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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
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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.
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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
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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
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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
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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.
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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
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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
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IV. PROPOSED EPA ACTIONS
AND MITIGATIONS
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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
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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
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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
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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
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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
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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
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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.
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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
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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.
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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
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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.
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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.
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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.
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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.
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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.
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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.
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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.
,:
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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.
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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.
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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.
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V. PROBABLE CONSEQUENCES
OF PROPOSED ACTIONS
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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.
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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
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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.
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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.
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APPENDICES
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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
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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
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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.
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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.
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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.
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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
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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.
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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.
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REGIONAL DEVELOPMENT POLICIES
AREAWIDE POLICIES
A. Urban Development
1. URBAN DEVELOPMENT SHOULD OCCUR ONLY IN DEFINED
URBAN DEVELOPMENT AREASURBAN 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:
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(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.
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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.
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(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
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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.
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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.
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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.
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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.
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(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
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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.
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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.
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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.
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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.
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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
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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.
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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
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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)
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