        SHOULD BE REDUCED WITHIN THE CITY OF DENVER.

   52.   THE ECONOMIC VITALITY OF THE CITY OF DENVER SHOULD BE
        IMPROVED BY PROVIDING MORE EMPLOYMENT OPPORTUNITIES.

   53 .   REDEVELOPMENT OF DETERIORATING OR OBSOLETE AREAS WITH-
        IN THE CITY OF DENVER SHOULD BE ENCOURAGED WITH A
        HIGH PRIORITY ON NEW HOUSING IN THESE AREAS.

   54.   EQUITABLE COMPENSATION SHOULD BE  PROVIDED TO THE CITY
        OF DENVER FOR AREAWIDE USE OF REGIONAL FACILITIES PRO-
        VIDED BY DENVER.

C. Regional Development Areas  (Urban Service Areas)

   55.   NEW DEVELOPMENT WITHIN URBAN SERVICE AREAS SHOULD
        OCCUR CONTIGUOUS TO EXISTING DEVELOPMENT AND THE
        IN-FILL OF THE EXISTING PATTERN WHERE  DEVELOPMENT HAS
        "LEAP-FROGGED" IN THE PAST  SHOULD  BE ENCOURAGED.

   56.   MUNICIPAL GOVERNMENTS WITHIN URBAN SERVICE AREAS ARE
        ENCOURAGED TO ANNEX UNINCORPORATED AREAS WHICH ARE
        CURRENTLY DEVELOPED OR ARE SCHEDULED FOR DEVELOPMENT
        BASED ON THE FOLLOWING GUIDELINES:

            (1)   ANNEXATION SHOULD REPRESENT A LOGICAL EXTEN-
                SION OF A MUNICIPALITY'S BOUNDARY.

            (2)   ANNEXATION SHOULD BE CONSISTENT WITH MUNI-
                CIPALITIES' ABILITY AND CAPACITY TO SERVE THE
                ANNEXED AREA WITH URBAN SERVICES AND  FACILITIES.

            (3)   ANNEXATION SHOULD BE BASED ON A LOGICAL PRO-
                GRAM AND SCHEDULE DEVELOPED BY THE MUNICIPALITY.

   57.   ESTABLISHED RESIDENTIAL AND COMMERCIAL AREAS WITHIN
        URBAN SERVICE AREAS SHOULD BE MAINTAINED AND PRESERVED.
                             91

-------
D. Plains

   58.   THE AGRICULTURAL CHARACTER OF THE PLAINS SHOULD BE
        PRESERVED.

   59.   NEW DEVELOPMENT IN THE PLAINS SHOULD BE DIRECTED TO
        RURAL TOWN CENTERS WHERE PUBLIC WATER AND SEWER
        SYSTEMS AND OTHER LOCAL SERVICES ARE PRESENT OR CAN
        BE PROVIDED.

   60.   RURAL PUBLIC SERVICE STANDARDS SHOULD BE MAINTAINED
        IN THE PLAINS WHILE NOT ALLOWING THE EXTENSION OF
        REGIONAL SYSTEMS OR THE PROVISION OF REGIONAL SERVICES,

E. Mountains

   61.   NEW DEVELOPMENT IN THE MOUNTAINS SHOULD BE DIR-
        ECTED TO MOUNTAIN DEVELOPMENT AREAS WHERE PUBLIC
        WATER AND SEWER IS PRESENT OR CAN BE PROVIDED.

   62.   THE LOCATION AND EXTENT OF DEVELOPMENT IN THE MOUN-
        TAINS AREA SHOULD BE BASED ON ITS ENVIRONMENTAL
        CAPACITY.

   63.   RURAL PUBLIC SERVICE STANDARDS SHOULD BE MAINTAINED
        IN THE MOUNTAINS AREAS, WHILE NOT ALLOWING THE
        EXTENSION OF REGIONAL SYSTEMS OR THE PROVISION OF
        REGIONAL SERVICES.

   64.   THE SUBSIDIZATION OF MOUNTAINS AREA DEVELOPMENT BY
        THE REMAINING PORTIONS OF THE REGION SHOULD BE
        REDUCED.
                                  92

-------
                            Appendix  C
           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                            WASHINGTON. D.C. 20460

                                 OCT   3 1377
                                                                 THE ADMINISTRATOR
SUBJECT:  EPA Policy on LandX/eat#ient of
          Wastewater
FROM:     The Administrator

TO:.      Assistant AdministVatorfe and
          Regional Administrators  (Regions I-X)


     President Carter's recent Environmental Message to the Congress
emphasized the design and construction of cost-effective publicly owned
wastewater treatment facilities that encourage water conservation as
well as adequately treat wastewater.  This serves to strengthen the
encouragement under the Federal Water Pollution Control Act Amendments
of 1972 (P.L. 92-500) to consider wastewater reclamation and recycling by
land treatment processes.

     At the time P.L. 92-500 was enacted, it was the intent of Congress
to encourage to the extent possible the development of wastewater manage-
ment policies that are consistent with the fundamental ecological  principle
that all materials should be returned to the cycles from which they were
generated.  Particular attention should be given to wastewater treatment
processes which renovate and reuse wastewater as well  as recycle the
organic matter and nutrients in a beneficial manner.  Therefore, the
Agency will press vigorously for publicly owned treatment works to
utilize land treatment processes to reclaim and recycle municipal  wastewater.

RATIONALE

     Land treatment systems involve the use of plants  and the soil to
remove previously unwanted contaminants from wastewaters.  Land treatment
is capable of achieving removal levels comparable to the best available
advanced wastewater treatment technologies while achieving additional
benefits.  The recovery and beneficial reuse of wastewater and its
nutrient resources through crop production, as well as wastewater
treatment and reclamation, allow land treatment systems to accomplish
far more than most conventional treatment and discharge alternatives.
                            93

-------
     The application of wastewater on land is a practice that has  been
used for many decades; however, recycling and reclaiming wastewater that
may involve the planned recovery of nutrient resources as part of  a
designed wastewater treatment facility is a relatively new technique.
One of the first such projects was the large scale Muskegon,  Michigan,
land treatment demonstration project funded under the Federal  Water
Pollution Control Act Amendments of 1966 (P.L. 84-650), which began
operations in May 1974.

     Reliable wastewater treatment processes that utilize land treatment
concepts to recycle resources through agriculture, silviculture and
aquaculture practices are available.  The technology for planning,
designing, constructing and operating land treatment facilities is
adequate to meet both 1983 and 1985 requirements and goals of P.L. 92-
500.

     Land treatment is also presently in extensive use for treatment of
many industrial wastewaters, particularly those with easily degraded
organics such as food processing.  Adoption of suitable in-plant pretreatment
for the removal of excessive metals and toxic substances would expand
the potential for land treatment of industrial wastewater and further
enhance the potential for utilization of municipal wastewater and  sludges
for agricultural purposes.

APPROACH

     Because land treatment processes contribute to the reclamation and
recycling requirements of P.L. 92-500, they should be preferentially
considered as an alternative wastewater management technology.  Such
consideration is particularly critical for smaller communities.  While
it is recognized that acceptance, is not universal, the utilization of
land treatment systems has the potential for saving billions of dollars.
This will benefit not only the nationwide water pollution control  program,
but will also provide an additional mechanism for the recovery and
recycling of wastewater as a resource.

     EPA currently requires each applicant for construction grant funds
to make a conscientious analysis of wastewater management alternatives
with the burden upon the applicant to examine all available alternative
technologies.  Therefore, if a method that encourages water conservation,
wastewater reclamation and reuse is not recommended, the applicant should
be required to provide complete'justification for the rejection of
land treatment.

     Imposition of stringent wastewater treatment requirements prior to
land application nas quite often nullified the cost-effectiveness of
land treatment processes in the  past.  We must ensure that appropriate
Federal, State and local requirements and regulations are imposed at the
                                94

-------
 proper point in the treatment system and are not used in a manner that
 may arbitrarily block land treatment projects.  Whenever States  insist
 upor piacing unnecessarily stringent preapplication treatment require-
 ments upon land treatment, such as requiring EPA secondary effluent
 quality in all  cases prior to application on the land,  the unnecessary
 wastewater treatment facilities win  not be funded by EPAi  This  should
 encourage the btates to re-examine and revise their criteria,  and so
 reduce the cost burden, especially to small communities,  for construction
 and operation of unnecessary or too costly facilities.   The reduction of
 potentially toxic metals and organics in industrial  discharges to municipal
 systems often is critical  to the success of land treatment.   The  development
 and enforcement at the local  level  of pretreatment standards that are
 consistent with national pretreatment standards  should  be required as an
 integral  part of any consideration or final selection of  land  treatment
 alternatives.   In addition,  land treatment alternatives must be fully
 coordinated with on-going  areswide planning under section 208 of  the
 Act.   Section  208 agencies should be  involved in the review and development
 of  land treatment options. *

      Research will  be continued to  further improve criteria  for preappli-
 cation treatment and other aspects  of land treatment processes.   This
 will  add  to Our kr.owledge  and reduce  uncertainties about  health and
 environmental factors.   I  am  confident,  however,  that land treatment of
 municipal  wastewaters  can  be  accomplished  without adverse effects on
 human health  if proper consideration  is  given to design and  management
 of  the system.

 INTER-OFFICE COORDINATION

      The  implementation  of more recent mandates  from the  Safe Drinking
 Water"-Act  (P.L.  93-532), the  Toxic  Substances Control Act (P.L. 94-469),
 and the Resource Conservation and Recovery Act of 1976 (P.L. 94-580)
 must  be closely coordinated with the  earlier  mandate  to recycle wastes
 and fully  evaluate  land  treatment in  P.L.  92-500.  Agencywide coordination
 is especially important  to the proper management  of  section  201 of P.L.
 92-500, because the construction and  operation of  thousands of POTW's
 involve such a  broad spectrum of environmental issues.  A concerted
 effort must be  made to avoid  unilateral  actions,  or  even  the appearance
 of unilateral actions, which  satisfy  a particular mandate of one  Act
 while  inadvertently conflicting  with  a major  Agency  policy based  upon
 another Act.  The intention of P.L. 92-500, as it concerns land treatment,
 is compatible with  the pertinent aspects of more  recent environmental
 legislation.

 ACTION REQUIRED

      Each of you must exert maximum effort  to ensure that the actions  of
your  staffs reflect clearly visible encouragement of wastewater reclamation
 and recycling of pollutants through land treatment processes in order  to
move  toward the  national goals of conserving water and eliminating the
 discharge of pollutants  in navigable waters by 1985.


                                 95

-------
                                        4
         This policy will  apply to all future municipal  construction grant
    activities, as well as all  current grant applications  in the Step 1
    category that have not been approved as of this date.   Detailed information
    and guidance for implementation of this policy is  under preparation and will
    be issued in the near  future.
                                         96
* U.S. Government Printing Office: 1978-777-299/291 Regions

-------
                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.
  EPA-905/5-77-001A
                             2.
                                                           3. RECIPIENT'S ACCESSIOI*NO.
4, TITLE AND SUBTITLE
                                                           5. REPORT DATE
  Denver Regional Environmental  Impact Statement for
  wastewater facilities and the  Clean Water Program,
  Volume 1:   Issues and Actions.
            i. PERF
                 ORMING ORGANIZATION CODE
7. AUTHOR(S)
                                                           8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
  U.S.  Environmental Protection Agency
  Region  VIII
  1860  Lincoln Street
  Denver, Colorado 80295
                                                           10. PROGRAM ELEMENT NO.
            11. CONTRACT/GRANT NO.

             Task Order No. 68-01-3441
             BOA No.  68-01-2860
12. SPONSORING AGENCY NAME AND ADDRESS
  U.S.  Environmental Protection Agency
  Region  VIII
  1860  Lincoln Street
  Denver,  Colorado 80295	
                                                           13. TYPE OF REPORT AND PERIOD COVERED
            14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
       This is the ftnal  environmental impact statement  (EIS) prepared by EPA  for  the
 Denver Region concerning  actions to be taken on  10 wastewater facility plans and
 the Denver Clean Water  Plan (208 Plan).  This EIS addresses the regional effects of
 these projects and the  208 Plan considering both direct and secondary impacts.
 Emphasis  is given to the  regional and cumulative impacts of population growth and
 development through the year 2000 which these projects  and plans anticipate.   The
 regional  impacts on air quality, water quality,  recreation, sensitive lands,  agri-
 culture,  economy, and energy are examined.  Volume 1 addresses the most important
 issues and EPA proposed actions.  Volume 2 contains  the detailed analysis of impacts,
 comments  received on the  draft EIS and EPA's responses  to comments.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lDENTIFIERS/OPEN ENDED TERMS  C. COSATI Field/Group
 Water  quality, air quality,  environmental
 sensitive areas, agricultural  land, re-
 creation, environmental management, water
 conservation, nonpoint pollution.
Denver Region  Colorado;
wastewater  facility
plans, 208  plan,  growth.
13. DISTRIBUTION STATEMENT
                                              19. SECURITY CLASS (This Report)
 Unlimited
                          21. NO. OF PAGES

                              113
                                                                         22. PRICE
EPA Form 2220-1 (9-73)

-------