VOLUME 2: ANALYSES, COMMENTS
AND RESPONSES
EPA-908 5-27-001B
DENVER REGIONAL
ENVIRONMENTAL IMPACT
STATEMENT FOR
WASTEWATER FACILITIES
AND THE CLEAN WATER
PROGRAM
FINAL
U.S. ENVIRONMENTAL
PROTECTION AGENCY
REGION VIII. DENVER
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VOLUME 2: ANALYSIS, COMMENTS FINAL
AND RESPONSES
EPA-908/5-77-001B
DENVER REGIONAL
ENVIRONMENTAL IMPACT STATEMENT
for
WASTEWATER FACILITIES
and the
CLEAN WATER PLAN
Prepared by
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION VIII, DENVER
April 1978
«*•-
Approved By:
n
Administrator
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CONTENTS
Page No.
I. INTRODUCTION 1
BACKGROUND 1
ACTIONS UNDER CONSIDERATION IN THIS EIS 4
The 201 Facility Plans 4
The Clean Water Program (208 Plan) 6
THE NEED FOR THIS EIS 7
Air Quality and Water Quality Planning Consistency 7
Impacts of Growth on Achieving Water Quality Standards 8
Relationships of Wastewater Treatment Plant Organization 9
Prime Agricultural Land Losses 9
Sensitive Environmental Areas 10
Socio-economic Impacts 10
Land Treatment and Reuse in the Denver Metropolitan Area 11
THE OBJECTIVES OF THIS EIS 11
THE EIS PROCESS 12
II. THE EXISTING ENVIRONMENT 15
SITUATION AND DESCRIPTION OF THE DENVER REGION 15
ENVIRONMENTAL SENSITIVITIES 16
Regional Climate 16
Air Quality in the Denver Region 17
Climatic Conditions Which Affect Air Quality 17
Effects of Air Pollutants on Health 18
Effects of Air Pollutants on Crops 21
Existing Air Quality 22
Pollutant Emissions in Denver 29
Geology 32
Soils 34
Hydrology 34
Water Supply 36
Surface Water 36
Ground Water 38
Water Quality 38
Desired Water Quality 39
Existing Water Quality 45
Sources of Water Quality Problems 52
Biology 56
Energy 57
Historic Features 58
Outdoor Recreation Sites 58
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Aesthetics 59
Land Waste Disposal and Reuse 59
Traffic 61
Plutonium Contamination and Radiation Hazards 62
SOCIO-ECONOMIC ENVIRONMENT 62
Regional Economy, Population and Land Use 63
The Economy 63
Population 65
Land Use 69
Community Services and Facilities 71
Agricultural Land Use 72
Land in Agricultural Use 74
The Economic Value of Agricultural Activity 76
Future Prospects for Regional Agriculture 77
Regional Planning Policies 78
PUBLIC VIEWS OF ENVIRONMENTAL PROBLEMS 80
Air Quality 80
Water Quality 81
Land Use 81
Other Environmental Issues 83
III. THE PROPOSED PROJECTS AND ALTERNATIVES 85
PROPOSED PROJECTS 85
BACKGROUND 85
Alternative and Preferred Non-Point Source Control
Strategies 86
Alternative and Preferred Wastewater Treatment Facility
Designs 86
South Adams County Water and Sanitation District
Service Area 92
Englewood/Littleton Advanced Wastewater Treatment
Plant 92
South Lakewood Service Area 93
Cherry Creek and Goldsmith Gulch Service Area 93
Lower South Platte Service Area 94
Sand Creek Service Area 94
Clear Creek Service Area 95
Broomfield/Westminster Service Area 95
Northglenn 96
Expansion of Metropolitan Denver Sewage Disposal
District No. 1 Plant 96
The Clean Water Program's Recommended Plan for Municipal
Wastewater Treatment Plants 97
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EIS ALTERNATIVES ^ POINT SOURCES 97
The Local Alternative 97
The Regional Alternative 101
The No-Action Alternative 101
ALTERNATIVES TO STREAM DISCHARGE 101
CLEAN WATER PLAN MANAGEMENT ALTERNATIVES 104
Point Sources 104
Non-Point Sources 105
IV. PROBABLE ENVIRONMENTAL IMPACTS 107
SOCIO-ECONOMIC IMPACTS 107
Regional Population and Economic Impacts 107
Sources of Regional Growth 107
Economic Impacts of Growth 108
Evaluating the Economic Costs
and Benefits of Growth 110
Future Economic Growth in the
Denver Region 111
Future Population Growth in the
Denver Region 113
Community Services and Facilities 116
Costs, Financing and Fiscal Impacts 116
COST CONSIDERATIONS 118
REVENUE CONSIDERATIONS 119
Net Fiscal Impacts and Land Use Planning 119
Impacts of Wastewater System Costs 120
LAND USE CHANGE TO THE YEAR 2000 124
Future Land Use Change 124
Regional Development Patterns 126
Regional Planning Issues 131
Efficiency of Future Development Patterns 132
Population Growth 135
Impact of Wastewater Facilities on Land Use 137
CONVERSION OF AGRICULTURAL LANDS 137
Causes of Agricultural Land Conversion 139
Agricultural Land Conversion as an
Environmental Issue 142
Socio-Economic Impacts of Agricultural
Land Conversion 142
Impacts of Agricultural Land Conversion
on the Natural Environment 144
Conversion of Agricultural Land in the Denver Region 144
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AIR QUALITY IMPACTS 150
Introduction 150
Modeling Air Quality in Denver 151
Error Discovered 152
Data and Assumptions 153
Model Validation 156
Ozone Validation 156
Carbon Monoxide Validation 158
NOX Validation 158
Particulate Validation 158
Denver Air Quality Projections 158
Ozone 159
Carbon Monoxide 159
Nitrogen Dioxide 160
Participates 161
Uncertainty of Results 161
Probable Effects of an Automobile
Inspection and Maintenance Program 166
Possible Effects of a Relaxation of the
NO Emission Standard 167
Effects on Agricultural Crops 168
WATER QUALITY 170
Background 170
The Local Alternative 177
The Regional Alternative 180
The No-Action Alternative 182
Summary 183
GROWTH-INDUCED IMPACTS ON THE REGION'S
ENVIRONMENTALLY SENSITIVE AREAS 190
Climate 190
Geology 190
Soils 191
Hydrology 191
Biology 192
Energy 193
Aesthetics 194
Outdoor Recreation Sites 194
Land Waste Treatment Sites and Wastewater Reuse 194
Traffic 198
DIRECT ENVIRONMENTAL IMPACTS 199
Climate 199
Hydrology 199
Geology 200
Soils 200
Biology 200
Direct Impacts of Local Alternative 200
Direct Impacts of Regional Alternative 202
Direct Impacts of the No-Action Alternative 202
iv
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Energy 203
Transportation 204
Historical Features 204
Outdoor Recreation Sites 204
Land Waste Treatment 206
Aesthetics 206
Construction Effects 207
Operation Effects 207
V. PUBLIC COMMENTS 209
U.S. Department of Agriculture,
Forest Service, 11 July 1977 211
U.S. Department of Agriculture, Soil
Conservation Service, 8 July 1977 213
U.S. Department of the Interior, 1 August 1977 216
Federal Energy Administration, 27 June 1977 223
U.S. Department of Health, Education,
and Welfare, 14 July 1977 225
U.S. Department of Housing and Urban
Development, 8 July 1977 227
U.S. Department of Housing and Urban
Development, 18 July 1977 230
Val R. Veirs, Chairman of the Colorado
Air Pollution Control Commis-
sion, 19 July 1977 234
The Governor of the State of Colorado,
1 August 1977 237
Colorado Department of Health, Division of
Air Pollution Control, 25 July 1977 240
Colorado Department of Health, Division of
Radiation and Hazardous Materials Control,
18 July 1977 246
Colorado Department of Health, Division of
Radiation and Hazardous Materials Control,
20 July 1977 248
Department of Local Affairs, Colorado Division of
Planning, 11 July 1977 250
Colorado Division of Wildlife, 5 July 1977 254
Colorado Division of Water Resources, 20 July 1977 256
The Office of the State Archaeologist, 21 July 1977 258
The State 208 Coordinator, 8 July 1977 261
The State Department of Highways, 21 July 1977 264
The State Historical Society of Colorado, 5 August 1977 272
The State Water Quality Control Division, 28 June 1977 275
State Senator Al Meiklejohn, 25 July 1977 277
The City of Arvada, 18 July 1977 280
City and County of Denver, Department of Parks -
Recreation, 21 June 1977 282
City and County of Denver, Department of Public
Works, 19 July 1977 285
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The City of Northglenn, 18 July 1977 290
The City of Thornton, 18 July 1977 296
The City of Westminster, 14 July 1977 299
The Denver Board of Water Commissioners,
18 July 1977 312
The Denver Board of Water Commissioners,
15 August 1977 315
The Denver Regional Council of Governments,
21 July 1977 318
The Lakewood Board of Water and Sewer
Commissioners, 9 August 1977 328
The Metropolitan Denver Sewage Disposal
District Number 1, 18 July 1977 334
The North West Colorado Council of Governments,
3 August 1977 344
The Regional Transportation District,
21 July 1977 352
The Colorado Open Space Council, 8 August 1977 354
The Denver Chamber of Commerce, 15 August 1977 358
The Denver County Republican Party Water Task
Force, 18 July 1977 364
The Denver Sierra Club 367
Historic Denver, Inc., 23 June 1977 371
The Jefferson County Board of Realtors,
25 July 1977 373
The Legislative Forum of the Arvada Chamber
of Commerce, 22 July 1977 376
The Metro Denver League of Women Voters,
27 July 1977 378
Mrs. N.J. Besch, 17 July 1977 381
Mr. Dan Chiras, 13 July 1977 383
Mr. David R. Cogley, 7 July 1977 387
Mr. Jim Fisher 390
Mr. John L.J. Hart, 14 July 1977 392
Mr. Cal Harvey, 10 July 1977 394
Ms. Bonnie Irvine 396
Mr. Byron L. Johnson, 18 July 1977 398
Mr. C.J. Medema 402
Mr. James E. Mogan 404
Mr. Clarence Paquet, 1st Letter 406
Mr. Clarence Paquet, 2nd Letter 408
Mr. Harry Parmenter and Mrs. Betty Ann
Parmenter, 23 July 1977 410
Mr. David A. Wicks, 17 July 1977 412
VI. GLOSSARY AND BIBLIOGRAPHY 415
DISTRIBUTION LIST
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LIST OF FIGURES
Figure Page No.
I-A Relation of Denver Region to the State of Colorado 2
II-A Air Quality Monitoring Stations 23
II-B Number of Days in 1974 Stations Recorded Levels
Exceeding Standard — Carbon Monoxide 24
1I-C Days Carbon Monoxide Exceeded Standard 25
II-D Carbon Monoxide Levels Compared with Traffic Volume 26
II-E Ozone Formation 27
II-F Number of Days in 1974 Stations Recorded Levels Ex-
ceeding Standard •— Ozone 28
II-G Days Ozone Exceeded Standard 30
II-H Water Supply System - Denver Water Department 35
II-I Denver Region Water Supply and Demand 37
II-J Land Waste Treatment Sites 60
II-K Regional Employment and Population by County 66
III-A Schematic of Local Alternative 100
III-B Schematic of Regional Alternative 102
IV-A Regional Employment and Population by County 115
IV-B Future Service Areas 129
IV-C The Variation of Averages Over All Stations of
Observations and Predictions 157
IV-D Average Projected Particulate Concentrations
1974 and 2000 162
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LIST OF TABLES
Table Page No.
I-A Summary and Status of Denver Region 201 Facility Plans
(1978) 5
II-A National Ambient Air Quality Standards 19
II-B Maximum Pollution Concentrations Measured During -,
1974 and 1975 in Denver
II-C 1974 Denver Emissions Inventory 33
II-D Recommended Water Quality Levels for Specific Water Uses 40
II-E Current State of Colorado Classification by Stream and
Reach 41
II-F Water Quality Attainability/Use Potential 42-44
II-G Wastewater Treatment Facilities Investigated for Their
Impact on Existing Water Quality, Status Circa 1972 46
II-H Existing Water Quality 47-48
II-I Comparison of Estimated Point and Non-Point Source
Loading in the South Platte and Major Tributaries 53
II-J Recent Trends in Nonagricultural Employment by Sector
in the Five-County Denver Region 64
II-K Demographic Characteristics of the Denver SMSA Population,
1970 67
II-L Components of Estimated Resident Population Change, 1975 68
II-M Distribution of Net In-Migrants to Five Counties, 1970-72 68
II-N County Land Use Summary, 1960 and 1970 70
II-O Summary of Available Information on User Charges 73
II-P 1973 Estimates of Agricultural Acreage by Empiric County
in the Denver Region 74
II-Q 1973 Estimates by Political County of Existing Agricultural
Land Within the Region's Major Drainage Basins, but Out-
side the Empiric County Boundaries 75
viii
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Table Page No.
II~R Value of Crop Population by County, 1974 76
III-A Current Facility Plan Alternatives 87-91
III-B Clean Water Plan Recommendations for Municipal Waste-
water Treatment Plants 98
III-C Summary of Alternatives 99
IV-A Incidence of the Economic Impacts of Growth Generated
by Increases in the Production of Goods and Services 1Q9
IV-B Sector Employment Forecast for the Denver Region,
1975-2000 112
IV-C Employment Projections for the Five-County Denver Region 114
IV-D Incidence of the Fiscal Impacts of Growth Generated by an
Increase in the Demand for Public Services 117
IV-E Estimated Aggregate Capital Costs of Wastewater
Facilities Alternatives _ 121
IV-F County Land Use Summary, 1970 and 2000 125
IV-G Percentage Distribution of Land by Use Category,
1970 and 2000 127
IV-H Regional Subarea Population Allocation by Service
Area (1977) 133
IV-I Population Growth Forecasts for Facility Planning Areas 138
IV-J Agricultural Land Use in the Five-County Region:
1960, 1970 145
IV-K Projected Year 2000 Agricultural Land in Five-County
Region 147
IV-L Anticipated Conversion of Prime Agricultural Land as
a Consequence of Urban Expansion to Year 2000 148
IV-M Denver Emissions Inventory for 1985 Air Quality Pro-
jections 155
IV-N Denver Emissions Inventory for 2000 Air Quality Pro-
jections 155
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Table Page No.
IV-0 Denver Mr Quality Projections 163
IV—P Status of Existing/Proposed Wastewater Collection
and Treatment Facilities Under the Local, Regional
and No-Action Alternatives 171-173
IV-Q Current and Recommended Stream Classifications by
Stream Reach 175
IV-R Current and Proposed Water Quality Standards to
Meet 1983 Goals 176
IV-S Anticipated Point and Non-Point Source Loadings in
the Year 1985, by Stream Basin 184-185
IV-T Control Requirements for Point and Non-Point Sources 188
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ACKNOWLEDGEMENTS
EPA Region VIII wishes to gratefully acknowledge the assistance
of Engineering-Science, Inc., in preparing this EIS, and Systems
Applications, Inc., for the analysis of Denver's future air quality.
The assistance of Engineering-Science's subcontractors, Gruen Gruen &
Associates, and Leonard Rice Consulting Water Engineers, is also
gratefully acknowledged.
XI
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X. Introduction
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SECTION I
INTRODUCTION
The Denver Metropolitan Area includes nearly 60 percent of the
population of the State of Colorado. It is located geographically
near the middle of the state where the eastern plains of Colorado
meet the Rocky Mountain foothills (see Figure I-A and Map A)*.
BACKGROUND
In 1969 a law of far-reaching significance for federal agencies
was passed by Congress. This law, called the National Environmental
Policy Act (and referred to as HEPA), requires a federal agency to
take account of and make known the environmental impacts of any major
action it is about to undertake. The vehicle used to do these things
is a document called an environmental impact statement (EIS).
The Environmental Protection Agency (EPA) is responsible for
seeing to it that many of the environmental laws passed by Congress
are put into effect; however, it is also one among many federal
agencies which must comply with NEPA in its own actions.
In 1972, EPA became responsible for implementing the Water
Pollution Control Act Amendments (PL 92-500). This law, among
other things, established water quality goals for U.S. waters:
1. "... wherever attainable, an interim goal
of water quality which provides for the
protection and propagation of fish, shell-
fish, and wildlife and provides for recre-
ation in and on the water be achieved by
July 1, 1983" and
2. "... that the discharge of pollutants into
navigable waters be eliminated by 1985".
*A11 maps referred to can be found in the Map Folder supplied with
this report.
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RELATION OF DENVER REGION
TO THE STATE OF COLORADO
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The law set up a comprehensive planning process involving EPA
and individual states to define the necessary stream water quality
standards and treatment levels to achieve these goals, and determine
how they would be attained. The law created the National Pollutant
Discharge Elimination System (NPDES) of permits to regulate and con-
trol discharges to the nation's streams. Congress also set aside
$18 billion in grant funds to pay 75 percent of the eligible costs
of publicly owned waste treatment works to assist municipalities in
achieving the necessary wastewater treatment plant effluent quality
to meet the water quality goals.
New amendments were enacted in 1977 changing the name of the
law to the "Clean Water Act". More importantly, the 1977 amendments
authorized the expenditure of an additional $19.5 billion in grant
funds for publicly owned wastewater treatment works. The Water Act's
deadline for municipal compliance with secondary treatment standards
was modified to authorize EPA extensions, on a case by case basis, to
July 1, 1982. If a municipal system will use innovative treatment
methods, extensions could be granted to July 1, 1983. The amendments
also delete funding for separate stormwater runoff sewer systems.
In addition to encouraging innovative treatment technologies, the
Act also emphasizes energy efficiency and consideration of system
compatibility with recreation needs and planning.
The Environmental Protection Agency is charged with overseeing
most of these and other provisions of the Act. Two areas of EPA
responsibility under the Act are brought together in this EIS effort.
Section 201 of the Act provides for a three-step, facilities
planning, design and construction approach to secure federal funds
for municipal wastewater treatment works. Step I involves the
development of a "facilities plan" that evaluates treatment needs,
systems capabilities, alternatives and develops a preliminary de-
sign for the project. EPA is charged with review and approval of
such Step I plans before design (Step II) and construction (Step III)
funds can be obtained. An integral part of the EPA's review involves
an assessment of environmental impact that the facility plan defines.
Section 208 of the Act is also administered by EPA. This is a
special planning function that analyzes complicated water pollution
problems on a regional or statewide scale. Where the governor of a
state identifies a major water pollution problem, a "208 agency" is
designated to develop a comprehensive Clean Water Plan to deal with
the problem. 208 planning involves: defining point and non-point
sources; projecting wasteloads; establishing treatment needs and
priorities; evaluating stream classifications and determining the
necessary controls and types of management to achieve the goals of
the Act. Such a plan in effect will set many of the criteria to be
met by individual 201 facilities plans for the study area.
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ACTIONS UNDER CONSIDERATION IN THIS EIS
The 201 Facility Plans
Various local agencies have prepared or are developing facility
plans to construct, improve and/or expand municipal wastewater col-
lection and treatment systems for the following planning areas (see
Map J):
1. South Adams County
2. Englewood and Littleton
3. South Lakewood
4. Cherry Creek and Goldsmith Gulch
5. Lower South Platte
6. Clear Creek
7. Sand Creek
8. Westminster and Broomfield
9. Northglenn (originally part of Lower South Platte planning
area)
10. Metropolitan Denver Sewage Disposal District No. 1
Each of these wastewater treatment facility plans must identify
the most cost-effective and environmentally sound alternative after
considering the local and regional implications of the project.
Some of these facility plans are complete and the recommended
alternatives are known. Other plans have been started, and still
others have not yet been initiated. Table I-A briefly summarizes
the status of the ten facility plans, and in the case of those
not yet begun or completed, Table I-A presents the probable plan
recommendation based on other sources of information. Detailed
information on each facility plan can be found in Volume 2, Section
III of this EIS.
Considered together, these projects raise significant regional
issues which must be addressed, such as population levels and dis-
tribution, air quality, conversion of agricultural land, protection
of environmentally sensitive areas, and point and non-point water
pollution controls. There has been and continues to be a great deal
of discussion between citizen groups and various levels of government
concerning the best way to address these regional issues. The con-
cept of a regional environmental study has been developed as one
possible way to evaluate these issues. EPA's policy in the past has
been to evaluate wastewater treatment facility plans in the Denver
Metropolitan Area on a project-by-project basis and to prepare the
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Table I-A. SUMMARY AND STATUS OF DENVER
REGION 201 FACILITY PLANS (1978)
Service Area
Expected Plan
Status of 201 Plan
South Adams
Maintain existing plant, Phase I expansion
from 2.5 to 4.25 mgd in 1978, Phase II
expansion to 6 mgd by 1986. Nitrification
by land application via discharge to 0'Brian
Canal and Burlington Ditch.
Complete, Phase I
under construction.
Phase II not acted
on by EPA.
Englewood/Littleton
Addition of ammonia and chlorine removal and
expansion to 30 mgd capacity by 1982. Further
expansion of joint plant to total capacity
with AWT to 40 mgd in 1993.
In preparation
South Lakewood
Enlarge existing plant, improve sludge hand-
ling facilities; capacity expanded from 2 mgd
to 3 mgd.
Complete, under EPA
review.
Cherry Creek/
Goldsmith Gulch
System of interceptors to expected 1985 flow
from upper Cherry Creek to Northside/MDSDD#l
complex. Provision for AWT satellite plant
in 1985.
Complete, under EPA
review.
Lower South Platte
New plant for flows from Brighton, 1st, 2nd
and 3rd creeks. Lower Thornton flows to West-
minster's Big Dry Creek plant for agricultural
exchange. Remainder of the area flows to
MDSDD#1 and South Adams County Water and Sani-
tary District.
Complete, under EPA
review.
Clear Creek
Parallel Clear Creek interceptor to transport
all basin flow to MDSDD#1 for treatment.
Complete, under EPA
review.
Sand Creek
Expand existing Aurora plant from 1.5 to 2 mgd
with reuse. Remainder of area flows to
MDSDD#1.
Complete, under EPA
review.
Bloomfield/
Westminster
Expansion of existing Big Dry Creek Plant to
9 mgd by 1985 with land application/agricul-
ture reuse.
A plan was completed in
1975 but rejected. Work
on new plan suspended.
Northglenn
All wastewater flows plus some stored surface
runoff to new Bull Canal Reservoir for pre-
treatment and storage of use in agricultural
exchange.
In preparation
MDSDD#1
Addition of ammonia removal for total plant
capacity of 190 mgd by 1983. Option for
reuse.
In preparation
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individual project environmental impact statements, if necessary.
The analysis of regional issues and secondary impact questions has
been difficult using a project-by-project approach. EPA acknow-
ledges this difficulty in the final EIS for the present plant
expansion by the Metropolitan Denver Sewage Disposal District No. 1
plant (MDSDD #1) (February 1974), in the final EIS for the Engle-
wood-Littleton sewage treatment plant (August 1974), and in the
negative declaration for the South Platte II interceptor sewer
(September 1975) where EPA indicated the intention to prepare a
regional environmental impact statement addressing these broader
issues.
As indicated above, there are other wastewater treatment pro-
jects that are in various stages of construction, some of which have
been the subjects of individual EIS's. Although not directly
affected by the EIS effort, it is EPA's intention to apply where
possible, any reasonable mitigating measures to any of those projects
beginning or still under construction. The on-going Denver area
projects not directly covered in this EIS are as follows:
1. City of Boulder's wastewater treatment plant improve-
ment program. Final EIS in preparation;
2. City and Count of Denver's interceptors in the Harvard/
Jewell area which are now under construction;
3. City and County of Denver's parallel Delgany interceptor,
and storm and sanitary sewer separation projects to be
constructed;
4. City of Westminster's Big Dry Creek plant expansion
now being constructed;
5. MDSDD #1 central plant expansion now in operation;
6. MDSDD #1 sludge disposal plan now being finalized for
funding, final EIS in preparation;
7. New regional plant and interceptors for Littleton and
Englewood; and
8. MDSDD #l's Platte River II interceptor now under
construction.
The Clean Water Program (208 Plan)
The Denver Regional Council of Governments (DRCOG) was desig-
nated the 208 planning agency for the Denver area to address the
complicated water pollution problems in this highly urbanized area.
The DRCOG 208 study, named the Clean Water Program, has evalua-
ted the national goals and their attainability in the Denver area with
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respect to financial, environmental, social and economic impacts.
It has also attempted to determine technical solutions to regional
environmental problems and recommended a management system for
implementing the Clean Water Flan.
As an integral part of the work effort of the Clean Water Plan,
population allocations and a land-use plan have been developed by
DRCOG, as well as a set of recommended treatment plant funding pri-
orities and levels of quality for plant effluents. An assessment
of the non-point source problem as it affects meeting the national
goals is also included in the plan.
The draft of the Clean Water Plan was released in April 1977
by DRCOG. The final recommended plan was approved and adopted by
the Denver Regional Council of Governments on July 24, 1977. The
Governor of the State of Colorado approved the plan with conditions
and transmitted the plan to the Regional Administrator, EPA Region
VIII for review and approval on January 11, 1978. EPA has until
May 11, 1978 to act on the Clean Water Plan. This EIS explains
EPA's proposed major actions on the plan. However, final action
will not take-place until after a 30 day review of the final EIS.
THE NEED FOR THIS EIS
As mentioned briefly, EPA is concerned about the piecemeal
manner in which its NEPA reviews of earlier projects have proceeded.
Regional or secondary impacts simply could not be adequately dis-
cussed at the project level. The preparation of this regional
environmental impact statement has allowed EPA, local, state and
regional governments and the public the opportunity to address these
significant issues.
Air Quality and Water Quality Planning Consistency
The regulatory aspects of EPA's activities under the Clean Air
Act relating to transportation control plans to achieve air quality
standards may not require a NEPA evaluation. However, EPA has come
to realize that activities in different media programs need to be
consistent, such as in this case where there must be a consistancy
between air and water pollution controls.
The Denver Air Quality Control Region (AQCR) is currently in
violation of ambient air quality standards for carbon monoxide,
particulates and ozone. A transportation control plan (TCP) has been
adopted by the Colorado Air Pollution Division, Department of Health
and EPA. Implementation of the various control strategies to date
has been very limited and air quality standards will continue to be
violated over the next several years even with controls.
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The Clean Air Act Amendments of 1977 will require changes to the
State Implementation Plan (SIP). These changes must be submitted to
EPA by January 1, 1979. EPA must approve or disapprove the changes
by July 1, 1979, and develop alternative plans for those changes it
disapproves. An important part of the SIP, the Transportation Con-
trol Plan (TCP), is now being revised. Under the 1977 amendments, it
must include all "reasonable" carbon monoxide and oxidant control
measures to be implemented by 1982. If air quality standards would
still not be met, another plan including all "necessary" measures to
attain standards by 1987 must be submitted by 1982. The new SIP
must include the effects of future growth when demonstrating the
attainment and maintenance of air quality standards. If mandated
SIP revisions are not submitted or are not complied with, federal
sanctions can result, thus limiting federal assistance and the grant-
ing of permits.
In regard to facility planning, the environmental issue of note
becomes this: to what extent does the population growth planned for
in sewage treatment plant and interceptor capacity relate to
further VMT growth in the Denver Metropolitan Area? Is the planning
for treatment plant capacity consistent with air quality maintenance
plans? Among available control strategies, the Clean Air Act pro-
vides for land-use controls, if necessary, to achieve and maintain
air quality standards. Thus, it is necessary to look at projected
population growth in terms of: a) total growth; b) the distribution
of this growth and the resulting transportation needs and patterns;
and c) how these future development and transportation patterns
would impact air quality. Such projections for growth, size and
distribution are, of course, an essential element of facilities
planning for sewers and wastewater treatment plants. EPA feels that
its approach in these two areas of environmental protection must be
consistent.
Impacts of Growth on Achieving Water Quality Standards
Planning for future growth means that more sewage and other
forms of water pollution must be accounted for and controlled. In
particular, non-point sources (those diffuse pollution sources not
developed or released at a definable single point on a stream or
lake — e.g., stormwater runoff, agricultural return flows, lawn
watering and car washing) must be accounted for in calculating the
total impact on a stream quality.
In order to properly plan for wastewater treatment facilities,
one must know:
• what degree of treatment is necessary at the plant;
• what are the other pollution sources on that stream reach
which are also contributing to the problem;
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• how can they all be controlled; and
• what is the likelihood and cost of attaining stream
standards required under the Act?
The Clean Water Plan, developed by DRCOG and conditionally
approved by the State, was developed at the same time as most of
the facility plans. However, decisions on facility plans, such as
a degree of treatment, type of treatment, location and population
impacts, must have the benefit of the overall Clean Water Program.
This EIS is an attempt to bring together these plans for EPA's
evaluation of the total water quality picture for the Denver Metro-
politan Area.
Relationships of Wastewater Treatment Plant Organization
Sixteen wastewater treatment projects are undergoing planning
or construction at this point in time in the contiguous Denver Metro-
politan Area. Virtually all of the separate facilities planning are
inter-related in some fashion. Decisions on the upstream plants
(South Lakewood, Cherry Creek, Clear Creek and Sand Creek) invari-
ably involve maintenance or development of an upstream facility
versus connection with a downstream facility, such as Denver North-
side or MDSDD #1. In some cases (Westminster and Lower South Platte)
potential decisions may involve a redistribution of flows between
the separate districts. It is thus important to consider these
individual options together and at a common point in time. EPA
believes that it is possible to develop an overall policy, concern-
ing satellite versus centralized treatment, which is consistent
with other needs of the State, such as water rights, water supply,
reuse and instream benefits.
Prime Agricultural Land Losses
This is a special land-use problem that is not only a regional
problem, but a national one. The Council on Environmental Quality,
rightly concerned with the problem, commissioned a special study to
analyze the impacts of urban growth on the nation's farmlands. The
study demonstrated that prime agricultural land is rapidly being
converted to urban uses. In a qualitative way, EPA has been aware
of similar problems in the Denver Metropolitan Area. Virtually all
new housing development in the metropolitan area uses some form of
agricultural land. The land varies from rangelands to dryland farms
to irrigated farmlands.
The relationships between this loss of agricultural lands and
facility planning is as follows: the projections used in facilities
planning for new population increases and their locations will have
a strong effect on the amount of farmland lost.
-------
This is one more area in which EPA and other agencies have
limited information with which to make a decision. Facility plans
to date have not catalogued how much of the various categories of
farmland will be converted by the future development. Therefore,
EPA cannot estimate the magnitude of the problem except in general
terms. This EIS will investigate on a regional level, how much
area of the various categories of farmland will be lost to future
development, how critical in terms of the overall state and
national farming economy the loss of these lands are, and whether any
specialty crops are involved that cannot or are not likely to be
grown elsewhere. Only with this information can a set of reasonable
strategies be offered for mitigating such land losses in facility
planning.
Sensitive Environmental Areas
In planning for future growth, planners need to be aware of
the potential impact of new population on environmentally sensitive
areas unsuitable for development. Such a list of features would
include:
unusual geological features
archaeological features
historical features
floodplains
marshland/wetlands
wildlife habitat areas
natural vegetation areas
steep slopes/unstable soils
The first problem is to recognize the commonality of these
items from one service area to another. Many of the items in a
given service area represent only a fraction of the total resources.
There is a need to look cumulatively at the entire Denver region
to assess how vulnerable these resources are. The EIS, in con-
junction with the Clean Water Program information, developed an
environmental sensitivity inventory that gives EPA an overall
picture of the situation.
Socio-economic Impacts
This is an area that has received very little attention in
past EIS efforts on wastewater facilities. The EIS attempts to
identify any sociological or economic impacts, both beneficial
and adverse, that could occur because of the overall federal
investment pattern of construction grants in the Denver Metropolitan
Area. The EIS addresses the conflicts between suburban districts
and central facilities, and the potential influence that this
federal funding program may have on urban land use form.
10
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Land Treatment and Reuse in the Denver Metropolitan Area
EPA requires and encourages the consideration of land applica-
tion and reuse of wastewater as potentially beneficial ways of achiev-
ing water quality standards and attaining other valuable environmental
objectives, such as farmland protection and use of nutrients. Until
now, land treatment has received limited evaluation in facility plans.
Land treatment involves the discharge of treatment plant effluent
onto the land surface where percolation through and interaction with
the soil removes pollutants. The first comprehensive water quality
management study (called the 303-e Plan) for the Denver Metropolitan
Area eliminated land treatment because of high costs. The Clean Water
Program reevaluated the potential for land treatment and reuse in
the study area, and is encouraging land treatment and reuse systems.
Because of the scarcity of water in Colorado for municipal,
industrial and agricultural uses, interest has grown in many Colorado
communities in instituting some form of water reuse. Particularly
in the fast growing areas, municipalities may be able to increase
their domestic water supplies through an arrangement of "first use"
by municipalities and subsequent use of wastewater effluent by agri-
cultural concerns. Colorado water rights laws dictate to a large
extent what kinds of "reuse" schemes are available to communities.
The effects on water quality may be beneficial, but it is not
necessarily true in every case. Stream flows can be depleted as
well as agumented. It will depend to a large extent on the type of
reuse system involved. The issues involving plant organization are
in some ways related to this issue. In this EIS, then, EPA will
define the types of potential reuse systems, the specific situation
as it occurs in Colorado, and impacts likely to occur for different
systems. Eventually, decisions on the most beneficial types of
reuse from a water quality standpoint may be influential in de-
termining the satellite-regional plant arrangements.
THE OBJECTIVES OF THIS EIS
As an overall perspective, the following general objectives
were identified for this EIS based on the preceeding discussions:
• To define and assess the environmental, impacts of
the ten Denver Metropolitan Area wastewater facility
plans and the Clean Water Plan.
• To define EPA policy and decision options for assurance
of consistency between EPA's air and water programs and
goals of NEPA, including the options for mitigation of
adverse secondary impacts; and
11
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• To stimulate public discussion about "desirable" environ-
mental goals for the Denver Metropolitan Area, with emphasis
on the relationship of EPA's construction grants program to
other federal, state, regional and local governmental pro-
grams.
The latter point deserves some further elaboration. EPA has
extensively coordinated the preparation of this EIS with various
state, local and federal agencies. For example, this EIS makes
extensive use of information, data and analysis developed by the
Clean Water Program planning effort. In addition, EPA has followed
the U.S. Department of Housing and Urban Development's preparation
of an EIS on its Federal Housing Administration program for Denver,
and the U.S. Bureau of Land Management's revision to its draft EIS
on the proposed Foothills Water Treatment Plant. In terms of growth
related environmental issues, this EIS emphasis areas of EPA respon-
sibility, such as air and water quality, and it intended to supple-
ment work by other agencies. Thus, it is hoped that this EIS will
help provide a focus for confronting growth related environmental
issues of much concern to the State of Colorado and the citizens of
the Denver region.
THE EIS PROCESS
The Draft EIS for Wastewater Facilities and the Clean Water
Program was released for public review on June 3, 1977. Formal
public hearings were held on July 18 and July 19, 1977. The public
review period ended August 15, 1977.
The Draft EIS presented a number of environmental issues and
impacts within the context of three overall alternative strategies
that EPA was considering for adoption. The EIS stated that one of
the basic EPA objectives was to stimulate the fullest possible public
discussion and review so that one of the strategies could be evolved
into a reasonable and prudent course of action for EPA to follow.
To that end, an extensive public participation program was organized.
A twenty minute slide presentation with a taped narration was used
extensively for presentations before twenty federal, state, regional
and local agencies, and special interest groups. Brochures and ques-
tionnaires were also used at these .presentations. Newspaper supple-
ments were distributed by the region's two major daily newspapers
explaining the issues and providing a means for further citizen comment.
A detailed analysis of citizen attitudes, based on the results of the
public participation program, is presented in Reference 130. Some
highlights from the findings of that analysis are:
12
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Air quality is perceived as the Denver region's
most serious environmental problem.
Air and water pollution, the loss of agricultural
land and waste of energy resources are generally
attributed to regional growth and to a regional
land use pattern characterized as "sprawl".
Significant institutional changes are thought
necessary to correct these problems. Consoli-
dation of local service districts, improvements
in land use planning (strenghtened zoning, state
assumption of responsibility for agricultural
land preservation and more caution iri extension
of public services), and greater regionalization
of certain functions (including establishment of
regional service districts and regional tax base
sharing) are widely seen as promising approaches.
Federal funding from the Environmental Protection
Agency is greatly needed for water quality improve-
ment; however, there is disagreement on whether
federal funds should be used to pay for water-
water system expansions to accommodate growth.
Public ignorance and apathy about environmental
problems is an obstacle to the solution of those
problems. The education of the public and public
involvement in environmental decisions are seen
as critical to the success of environmental im-
provement programs.
The environmental problem that the Denver region
faces are seen as inter-related, and solutions to
those problems will require a degree of coordination
among jurisdictions and levels of government beyond
that now existing in the region.
13
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14
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XI. The Existing
Environment
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SECTION II
THE EXISTING ENVIRONMENT
SITUATION AND DESCRIPTION OF THE DENVER REGION
The study area for this EIS is shown on Map A*. The semi-arid
Denver region is located at the approximately 1,600 metres (5,280
feet) high western edge of the high plains province of Colorado. This
portion of the Great Plains slopes upward 585 metres (1,930 feet) for
almost 300 kilometres (186 miles), from the 1,020 metres (3,350 feet)
high eastern state boundary to the abruptly rising foothills at the
base of the Rocky Mountains. Relief is characterized by rolling
prairie, with some hills and ridges intersected by level flood plains
along the generally northeast flowing watercourses of the Platte River
drainage. The South Platte River and Cherry Creek flow through the
heart of Denver.
Approximately 1.5 million people (1975) live in the region.
Regional growth reached a peak rate of 5.5 percent per year in 1972-
73 and has since declined to a rate close to the 1960 to 1970 average
of 2.6 percent. Population distribution patterns are changing as the
central city continues to lose population to the suburbs (see Map B).
Residential areas and their service facilities surround the commerce
areas, with densities decreasing from the urban core to the suburban/
rural edge of the region.
Denver is the state capital and is the major federal administra-
tive center for the Rocky Mountain States. Government employment is
considerable, with thousands of people employed by the state, the
Rocky Mountain Arsenal and other government facilities. Transportation
industries, such as aviation, trucking and railroads, are of major
importance to the region's economy due to Denver's crossroads situation
for many transportation routes. Commercial and industrial enterprises
are concentrated in the urbanized areas, with many of them located in
the Denver downtown area and along major streams. Agricultural activity
is a significant part of the region's economy.
* All maps referred to can be found in the Map Folder supplied with
this report.
15
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ENVIRONMENTAL SENSITIVITIES
EPA* s purpose for this EIS is to examine the effects and issues
of growth in the Denver area, so that it might determine whether or
not it should contribute to the accommodation of this growth through
its wastewater funding programs. Also, EPA must consider its admini-
strative responsibilities in terms of the regional environment, and
promote programs and strategies for dealing with physical environ-
mental problems, such as air and water quality. To examine these
problems, a mass of data and information on the Denver area has been
edited to emphasize the major characteristics of the region that may
affect or be affected by the proposed projects and the growth they
will help accommodate.
Regional Climate
The Denver region, lying at the western edge of the Great Plains
near the Rocky Mountain Foothills, is in an area of transition
between the climate of the plains and that of the mountains. The
region is situated within an area having a high-altitude, continen-
tal climate. Locally, the region's climate is that of semi-arid
steppe.
Temperatures are generally moderate. The growing season is
approximately five to six months long. Precipitation is relatively
light, with a large portion falling during the April to September
growing season. Much of the summer precipitation occurs as a result
of thunderstorm activity, and heavy thunderstorms in the eastern
foothills and plains area occasionally cause flash floods. Snow-
fall is generally not heavy. Extensive flooding caused by snowmelt
in the nearby mountains occurs only at times when there has been
either a heavy accumulation of snow or sudden high altitude warming.
The generally low- relative humidity is a major factor in the region's
somewhat high annual evapotranspiration rate, which is twice the
average annual precipitation.
Denver experiences infrequent and often destructive "Chinook"
winds from the northwest during fall through spring. Chinooks,
with velocities of up to 54 metres per second (120 miles per hour),
blowing down from high-elevations are warmed by compression during
their rapid descent through the shallow layer of cool air covering
the plains. The sudden rises in temperature resulting from these
gusty winds exert a moderating influence on winter temperatures.
Chinooks are experienced in a 24 to 32 kilometres (15 to 20 mile)
wide zone along the foothills. Although little information has
been published which identifies areas of greatest wind velocities,
it is recognized that winds during Chinook events are 1.3 to 2.2 metres
per second (3 to 5 miles per hour) higher along the bottoms of the
16
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stream valleys than in the surrounding areas. Therefore, wind dam-
ages are also generally greater in the stream valleys. Ridges which
experience higher than average velocities during Chinook events are
shown on Map C. Construction activities are generally restricted
during Chinook events, and wastewater treatment processes involving
spraying are generally curtailed (Reference 126, 413).
Air Quality in the Denver Region
The following discussion will first present aspects of the
climate in the Denver region which affect air pollution levels.
Next, short discussions of health effects and effects on agricul-
tural crops are presented. The last section will discuss current
air quality and the sources of air pollutants.
Climatic Conditions Which Affect Air Quality —
Air quality in the Denver area is influenced primarily by the
topography of the South Platte River Valley. The topography's
associated drainage winds move down the valley to the northeast dur-
ing the evening and then reverse during the mid-morning with upslope
motion usually occurring during the remainder of the daylight hours.
As the air flows across the city, pollutants generated at the ground
surface are transported back and forth over the area increasing and
decreasing the pollutant concentration. Fortunately, Denver's loca-
tion on the east side of the Rockies means that pollutant contain-
ment by prevailing westerly winds does not occur, as it does in Los
Angeles.
Solar radiation plays an important role in determing air pol-
lution potential. The ultraviolet component of sunlight is the
driving force that initiates the chemical reactions necessary to
produce photochemical smog. Denver, at its "mile high" altitude,
receives a higher amount of ultraviolet radiation because the thin-
ner atmosphere does not filter out as much ultraviolet radiation.
Normally, the temperature of the air decreases with height
above ground surface. When the opposite occurs, or temperature
increases with height, upward movement of cold surface air is re-
strained by the "lid" of warmer air aloft. This condition is called
an inversion. The altitude or depth of this inversion, in tens,
hundreds or thousands of metres, determines the volume of air in
which air pollutants are mixed and how concentrated they become.
Denver is unusual because no city of comparable size in the nation
has a lower morning inversion or a higher afternoon inversion. This
means that air pollutants emitted in Denver's morning rush hour are
trapped in a very thin layer of air. However, by afternoon, the
volume of air has usually increased drastically as the inversion
17
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rises, and pollutants are thereby greatly diluted. Most severe pol-
lution episodes occur when the inversion does not rise, and pollutants
are trapped for a day or more in a relatively thin layer of air.
These situations most frequently occur in winter.
Effects of Air Pollutants on Health —
The Clean Air Act Amendments of 1970 mandated that minimum
standards of air quality be set to protect the public health and
welfare of the population at large. The law requires that primary
standards be set to protect the public health with an adequate
margin of safety, and that secondary standards be set to protect the
public welfare. Effects on public welfare are concerned mostly
with plant and property damage.
The EPA, after a great deal of research, set standards for six
pollutants. These are carbon monoxide (CO), photochemical oxidants
(usually characterized as ozone), sulfur oxides (SOX), nitrogen di-
oxide (N02), total suspended particulates (TSP), and hydrocarbons.
Standards for all but sulfur oxides are shown in Table II-A, and the
health effects of these pollutants are discussed below. Sulfur
oxides are not discussed in this EIS, as they are not currently a
problem in the Denver region.
Carbon Monoxide — Carbon monoxide (CO) is a colorless, odor-
less, tasteless gas commonly found in urban atmospheres in concen-
trations that can be harmful to people. A by-product of combustion,
the greatest single source of this pollutant is the automobile.
Carbon monoxide is inhaled through the lungs and enters the
blood stream by combining with hemoglobin, the substance that
normally carries oxygen to the cells. CO combines with hemoglobin
much more readily than oxygen does. The result is that the amount
of oxygen getting to the tissues is drastically reduced in the
presence of CO, and this can have a profound effect on health. CO
also impairs heart function by weakening the contractions of the
heart which supplies blood to the various parts of the body. The
effect of this on a healthy person is to reduce significantly his
ability to perform exercise, but in a patient with hearth disease,
who is unable to compensate for the decrease in oxygen, it can be
a life-threatening situation. A person who has a heart attack in
the presence of heavy carbon monoxide air pollution is more likely
to die than if the attack had occurred in clean air. Carbon mon-
oxide is also harmful to persons who have lung disease, anemia or
cerebral-vascular disease.
Carbon monoxide can also affect mental function at relatively
low concentrations of 30 parts per million (ppm). Visual perception
and alertness can be affected.
18
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TABLE II-A. NATIONAL AMBIENT AIR QUALITY STANDARDS
a
Pollutant
Particulate matter
Carbon monoxide
Nitrogen dioxide
Photochemical oxi-
dants
Hydrocarbons
(nonme thane)
Averaging Primary
Time Standards
Annual (geo-
metric mean)
24 hourb» c
8 hour
1 hour
Annual (Arith-
metic mean)
1 hour
3 hour
(6 to 9 a.m.)
75 yg/m3
260 ug/m
10 mg/m
(9 ppm)
40 mg/m
(35 ppm)
100 yg/m
(0.05 ppm)
160 yg/m
(0.08 ppm)
3
160 yg/m
(0.24 ppm)
Secondary
Standards
60 yg/m
150 yg/m3
10 mg/m
(9 ppm)
40 mg/m
(35 ppm)
100 yg/m3
(0.05 ppm)
160 yg/m3
(0.08 ppm)
160 yg/m3
(0.24 ppm)
•5
The air quality standards and a description of the reference
methods were published on April 30, 1971, in 42 C.F.R. 410,
recodified to 40 C.F.R. 50 on July 1, 1975.
Not to be exceeded more than once per year.
CState standards for particulate matter;
o
24 hour, 150'yg/m ; Annual, arithmetic mean, 45 yg/m.
19
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Ozone — Photochemical oxidants are responsible for a number
of health effects in humans. They can affect the lungs and eyes.
They may result in eye irritation with the familiar symptoms of
tears and inflammation. At certain concentrations they have been
shown to impair the performance of athletes, and to affect persons
with asthma.
Ozone, the main constituent of photochemical smog, is a severe
irritant to all mucous membranes, and its main health effects are
on the respiratory system. It is virtually intolerable at levels
of 1 part per million. At considerably lower concentrations (0.1 to
0.2 ppm), which often occur in the air of many American cities,
ozone in conjunction with other photochemical oxidants, causes a
variety of health effects which are aggravated by exercise. Ozone
also has an increased effect on respiratory functions in the presence
of sulfur dioxide.
Nitrogen Dioxide — Oxides of nitrogen usually originate in
high-temperature combustion processes, such as in auto engines and
electrical power generating plants.
Although measurement of this pollutant in the atmosphere is
difficult, experience has shown that in various forms, oxides of
nitrogen can affect humans as well as materials and vegetation.
Based on occupational exposures to nitrogen dioxide by firemen,
welders, silo fillers, miners, chemists, and other industrial work-
ers, it is known that a high concentration of this pollutant can be
fatal to humans. At lower levels of 25 to 100 parts per million,
it can cause acute bronchitis and pneumonia. The group of pollu-
tants known as nitrogen oxides also can affect lung tissue and lower
the resistance of laboratory test animals to influenza. Scientists
suspect the same effect may occur in humans. In one study of school
children living near an industrial plant producing nitrogen dioxide,
an increase in respiratory disease was-noted.
Oxides of nitrogen (NOX) also can react with hydrocarbons in
the presence of sunlight to form photochemical oxidants, which, as
noted elsewhere, can affect human lungs and eyes, as well as cause
respiratory irritation.
Total Suspended Particulates — Total suspended particulates
(TSP) is a term for the measurement of all particles in the air,
including soot, mists, and sprays. TSP includes a wide range of
non-toxic materials such as dust and dirt, and many other materials
that are known or suspected to be toxic, such as beryllium, lead,
asbestos, certain hydrocarbons which may be carcinogenic, suspended
sulfates and nitrates, and possible radioactive elements.
20
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The amount of toxic materials in the air will vary geographi-
cally, depending on the man-made and natural sources in a particular
area. To date, few studies have been conducted on the health effects
of individual particles because of the wide range of differences in
the makeup of particulate concentrations. Particulate matter is
studied for the most part as a single contaminant, and most studies
relate particulate concentrations to death, respiratory illness, and
breathing problems in urban industrial areas where energy supplied
by fossil fuel consumption is a major concern.
The effects of particulate air pollution on health are related
to injury of respiratory system surfaces, such as the linings of
the lungs and throat. Such injury may be temporary or permanent;
and it may be confined to the surface. However, by weakening resist-
ance to infection, such pollutants may affect the entire body ad-
versely. Chemicals carried into the lungs by particulates, for
example, may cause cancer to develop on the lung lining, which then
may spread throughout the body and prove fatal. Inhaled lead parti-
culates may cause lead poisoning - manifested by nervous and blood
symptoms - while causing very little damage to the lung itself.
In studies of air pollution in London and New York City, a rise
in the number of deaths has been recorded when both smoke and sulfur
oxides levels are high. Studies in Buffalo and Nashville also show-
ed increased death rates, particularly among older persons, where
combined pollution from particulates and sulfur oxides were recorded.
Eye irritation from dust particles also can be a problem in many
areas.
Effects of Air Pollutants on Crops —
The effects of air pollutants on crops have been subject to
investigation for nearly thirty years. However, the state of know-
ledge is not as complete as it is for effects on people. Pollutants
can damage crops by stunting growth and by causing physical changes
of a type similar to those caused by pests and plant diseases. The
stunting of growth reduces the yield per unit area and the visible
damage reduces the marketability, particularly for crops destined
for supermarket shelves.
The air pollutants of national interest are oxidants, sulfur
^dioxide, and fluorine compounds. The last two pollutants are
characteristic of certain types of point sources and are not of con-
cern at this time in the Denver region. Oxidants, primarily ozone,
are the pollutants of primary concern in the Denver region. Crop
damage caused by ozone is not a straightforward function of ozone
concentration. The degree and type of damage depends on the crop as
well as climate. Different varieties of crops, e.g. different hy-
brids of corn, have varying sensitivities to ozone. Of two vari-
eties of corn exposed 50 percent of the time to oxidant concentra-
tions of 8 parts per hundred million (pphm) or more during daylight
21
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hours, one was found to have little significant damage, while the
other variety had significant reductions in the number and size of
ears produced (Reference 933). The crops most sensitive to oxidants
are alfalfa, barley, beans, clover, hay, oats, potatoes, rye, soy-
beans, sugarbeets, all types of citrus, and leafy vegetables. As
many of these crops are grown in the Denver region, air pollutant
effects on agricultural productivity are of potential significance.
Existing Air Quality —
Since 1974, the Colorado Department of Health has had six con-
tinuous monitoring stations in operation in the Denver area. The
locations of these monitoring stations are shown in Figure II-A.
Carbon Monoxide — Figure II-B shows the number of days that
CO standards were violated in 1974 at these monitoring stations.
The CAMP station is in the heart of Denver, whereas the Welby
Station is in a very rural location.
The winter season is the worst for CO because the inversion
heights are lower and the CO is trapped in a more concentrated form.
Figure II-C shows the annual trend in 8 hour CO violations for 1974.
During an average day, CO concentrations tend to peak during
the traffic rush hours in the morning and afternoon. Figure II-D
demonstrates a typical "CO day" at the downtown CAMP station.
Since CO is directly emitted from car exhausts (the principal source
of CO in the Denver region is the automobile) concentrations are
highest along major streets and busy intersections. These areas of
high CO concentrations are often referred to as "hot spots".
Ozone — Ozone is not directly emitted by pollutant sources,
but is formed from hydrocarbon and NOX emissions by the action of
sunlight. Since time is required for the ozone to form, it occurs
in the highest concentrations downwind from the hydrocarbons sources,
as shown in Figure II-E.
About 80 percent of the hydrocarbon emissions in Denver come
from motor vehicles, and about 30 percent of the hydrocarbons come
from stationary sources like petroleum refineries, gas stations,
and dry cleaners.
Unlike CO, ozone, because of the way it is formed, tends to
record highest values in the suburbs. This occurs because during
days when wind speeds are low, the hydrocarbons and oxides of
nitrogen will have formed ozone about the time the pollutant cloud
has drifted over the suburbs and into rural areas. This trend is
shown in Figure II-F. In 1974 every monitoring station had a
significant number of days when the. ozone standard was exceeded.
22
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AIR QUALITY
MONITORING STATIONS
LEGEND
1. CAMP
2. JEWISH HOSP.
3. OVERLAND
4. CARIH
5. ARVADA
6. WELBY
-------
80
70
NUMBER OF DAYS IN 1974 STATIONS
RECORDED LEVELS EXCEEDING STANDARD
100
90
CARBON MONOXIDE
oo
>-
•a:
BO
50
40
30
20
10
CAMP
JEWISH
HOSP
OVER
LAND
V
URBAN
C4RIH
ARVADA
SUBURBAN
WELBY
RURAL
I
CD
-------
30
DAYS CARBON MONOXIDE
EXCEEDED STANDARD
20
CX3
•et
10
JFMAMJ JASOND
1974
-------
CARBON MONOXIDE LEVELS
COMPARED WITH TRAFFIC VOLUME
CAMP STATION
12 PM
NOON
12 PM
-------
OZONE FORMATION
A f-
V-X
•:
HII ;^£p?' v.
p%f^p|^mw^iilft§| -v^^. 'i
,-^- ;i
'
H
HYDROCARBON
EMISSIONS
-------
NUMBER OF DAYS IN 1974 STATIONS
RECORDED LEVELS EXCEEDING STANDARD
100
90
OZONE
80
70
60
50
40
30
20
CAMP
JEWISH
HOSP.
OVER-
LAND
CARIH
ARVADA
/
URBAN
SUBURBAN
WELBY
RURAL
-------
Ozone tends to be a problem in the summer because larger quanti-
ties of ultraviolet radiation from more intense sunlight causes more
ozone to be formed. Figure II-G shows this summertime peak in ozone.
This characteristic is in direct contrast with the annual distribu-
tion of CO concentrations shown in Figure II-C.
Particulates — Particulate matter is defined as any material,
except water, that exists in a finely divided form as a liquid or
solid. Since Denver lies in an arid section of Colorado, much of the
the particulate matter is generated from unpaved roads, construction
operations and natural soil erosion.
Particulate levels in the Denver area also exceed the standards
regularly. Fourteen of the twenty-two existing particulate monitors
in Denver currently record violation of the ambiant annual particu-
late standard. Depending on the location, these levels varied from
slightly over the standard to almost double the standard in 1974.
Nitrogen Dioxide — The Denver region has one nitrogen dioxide
monitoring station which is located in the central downtown area
where NO sources are the densest. Even with all the photochemical
activity frequently experienced during the summer months, no viola-
tion of the Federal annual average N02 concentration (0.05 ppm) was
reported in the Denver Metropolitan Area. Since N02 is formed from
NO emissions in the same photochemical process that forms ozone, ex-
ceedances of the N02 standard may exist in the suburbs of Denver
were presently no N0£ monitor exists.
Summary — Table II-B summarizes the exceedances of the CO and
ozone standards for 1974 and 1975. 1974 data was used for the above
discussion, however, 1975 data is similar. The frequency and magni-
tude of violations decreased somewhat in 1975, however, average wind
speed also decreased. The decreases in air pollution are not thought
to be caused by any reduction in emissions between 1974 and 1975.
Pollutant Emissions in Denver —
For the purposes of evaluating and modeling the present and
future air quality in the Denver Metropolitan Area, a number of
emissions inventories have been developed for present and estimated
future air pollutant emissions, including carbon monoxide, parti-
culates, oxides of nitrogen and hydrocarbons. These inventories
were compiled primarily by the staff members of the Air Pollution
Control Division of the Colorado Department of Health and by the
Colorado Division of Highways, A discussion of current emissions is
presented next. Future emissions, which are utilized to predict
1985 and 2000 air quality levels, will be discussed in the Probable
Environmental Impacts Chapter.
29
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30
DAYS OZONE
EXCEEDED STANDARD
20
oo
>-
•d
J F M A M
J J
MONTHS
0 N
-------
Table II-B. MAXIMUM POLLUTION CONCENTRATIONS MEASURED
DURING 1974 AND 1975 IN DENVER
One-hour C0a
Sample
CAMP
Nat.
Jewish
Arvada
CAR1H
Overland
Welby
Days with vio-
lations, 7.
1974 1975
2 2
2 2
0
0
0
0
2nd max
PPM
1974
61
49
28
26
25
22
1975
46.1
43.1
23.5
27.3
22.5
27.5
Max
PPM
1974
70
59
32
27
30
24
1975
47.2
51.4
26.9
27.9
28.8
30.8
EiRht-hour COD
Days with vio-
lations, %
1974
29
17
8
10
4
6
1975
21
19
3
8
2
4
2nd max
PPM
1974
28.9
19.1
15.2
14.8
11.7
13.5
1975
22.3
23.1
14.0
21.9
12.0
16.6
Max
PPM
1974
30.3
19.7
17.0
18.6
14.6
16.3
1975
22.6
24.0
16.0
23.3
15.0
19.0
One-hour
Days with vio-
lations, %
1974
9
9
21
14
15
36
1975
5
4
22
17
13
18
03C
2nd max
PPM
1974
.180
.140
.170
.140
.165
.250
1975
.115
.108
.178
.135
.135
.177
Max
PPM
1974
.185
.155
.220
.155
.165
.375
1975
.132
.110
.197
.139
.139
.182
One-hour CO standard - 35 PPM
Eight-hour CO standard • 9 PPM
C0ne-hour 03 standard » .08 PPM
Source: JRPP Air Quality Assessment Statement, Colorado Division of Highways,
1 November 1976.
-------
The air pollutant emissions that constitute the main problem
in the Denver Metropolitan Area are carbon monoxide, particulates,
reactive hydrocarbons (which react to form ozone) and the oxides of
nitrogen. Automobile traffic accounts for a major fraction of the
pollutants emitted. All traffic accounts for roughly 80 percent of
the hydrocarbon emissions, 30 to 40 percent of the nitrogen oxide
emissions, and about 95 percent of the carbon monoxide emissions.
It is thought that, while automobiles and other vehicles do not
directly contribute a high proportion of the particulate emissions
in the Denver Metropolitan Area, street sanding operations, which
are related to the operation of these vehicles, contribute anywhere
from 45 to 60 percent of the total particulate emissions. Next to
automobiles and other traffic, point sources are the most significant
contributors to total emissions. Large point emissions alone account
for as much as 50 percent of the total emissions of the oxides of
nitrogen. Table II-C gives the Denver emissions inventory estimated
for 1974. The State Air Pollution Control Division is currently
revising the Denver emissions inventory to incorporate the latest
estimates of vehicle emissions, current transportation planning and
population distribution forecasts.
Geology
The Denver area is divided into two distinct bedrock regions,
both of which dip to the east. The slightly dipping strata of the
plains is separated from the steeply dipping strata of the Front
Range, by a north-northwest, south-southwest trending zone of sharp,
almost vertical folds. The locations of unique and significant geo-
logical structures and formations are shown on Map C.
The most important potential geologic problem in the Denver
area is the shrink-swell characteristics of bentonitic clays found
in the Denver^Arapahoe and other formations underlying most of the
clay-derived soils in the area. Shrink-swell potential, which can
place severe restrictions on urban development because of slippage
and differential settling risks, is greatest in the foothills west
of Denver where special site design is needed. This potential is
moderate-to-low elsewhere in the region. Other less widespread
geologic hazards include landslides in the western foothills having
slopes greater than 25 percent and soils supported by clay substrata;
subsidence and slope instability in mining areas found scattered on
the north, west, and south peripheries of the metropolitan area; and
faults (see Map C) representing a very low potential for seismic
activity in the region.
32
-------
Table II-C 1974 DENVER EMISSIONS INVENTORY
Source
Q
Carbon monoxide
Automotive
Space heat
Point sources
Total
b
Hydrocarbons
Automotive
Space heat
Oil paint
Gas stations
Cleaners
Incinerators
Point sources
Airports
Total
Particulate
Space heat
Automotive
Airports
Construction
Street sanding
Point sources
Total
N02
Space heat
Small points
Automotive
Airports
Point sources
Total
Emissions,
tons
(per day)
2,925.0
2.9
167.6
3,095.5
(per day)
199.18
0.48
2.08
11.67
4.94
0.11
13.14
5,92
237.52
(per year)
511
4,213
63
8,730
15,857
5,981
35,355
(per year)
5,348
87
31,646
1,552
33,773
72,406
Contributions,
%
94.5
0.1
5.4
100.0
83.9
0.2
0.9
4.9
2.1
0.0
5.5
2.5
100.0
1.4
11.9
0.0
24.7
44.9
16.7
99.6
7.4
0.0
43.7
2.1
46.6
99.8
Based on winter emissions distributions.
Based on summer emissions distributions.
33
-------
Soils
Soils in the study area have been surveyed by the U.S. Soil Con-
servation Service (SCS) in recent years. Final survey reports have
been published for Adams and Arapahoe Counties (Reference 701 and 702),
while the results of the other county soil surveys for the study area
have yet to be published.
Because considerations of the agricultural capabilities of the
regional soils will be discussed at length under "Agricultural Land
Use", this discussion will address only general soil-related problems.
The major problem of most soils in the region is the shrink-swell
characteristics discussed in Geology above. The other significant
regional soils problem is aeolian, i.e. wind, erosion. Where dry-
land fanning is practical, wind erosion causes losses of valuable
topsoil during severe windstorm episodes. This problem is especially
critical in the dryland farming areas of Adams and Arapahoe Counties.
Hydrology
The principal hydrolbgic system is the South Platte River and
its tributaries. The South Platte River and the tributaries of Bear
Creek, Clear Creek, Boulder Creek and Coal Creek have their head-
waters in the mountains to the west (see Map E). They are snowmelt
streams whose annual variation of flow is directly related to the
snow pack accumulated during the previous winter. Approximately 75
percent of the annual flow occurs during the spring and early part
of the summer, peaking in May or June. The remaining 25 percent of
the flow occurs during the fall and winter months, with the low flow
in January or February. The other major tributaries, including
Cherry Creek, Sand Creek, Big Dry Creek and Plum Creek, rise on the
plains east of the mountains. Flow of these streams comes princi-
pally from precipitation. All streams in the study area respond
vigorously to frontal and thunderstorm rainfall events.
The natural flow of the South Platte River is insufficient to
meet the total demand of municipal, industrial and agricultural
users. This has lead to an elaborate regulation and distribution
system consisting of diversions for irrigation, transmountain di-
versions to augment basin supplies, and numerous reservoirs for
irrigation and flood control (see Figure II-H). This system of
water use, reuse and subsequent use radically alters the natural
flow characteristics of many streams. Flows in Cherry Creek below
Cherry Creek dam are sometimes comprised entirely of urban runoff.
At times, the flow in Clear Creek below Golden is primarily from
sewage treatment plant effluent, and at other times it is dry due to
irrigation diversions. Sand Creek is frequently an intermittent
stream with periods of no flow. Normal flows in Big Dry Creek are
primarily irrigation and irrigation return flows in addition to
urban runoff.
34
-------
WILLIAMS FORK RIVER
•GREEN MTN. RES. WILLIAMS
FORK
RESERVOIR
VASQUEZ TUNNEL
CONTINENTAL DIVIDE
GROSS RESERVOIR
MOFFAT
GRAND
JUNCTION
MOFFAT TUNNEL
,w>
i»
BOULDER
; . RALSTON RESERVOIR
GUMLICK TUNNEL LONG
DILLON
RESERVOIR
EAGLE-
COLORADO
RESERVOIR
SODA
HARRIMAN LAKE
ROBERTS
TUNNEL
KASSLER
TREATMENT
PLANT
GRANT V
AREA
ENLARGED
;T TWO FORKS
|i RESERVOIR
CONTINENTAL DIVIDE
CHEESMAN
RESERVOIR
PLATTE CANYON RESERVOIR
STRONTIA SPRINGS RESERVOIR
FOOTHILLS
«^i***fs"i TREATMENT
--" - PLANT
/~\ CASTLE ROCK
ANTERO RESERVOIR
ELEVEN MILE
RESERVOIR
COLORADO SPRINGS
EXISTING
PROPOSED
SOURCE: RTD
WATER SUPPLY SYSTEM
DENVER WATER DEPARTMENT
-------
Past urbanization has severely constricted some of the drain-
age ways to the point where structural measures are necessary to
safely pass a 100 year flood without substantial property damage.
Severe structural flood control projects in the area have been con-
ducted up to at least the master planning design state. They in-
clude Chatfield Damn, Cherry Creek Dam, Bear Creek Lake Dam (under
construction), and channel improvements for Sanderson Gulch, which
are designed for the 10 year flood event. Regulations are in effect
to limit the peak rate of runoff from urbanizing lands to the his-
toric peak rate in the counties of Jefferson and Boulder, and the
Cities of Arvada, Lakewood, Boulder and Thornton. The basin or
regionwide effect of requiring individual developments to provide
detention to meet historic peak runoff requirements is yet to be
determined for the study area. The "aggregate effect may be higher
peak rates of runoff for downstream reaches because detained hydro-
graphs from individual subbasins are long and flat and are more
likely to become additive. Present major drainage planning is based
on future basin development and considers that detention require-
ments will not be effective (see Map G).
Water Supply
Surface Water —
The largest municipal water supplier is Denver Water Department
which provides the City and County of Denver, plus a number of sub-
urban cities, special districts and other agencies with approxi-
mately two-thirds of the municipal raw water used in the region.
Thirty-three percent of the raw water utilized for municipal purposes
in the region is transmountain water imported from west of the Con-
tinental Divide by the cities of Denver, Aurora, Englewood, and
Boulder. Data from the Bureau of Land Management's SIS (Reference
615) and from the Denver Water Department's 1975 study of future
water demand (Reference 1001) were used in developing the information
shown in Figure II-I. The projection, based upon a 0.87 cubic metre
(230 gallons) per capita per day rate of consumption is the rate in
reference 615 applied to the region's population. Other projections
are based on consumption rates incorporating feasible management and
conservation practices. Reference 615 states that by 1980, the Denver
Water Department's ability to meet demand, about two-thirds of the
region's demand, will be constrained by the available capacity for
water treatment if the proposed Foothills water treatment project
is not built. This constraint occurs during summer peak demand days.
The quantity of raw water available to Denver will constrain demand by
1988 without Foothills and by 1990 if Foothills is built. Thus,
according to the EIS on the Foothills project, additional raw water
supplies, probably additional west slope importations, will be needed in
either event if past consumption rates continue. Conservation and
management practices could significantly delay these treatment capacity
and raw water supply needs.
36
-------
FIGURE 11-1
DENVER REGION WATER SUPPLY AND DEMAND
1,000
800
03
01
O
CO
600
400
200
230 GAL/
CAP. (100X)
160 GAL/CAP. (67%)
1970
1980
1990
2000
2010
YEAR
NOTE: POPULATION IS 2,350,000
FOR THE YEAR 2000.
37
-------
Ground Water —
There are two ground-water systems in the Denver area. The
first is the shallow ground-water system of aquifers under water-
table conditions found in the flood plains and terraces of the
South Platte River basin, in the dune sand deposits that occur in
the vicinity of the Rocky Mountain Arsenal, and in the alluvial fan
remnants that occur adjacent to the Front Range Mountains (See Map
C). Recharge to these aquifers occurs in areas where deposits are
exposed to the land surface. Further onto the plains area, streams
receive ground water discharges from shallow ground-water aquifers.
These discharges account for much of the flow in the South Platte
basin during the latter part of the summer. The shallow ground-
water aquifers in this area are sources for domestic water supplies.
Unusually high levels of nitrite have recently been discovered
in the City of Thronton's water system, which gets its supply from
wells in the alluvial aquifer near the South Platte River. This is
unusual because nitrite is unstable and easily oxidized to nitrate.
It is suspected that the recent drought has caused the overdrafting
of the alluvial aquifers. This would accelerate recharge from the
South Platte River which contains high levels of nitrates due in
part to nitrate concentrations in the discharge from the MDSDD #1
wastewater treatment plant. This hypothesis has not been proved,
and by itself does not explain high levels of nitrite. However,
it does demonstrate that surface water quality can affect a public
ground-water supply.
The second system is the deep ground-water aquifers under
artesian pressure. These aquifers are the Dawson, Denver and
Arapahoe formations, and the Laramie-Fox Hills sands containing
water under pressure at depths ranging from 150 to 900 metres
(500 to 3,000 feet) beneath the Denver region. These units are
separated from one another by layers of clay and shale which mini-
mizes the movement of water between aquifers. Generally, recharge
occurs throughout the southwestern quarter of the study area and
along the western edge of the Denver basin where these aquifers
outcrop. There are some wells drawing water from the Laramie-Fox
Hills formation. The water from some of these wells contain con-
centrations of iron and fluoride above limits recommended for a
public water supply.
Water Quality
The following discussions of current water quality in the
Denver region are based in large part on information developed by
DRCOG and its consultants to support the preparation of the Denver
Clean Water Plan (CWP). This program is frequently or commonly
termed the 208 Plan because it is required by Section 208 of the
Water Pollution Control Act Amendments of 1972.
38
-------
A number of physical parameters, chemical and biological are
used to indicate water quality. These characteristics are important
because they either directly affect people and wildlife or indirectly
interact to cause effects. For example, certain amounts of dissolved
oxygen (DO) in the water are necessary to support fish life and other
desirable organisms. Water temperature (T) affects the amount of
dissolved oxygen water can contain. Biochemical oxygen demand (BOD)
refers to the amount of organic material which is available as food
for various organisms. When a large amount of food is available, the
number of organisms increases and the amount of oxygen in the water
is reduced. The term BOD5 is commonly used to indicate the BOD over
a five day period. Total dissolved solids (TDS) are in the form of
salts. High TDS in water for agriculture limits crop productivity
and can cause salts to build up in soils and permanently degrade
agricultural soils. High TDS mades water disagreeable to taste and
can cause effects such as diarrhea. It also limits the use of water
by industry in manufacturing processes. Ammonia (NH3) is toxic to
fish. Nitrates (N03) can cause serious health problems for infants
if nitrates get into a public water supply. Nitrogen and phosphorus
compounds (N03, P04) supply nitrients to small water-borne plantlike
organisms. Algal blooms may occur and cause unpleasant odors and
unsighliness. Also, when these organisms die and decay, they repre-
sent a BOD. Fecal coliforms and streptococci (colistrep) are bac-
teria naturally occurring in the intestines of humans and warmblooded
animals. The presence of these bacteria are used as indicators of
fecal contamination of water, and thus the possible presence of
disease causing bacteria.
Desired Water Quality —
During the Clean Water Program study, various water uses were
considered and evaluated for the study area. Four broad areas of
desirable uses were identified: agriculture (irrigation and live-
stock watering), recreation (primary and secondary contact), main-
tenance of aquatic life (cold and warm water fisheries and stream
or lake aesthetics), and domestic raw water supply.
Current stream classifications and the recommended stream quality
parameter values for these uses are indicated in Table II-D. Table
II-E indicates the current State classification by reach of the
streams in the study area. Map E will assist the reader in identify-
ing streams.
Table II-F presents the historical and present uses, present
State stream classification; and the Clean Water Plan (CWP) use
classification recommendations for the major streams in the study
area.
39
-------
Table II-D. RECOMMENDED WATER QUALITY LEVELS FOR SPECIFIC WATER USES
Water quality parameters/limits
Stream
classi-
fication
B2
Bl
Tempera- Dissolved
ture, oxygen,
Uses °C me/1
Aesthetics (stream), 8 to 30 5
wildlife and live-
stock watering, urban
irrigation, secondary
contact recreation.
warm water fishery
Same as above (B|) 5 to 15 6
except cold water
fishery
Total
BODj, dissolved
mg/1 solids, ng/1
1,000
to
3,000
1,000
to
3,000
Fecal
coliforms,
MPH/100 ml
200
to
1,000
200
to
1,000
Fecal
streptococci,
MFN/100 ml
20
20
NH3-N, N03-N, Total N, FOi,-P,*
mg/1 mg/1 mg/1 ng/1
2.5 10 10 0.05
1.0 10 10 0.05
A2 Aesthetics (stream 8 to 30
or lake), wildlife
and livestock water-
Ing, urban Irriga-
tion, primary contact
recreation, domestic
potable water (raw
supply), warm water
fishery, plus all
Bj uses
AI Same as above (Aa) 5 to 15
except as cold water
fishery, plus all D!
uses
500
200
20
2.5
10
10
500
200
20
2:5
10
10
0.025
to
0.1
0.025
to
0.1
I'hosph.Hi'K arp essential for blo1oj;1ral growth especially n I g.ir, hut utli«r t innl 11 U'tis mini: t-xlHt hcfiirc problems result. Rc-rommendrd levels
iiullcatv ji nlgnirirnnl plmtvnt till priihlfm may pxlHl if other nrccsHury nind 11 Inns rxlsl.
c: Unt'liic'cr Inn Srtem-f' hnsol 111 larRP |);irt nn Rcfi-rc'iH-cs 20fl, 228, 26) und Nt;llldnrd« proposed hy Cnlnrndn IK-partinonl nf Men] til.
-------
Table II-E. CURRENT STATE OF COLORADO
CLASSIFICATION BY STREAM AND REACH
Stream
Use
class
Reach
South Platte
South Platte
Sloans Lake
Bear Creek
Bear Creek
Cherry Creek Reservoir
Cherry Creek
Cherry Creek
-Clear Creek
Clear Creek
Coal Creek
Coal Creek
Source to Exposition Avenue
Exposition Avenue to Nebraska
Inlet to outlet
Source to Morrison
82 Morrison to South Platte
Inlet to outlet
A-2* Source to reservoir
Reservoir to South Platte
Bi Source to Farmers Highline Canal
B2 Fanners Highline Canal to South Platte
B1 Source to Highway 93
Highway 93 to mouth
South Boulder Creek B]_ Source to Highway 93
South Boulder Creek 82 Highway 93 to mouth
Boulder Creek
Boulder Creek
Sand Creek
Big Drv Creek
Source to Highway 119
Highway 119 to mouth
82* Source to South Platte
B?* Source to South Platte
*Initially assumed for 208 study; not State of Colora'do classification.
Source: Reference 228
41
-------
Table Il-F. WATER QUALITY ATTAINABILITY/USE POTENTIAL
208 BMln
Historical and present use Present State classitleation
Use potential
CWP Rec
inded Use
Upper South Platte Natural trout stream formerly B, Cold-water fishery
South Metro
Cold-water put-and-take fish-
ery at present to Chatfield
Reservoir
Swimming, rafting during
high flows
Natural trout stream form-
erly
B. Cold-water fishery
(to Exposition Avenue)
Natural cold-water fishery
with suitable substrate and
flow conditions
Swimming, rafting
Rafting, boating
Cold-water fishery, put-
and-take
Primary-contact recreation
Agriculture and wildlife
Cold-water fishery
Hater supply
Primary-contact recreation
Agriculture and wildlife
Cold-water fishery
Hater supply
Lower South Platte
through Lakewood
Basin
Lower South Platte
through Clear Creek
Basin
Lower South Platte
below 104th Avenue
Cherry Creek above
reservoir
Cherry Creek below
reservoir
Only rough fish in flowing
waters or pooled areas
Some waterfowl use and some
boating
Only rough fish in flowing
waters/or pooled areas
Some waterfowl
Only rough fish in flowing
watera or pooled areas
Boating during high flows
Rough fish
Rafting in Hlghline Canal
during high flows
Rough fish and some warm-
water fish when flows con-
sistent
Boating in downstream areas
B. Harm-water fishery
(from Exposition Ave-
nue)
B. Harm-water fishery
(from Exposition Ave-
nue)
B- Warm-water fishery
Unclassified (A. res-
ervoir) *
Unclassified
Boating
Warm-water fishery
Boating
Warm-water fishery
Warm-water fishery with
Increased flown and Im-
proved quality
Boating, rafting
Warm-water fishery
Potential for secondary-
contact recreation In down-
stream areas
Warm-water fishery In down-
stream areas, upstream with
flow releases
Boating
Secondary-contact recreation
Wildlife
Agricultural/Industrial uae
Secondary-contact recreation
Agricultural/Industrial use
Secondary-contact (recreation
Agricultural/industrial use
Primary-contact recreation
Agricultural/Industrial Use
Warm-water fishery
Water supply
Secondary-contact recreation
Groundwater supply
Wildlife
Agricultural/industrial use
-------
Table II-F. WATER QUALITY ATTAINABILITY/USE POTENTIAL (continued)
208 Basin
Historical and present use Present State classification Dae potential
CWP Recommended
Sand Creek
Bear Creek through
Morrison
Bear Creek below
Morrison
Clear Creek to
Golden
Clear Creek below
nolden
Big Dry Creek
upstream of Stand-
ley Reservoir
Big Dry Creek below
Standley
Rough fish In pooled areas
most of tha year
No recreation
Natural trout fishery to
Morrison formerly
PUt-and-take fishery at
present
Some put-and-take fishery
at present
Rafting, boating downstream
from Morrison
Natural cold-water fishery
formerly
Natural cold-water fishery
to Idaho Springs
Fish populations precluded
from Idaho Springs to Gold-
en from low pll values, heavy
metals
Some trout and downstream
some warm-water fish
species
Boating, rafting downstream
of Golden
Put-and-take cold-water
fishery upstream of
Standley Reservoir *
Rough fish and warm-water
fishery
Unclassified
B, Cold-water fish-
ery (to Morrison)
B- Warm-water fish-
ery (from Morrison)
B. Cold-water fish-
ery (to High'line
Canal)
B- Warm-water fisher-
ies (Illghllne Canal
downstream)
Unclassified
Unclassified
Recreational potential dur-
ing high flows
No fishery potential, only
rough fish
No recreation potential In
upstream area
Natural cold-water fishery
potential
Recreation potential for
rafting, boating
Potential for cold-water
fishery with releases from
Mr. Carbon Reservoir
Natural cold-water fishery
to Golden
Rafting, boating
Warm-water fishery down-
stream of Golden
Cold-water fishery
Warm-water fishery with
sufficient flows
Secondary-contact recreation
Wildlife
Agricultural/Industrial use
Cold-water fishery
Primary-contact recreation
Wildlife
Water supply
Agricultural/Industrial use
Primary-contact recreation
Water supply
Wildlife
Cold-water fishery
Agricultural/Industrial
Cold-water fishery
Water supply
Primary-contact recreation1
Agricultural/Indus trial
Wildlife
Secondary-contact recreation
Water supply
Agricultural/Industrial Use
Cold-water fishery
Water supply
Primary-contact recreation
Warm-water fishery
Secondary-contact recreation
Wildlife
Agricultural/industrial
*U.S. Forest Sorvlci- Cnnimriit s th.ll (here is no rold-w;il or fishery in tliit; ort',1.
-------
II-F. WATER QUALITY ATTAINABILITY/USE POTENTIAL (continued)
208 Basin
Historical and present use Present State classification
Use potential
CHP Recommended Use
Coal Creek to Inter-
section with Route
93
Coal Creek Route 93
to South Platte
Natural cold-water fish-
ery upstream formerly
Put-and-take at present
Rough fish and warm-water
fishery
Boulder Creek source Natural cold-water fish-
to 75th Street ery
Boulder Creek, 75th
Street to Coal
Creek
Boulder Creek, Coal
Creek to mouth
Cold-water put-and-take
fishery
Rafting, swimming
Cold-water put-and-take
fishery and warm-water
fishery
B- Cold-vater fishery Cold-water fishery
Harm-water fishery
A- Domestic use, pri-
mary/secondary-contact
recreation, fisheries
B, Cold-water fishery
B. Harm-water fishery
Warm-water fishery
Domestic use, recrea-
tion
Cold-water fishery
Primary-contact recrea-
tion
Cold-water fishery with
reservoir releases
Cold-water fishery with
flows, otherwise warm-
water fishery
Cold-water fishery
Primary-contact recreation
Wildlife
Agricultural/indue trial
Water supply
Secondary-contact recreation
Wildlife
Agricultural/Industrial
Groundwater su pply
Primary-contact recreation1
Cold-water fishery
Water supply
Agricultural/Indus t rial
Primary-contact recreation
Cold-water fishery
Hater supply
Agricultural/Indus trial
Secondary-contact recreation
Agricultural/Industrial
Note: Historical and present uaca were obtained through existing literature sources and from interviews Resource Planning Associates conducted
with state and local experts In fisheries and water quality management and with ORCOG representatives during the week of Decentet 6-10 in
the Denver area. State classifications are those made effective June 19, 1974. Use potential is a concensus of opinion of the expert*
interviewed for this analysis and RPA's professional judgment aa to the highest and best uses for these stream segments; use potential
responds to the Colorado State Water Quality Control Commission's desire to assign a stream classification for the highest and best use to
which a stream segment could be put on the basis of past and present uses and/or natural conditions. Use potential does not consider the
technological capability, cost, or socio-economic Impact of Implementing such a classification. The recommended me Is the Clean Hater
Flan's recommendation for stream classification .to meet permits for Denver area streams. The CWP recommendations must be acted on. by the
Hater Quality Commission and EPA prior to adoption.
Source: References 259, 263
-------
It should be recognized that the Clean Water Plan use recommen-
dations represent goals for the study area the Clean Water Plan
considers consistent with the national goals of "fishable and swimm-
able waters" by 1983 and "zero" discharge of pollutants by 1985, as
stated in the Federal Water Pollution Control Act Amendments of 1972.
The Clean Water Plan recommends downgrading the classification of a
number of stream reaches by eliminating fishery designations. The
State of Colorado, however, has not adopted these use recommendations
nor the quality criteria used in the Clean Water Plan.
Existing Water Quality —
The following subsections present the "existing" water quality
in the study area by basin, based on stream data obtained during
calendar year 1972. Table II-G is a list of the wastewater treat-
ment facilities that were investigated for their impact upon stream
water quality.
Data for 1972 was used largely because this was the year picked
by DRCOG for Clean Water Program planning as most representative of
flow conditions for the last several years and for which water
quality data were available. The data used to characterize water
quality in 1972 is summarized in Table II-H. This data is compared
with the recommended levels shown in Table II-D and stream classi-
fications shown in Table II-E to evaluate water quality in 1972.
South Platte Basin Water Quality Trends — The following dis-
cussions are based primarily on average levels for various water
quality parameters. Effects of runoff events will be discussed
after each water quality parameter is examined.
Water temperature, in addition to following normal seasonal
trends, generally increases as flow proceeds through the urbanized
area of the basin. Temperatures are within limits for the water
uses designated for the various streams or portions of streams,
except for Bear Creek above Morrison, and the South Platte above
Littleton. Temperature limits are sometimes exceeded during late
summer.
Dissolved oxygen (DO), also follows expected seasonal trends
with DO levels decreasing from winter levels during the course of
the year until fall, when water temperatures begin to decrease and
DO levels begin to rise. Dissolved oxygen levels decrease as water
flows through the Denver area. Average dissolved oxygen levels con-
sistently meet recommended limits for the various water uses.
Total dissolved solids (TDS) show weak seasonal trends, but
seem most influenced by flow through the urban area. TDS levels for
tributaries to the South Platte generally increase by a factor of
-------
Table II-G. WASTEWATER TREATMENT FACILITIES INVESTIGATED FOR THEIR
IMPACT ON EXISTING WATER QUALITY, STATUS CIRCA 1972
Plant
Morrison
Glendale
Aurora
Fitzsiraons
Coora
Wheat ridge
Clear Creek Valley
Arvada
Crestvlew
Littleton
Englewood
South Lakevood
Metro Denver #1
South Adams County
Broomfield
Westminster
Erie
Lafayette
Louisville
Boulder White Rocks
Type
Activated sludge
rotot aeration
Activated sludge
Activated sludge
Trickling filter
Activated sludge
Trickling filter
Activated sludge
Trickling filter
Trickling filter
Trickling filter
activated sludge
Trickling filter
Activated sludge
Activated sludge
Trickling filter
Trickling filter
Activated sludge
Lagoon
Trickling filter
Activated sludge
aerated lagoon
Trickling filter
Primary
0.07
1.0
1.5
0.9
4.0
2.5
2.1
0.7
1.0
7.6
12.0
1.3
28.0
2.5
1.6
1.0
0.3
0.7
15.6
Capacity, nftd
Secondary
0.07
1.0
1.5
0.9
9.0
2.5
2.1
0.7
1.0
7.6/1.5
12.0
1.3
98.0
2.5
1.6
1.0
2.57 acres
0.3
0.7
15.6
Receiving Stream
Bear Creek
Cherry Creek
Sand Creek
Tollgate Creek
Clear Creek
Clear Creek
Clear Creek
Clear Creek
Clear Creek
South Platte
South Platte
South Platte
South Platte
South Platte
Big Dry Creek
Big Dry Creek
Coal Creek
Coal Creek
Coal Creek
Boulder Creek
-------
Table II-H.
EXISTING WATER QUALITY
(1972)
Location
Winter
Bear Creek it Morrison
Bear' Creek at mouth
Cherry Creek at Franktown
Cherry Creek at mouth
Sand Creek at mouth
Clear Creek at Golden
Clear Creek at mouth
South Platte at Blakeland
South Platte at 38th Ave.
South I'latte at Henderson
Spring
Bear Creek at Morrison
Rear Creek at mouth
Cherrv Creek at Franktown
Cherry Creek at mouth
Sand Creek at mouth
Clear Creek at Golden
Clear Creek at mouth
South Platte at Blakeland
South Pl.itte at 38th Ave.
South Platte at Henderson
State-
assigned
classifi-
cation
BI
B2
A2
«z
B2
BI
B2
BI
B2
B2
B!
B2
A?
n?
BZ
BI
B2
B!
BZ
»Z
Tempera-
turn ,
°C
Avg
6
10
2
8
9
4
8
7
8
8
10
20
10
20
20
10
20
15
17
18
Peak
12
17
4
18
15
10
20
12
15
16
14
25
16
25
25
13
25
18
2'i
23
Dissolved
oxygen,
mg/1
AVB Mln
13
10.8 7.2
13.6
10.3 7.3
11 7.5
13
11 7
9.5 .
10.5
10.2 7.3
9.2
8.5 6
10
8 4.6
8.6 5.8
7.3
8.9 ft. 7
7
8.5
8.1 6.1
Total
dissolved
solids, me/1
Avg
90
200
250
430
900
200
400
250
500
700
85
220
75
650
1,500
275
400
250
600
700
Peak.
95
3,800
-
6,800
4,000
500
4,000
_
4,500
4,000
100
3,000
150
4,750
3,600
500
600
-
1,000
1 , 000
BOD,
Ayg Peak
3
4
2
3
9
2
18
5
14
30
3
3
1.
3
10
2.
8
5
10
16
4
42
-
81
43
5
50
_
17
33
4
32
3 2
61
38
5 5
15
-
17
20
Ammonia ,
mg/1
Avg
0.13
0.2
0.01
1.0
5
0.23
4
0.01
3
10
\
0.13
0.2
0.02
0.6
5
0.23
1.5
0.01
1.5
8
Peak
-
1.8
0.05
3.5
7
-
11
-
3.8
13
-
0.7
-
2.7
6
-
7.3
-
3.5
15
Nitrate,
mK/1
Avg
0.31
1.0
0.11
3.0
3
0.4
2.5
0.03
1.5
1.8
0.31
1.5
0.16
2
3
0.4
2
0.03
1.5
1.8
Peak
-
A
6.15
5
4
-
4
-
1.8
5
-
4.5
0.18
4.5
5.2
-
2.8
-
2.8
4
Phosphate,
me/1
Avg
0.23
0.3
0.01
4
3.5
0.2
3.2
0.05
2
5
0.23
0.3
0.03
2.5
2.5
0.2
1.7
0.05
1
3
Peak
-
2
-
7
4.5
-
5
-
4.5
6.5
-
2.3
0.06
5.B
5
-
3.4
-
3.5
6.5
Fecal
colifonns,
MPN/100 ml
Atrg
200
300
-
650
2,500
204
800
30
600
1,000
400
300
-
800
2,500
400
800
15
600
1,000
Peak
-
15,000
-
26,000
19.000
600
25,000
35
17,000
16,000
1,500
1J.OOO
-
6,000
14,500
600
10,000
40
20,500
9,000
Fecal
streptococci,
MPN/100 ml
Ave Peak
300
700 154,000
— —
1,800 204,000
4,000 123,000
300 400
300 200,000
40 45
20,000 130,000
2,500 125,000
300 1,000
700 121,000
- -
IjOOO 22,000
4,000 84,000
200 400
300 90,000
32 40
20,000 100,000
2,500 65,000
-------
Table II-H. EXISTING WATER QUALITY (continued)
(1972)
oo
State Tempera-
assigned ture,
classifi- *C
Location
Summer/Fall
Bear Creek at Morrison
Bear Creek at month
Cherry Creek at Franktown
Cherry Creek at mouth
Sand Creek at mouth
Clear Creek at Golden
Clear Creek nt mouth
South Flatte at Blakeland
South Flatte at 38th Ave.
South Flatte nt Henderson
cation
Bl
85
A2
B2
B,
Bl
B2
Bl
BZ
B2
Avg
14
21
15
20
20
13
22
16
20
20
Peak
20
28
20
26
26
20
28
21
26
27
Dissolved
oxygen,
ma/1
Avg Min
10.1
8 5
9.8
7.3 0.4
8.2 6.2
10
8.2 6.2
6.3
8
7.6 5.4
Total
dissolved
solids, me/1
Avg
85
250
230
725
1,200
175
400
250
650
700
Teak
95
3,600
250
6,800
3,300
200
600
4,600
2,000
BOD,
Avg Peak
2.5
2
2.7
3
6
2
8
5
10
10.2
3
41
3
75
35
5
13
16
16
Amm
m
AVR
0.13
0.15
0.07
0.6
3
0.23
1.2
0.01
7.5
lonia ,
aZl
Peak
_
1.8
0.10
4.3
6.5
-
2.5
12.5
Nitrate,
BE/1
Avg
0.31
1.0
0.18
2.1
3.5
0.4
2
0.03
2
PeaV
-
4.3
0.20
5.5
4.5
-
2.3
-
3.5
Phosphate,
mz/1
AVR
0.23
0.3
0.04
2.5
3.5
0.2
1.4
0.05
4
Peak
-
1.7
0.05
6.2
8.5
-
1.5
-
6
Fecal
coHforma,
MPN/100 ml
Avg
200
300
-
800
2,500
204
800
20
600
1,000
Peak
_
18,000
-
26,000
12,500
400
10,000
30
16, 000
10, 000
Fecal
streptococci,
MPN/100 ml
Avg
300
700
-
1,000
4,000
300
300
34
20,000
2,500
Peak
_
140.000
-
182,000
56,000
380
90,000
40
130,000
75,000
-------
two as streams progress through the urban area. With the exception
of Sand Creek, levels for TDS are at or below limits recommended
for specific water uses. The high TDS levels in Sand Creek are due
in large measure to the nature of the creek bed, and the gravel
mining which occurs on upstream portions of the stream.
Five day biochemical oxygen demand (BOD,.) levels generally are
fairly constant throughout the year in the upstream portions of basin
streams. The same is also true at the mouth of Cherry Creek. BOD,.
levels, where Bear and Clear Creeks enter the Platte and on the
Platte below Littleton, decrease from winter highs to lowest levels
in the spring instead of winter. These trends appear to indicate a
greater influence from point sources during wintertime low natural
stream flows. The highest BOD levels in the South Platte occur at
Henderson and the highest levels in tributaries occur at the mouths
of Clear and Sand Creeks.
The downstream portions of Clear, Sand and Cherry Creeks, as
well as the South Platte below Littleton, have ammonia (NH3) concen-
trations (in conjunction with pH and temperature) which are on the
average at potentially toxic levels throughout the year. The highest
levels, 10 milligrams per litre (mg/1), occur in the South Platte at
Henderson during the winter. Highest ammonia levels generally occur
in winter for the streams mentioned. Ammonia levels in the headwaters
are at acceptable levels.
Nitrate levels throughout the South Platte basin are within
recommended levels. However, these levels will maintain, and perhaps
speedup present eutrophication. Table II-H shows that the highest
levels occur in Sand Creek, Cherry Creek and Clear Creek where these
creeks flow into the South Platte. These levels vary between 2.0 to
3.5 mg/1, which are significantly below the recommended limit of 10
mg/1 for nitrate. However, recommended levels for total nitrogen
are exceeded in the South Platte at Henderson, and nitrate levels
in the South Platte are suspected of causing problems for the City
of Thornton water supply.
Levels of phosphate, a pollution indicator, exceed recommended
levels throughout the basin during the year except for wintertime
levels in Cherry Creek above Cherry Creek Reservoir and the South
Platte above Littleton which is at the limit. Phosphate levels
increase downstream from upstream. The upper portion of Cherry
Creek, above the reservoir, is the only headwater showing a variation
in levels through a year. Bear Creek at the mouth had constant
levels of phosphate, however, a seasonal trend is very pronounced
for the remainder of the tributaries where they flow into the South
Platte as well as for the South Platte itself. This trend begins
with high levels during the winter, with generally lower levels
throughout the remainder of the year until fall, when levels begin to
49
-------
climb to winter highs. Phosphate levels are highest in the South
Platte at Henderson where levels of 5.0 mg/1 occur. The next highest
levels occur in Cherry Creek at the mouth, 2.5 to 4.0 ntg/1, Sand Creek
at the mouth, 2.5 to 3 mg/1, and Clear Creek at the mouth, 1.4 to
3 mg/1.
Fecal coliform recommended limits are met year round only in
the South Platte above Littleton. They are equalled during summer,
fall and winter in the headwaters of Bear and Clear Creeks, but
are exceeded during spring. No data exists for Cherry Creek above
Cherry Creek Reservoir, but a similar trend is expected. The higher
levels in downstream portions of the basin are essentially constant
throughout the year. The highest levels in the basin are found in
Sand Creek at the mouth with 2,500 MPN/100 ml.*
Recommended limits for fecal streptococci, 20 MPN/100 ml, are
exceeded throughout the South Platte basin throughout the year.
The lowest levels, 32 to 40 MPN/100 ml, are found in the South Platte
above Littleton. Fecal streptococci levels are essentially constant
throughout the year except at the mouth of Cherry Creek where winter
levels are substantially above levels for the remainder of the year.
The highest levels in the South Platte basin occur in the South Platte
at 38th Avenue in Denver, approximately one mile downstream of where
Cherry Creek enters the South Platte. These levels are also found in
Sand Creek at the mouth. Very high levels are also found in the
South Platte at Henderson, 2,500 MPN/100 ml, and at the mouth of
Cherry Creek, 1,000 to 1,800 MPN/100 ml.
The previous discussions were concerned with water quality
during average conditions. Table II-H also indicates peak levels
that occur during various seasons of the year. Data indicates that
these peaks occur during runoff events, such as snowmelt and/or rain
in the region. A review, of Table II-H indicates that peak levels
during runoff events at times exceed recommended levels which are in
some measure met during average conditions for total dissolved solids
(TDS), ammonia (NH_) and total nitrogen.
Temperature and dissolved oxygen levels by themselves are not
generally a problem during runoff events, and peak levels of nitrate
are still within limits. Minimum levels of dissolved oxygen, not
associated with runoff events, do occasionally fall below recommended
minimums, particularly in the Lower South Platte and at the mouths of
tributary streams during summer months. Levels for phosphate, fecal
coliform and fecal streptococci, pollution indicators, generally
exceed recommended levels during average conditions. The levels of
*MPN/100 ml means. Most Probable Number of organisms per 100 millilitres.
50
-------
these pollutants in the headwaters indicate a background level most
probably caused by non-point sources further upstream.
The remaining discussions will be limited to TDS, ammonia and
total nitrogen. Levels of TDS exceed recommended levels during
runoff events throughout the year at ths mouth of Bear, Cherry and
Sand Creeks, and in the South Platte below Littleton. Levels are
exceeded at the mouth of Clear Creek during spring, summer and fall.
Few general statements can be made about trends because such factors
as localized rain storms may have distorted the information given in
Table II-H. Two observations can be made however. The highest peak
levels of TDS occured in Cherry Creek, and the reason for this is not
known. This was true for every season of the year. Also, peak TDS
levels are generally highest during the winter at the mouth of the
tributaries, and downstream from Littleton in the South Platte. These
winter peaks correspond to small peaks in flow which infer that the
wintertime TDS peaks are associated with snowmelt runoff from streets
treated with salts.
Virtually no data exists for ammonia peak levels at the head-
waters of the tributaries or for^the South Platte above Littleton.
The data for the lower reaches indicates recommended levels are
exceeded during runoff events. No strong seasonal trends are apparent.
The highest peaks in ammonia concentrations occurred in the South
Platte at Henderson with concentrations of 12.5 to 15 rag/1.
Data on peak levels of total nitrogen are not available for
the headwaters of the South Platte or its tributaries in the Denver
region. The data for lower reaches indicates excessive levels during
runoff events year around in Sand Creek and in the South Platte at
Henderson, and in Clear Creek during winter and spring. No strong
seasonal trends are apparent. The highest peaks occurred in the -
South Platte at Henderson with concentrations of 16 to 19 mg/1.
Big Dry, Coal and Boulder Creek Basins — There are no significant
existing data for these basins available for assessment of seasonal
variations in water quality, nor are there sizeable amounts of data
for assessment of non-point or point source water quality.
Water quality for Boulder Creek at its mouth (confluence with St.
Vrain Creek) indicated an arithmetic mean of samples taken from 7 to
12 September 1971 for BODs of 2.8 mg/1, total dissolved solids of
955 mg/1, fecal coliform of 1,080 MPN/100 ml and fecal streptococcus
of 14,500 MPN/100 ml. It has also been noted that, below the Boulder/
White Rocks treatment plant, chlorine and ammonia residuals preclude
the migration farther upstream of sensitive fish species; fecal
coliform and fecal streptococcus counts increase from upstream levels;
and dissolved oxygen falls to a range of 6 to 8 mg/1 from upstream
51
-------
levels of 9 to 12 mg/1. The headwaters of Boulder Creek were noted to
have high levels of dissolved oxygen, and temperatures from November
through March of 5°C. It has also been noted that phosphate levels
are apparently higher than suggested levels for stream aesthetics
(0.06 mg/1).
Coal Creek, in the upper portion of its basin, has temperatures
and dissolved oxygen levels sufficient to support a put-and-take
trout fishery. The lower portion's water quality was degraded in 1972
because of discharges from the Erie, Lafayette and Louisville munici-
pal treatment plants and the former extraction of coals, and shows
levels of fecal coliform and fecal streptococcus greater than 200
MPN/100 ml.
Water quality in the upper portion of Big Dry Creek Basin was
unaffected in 1972 by point sources of pollution and has been suitable
for use as a put-and-take cold-water fishery. It appears that levels
of phosphate and total nitrogen are lower than suggested levels for
these pollution indicators for stream aesthetics. In the lower portion,
water quality is impacted by low releases from Standley Reservoir and
point source inflows from the Westminster and Brcornfield municipal
wastewater treatment plants. Coliform levels periodically exceed
suggested levels for urban irrigation and secondary-contact recreation.
Sources of Water Quality Problems —
This discussing will address the causes of water quality problems
identified in the two previous sections of this report. It is based
upon material previously referenced and consists of data generated
during DRCOG's Clean Water Program water quality modeling and planning
activities. Table II-I presents a summary of pollutant amounts in
each basin under the headings of point sources and non-point sources.
The following discussions are organized by basin as appropriate.
General — The two indicators of pathogenic organisms, fecal
coliforms and streptococci, are a consistent problem throughout the
South Platte basin. Table II-I clearly shows that the overwhelming
majority of these organisms come from non-point sources. Point
sources of fecal coliforms constitute less than one percent of the
total number, and point sources of fecal streptococci constitute
less than one-tenth of one percent.
The levels of nitrate (N03> are not known to cause water quality
problems, but it is suspected that they are contributing to a nitrite
(N02) problem in the City of Thornton's water supply which is drawn
from wells in the alluvial aquifers along the South Platte. The
highest levels, 1.5 to 2.0 mg/1, are found in the South Platte below
38th Avenue. These levels are significantly below the recommended
52
-------
Table II-I.
COMPARISON OF ESTIMATED POINT AND NONPOINT SOURCE LOADING
IN THE SOUTH PLATTE AND MAJOR TRIBUTARIES
(pounds per day)
Ul
Basin
Bear Creek
Cherry Creek
Sand Creek
Clear Creek
South Platte
South Metro
Middle
Lower
Totals
B0bs
NPSS PS
908
2,500
5,500
4,120
2,600
8,500
4,200
28,328
18
65
108
4,800
4,900
485
36,000
46,411
NPS3
77,300
207,200
445,000
349,000
220,400
712,400
321,000
2,332,300
TDS .
psb
410
5,770
9,700
68,300
78,600
10,600
667,600
840,980
NFS8
80
180
450
340
200
670
320
2,240
9
27
108
770
1,810
240
18,100
21,054
NPS3
70
180
400
300
190
630
310
2,080
P0" T,
PS
5
97
86
1,080
860
130
7,300
9,558
Fecal collform .
NFS8 PS
1,441,000
3,975,000
8,851,000
6,049,000
3,934,000
11,741,000
7,673,000
43,664,000
37,850
50,720
36,600
72,000
83,300
15,100
22,800
318,370
Fecal streptococci.
NPS* PSD
9,553,000
27,757,000
55,814,000
39,693,000
21,760,000
77,346,000
48,057,000
279,980,000
7,600
6,400
7,200
17,000
26,500
3,800
3,800
72,300
Note: a. Nonpolnt source loading are 1970.levels as given in Reference 215.
b. Point source loadings are estimated from yearly average effluent flows and qu<
Hydrocomp Model for 1972.
c. Values are in units of 10° per day.
d. Effluent levels estimated for Morrison sewage treatment plant.
lity for major municipal treatment plants as input to the
-------
level of 10.0 mg/1. Also, nitrates plus ammonia levels at Henderson
exceed total nitrogen recommended levels of 10.0 mg/1 in winter by
1.8 mg/1.
Bear Creek Basin — Aside from occasional high temperatures in
the headwaters and the aforementioned fecal colifonn and streptococci
problems, Bear Creek has levels of phosphates higher than recommended
for current goals for beneficial use. Table 1I-I data indicates that
less than seven percent of this potential pollutant comes from point
sources. The pollution problems that do exist on Bear Creek are caused
by non-point sources. The data cited for this discussion do not
include the effects of construction of Bear Creek Lake Dam near
Morrison, which probably is increasing suspended solids, TDS, and
stream bed sediment loads.
Cherry Creek Basin — The water quality problems in this basin,
other than fecal coliform and fecal streptococci, occur below Cherry
Creek Reservoir and are associated with high year round phosphate
and ammonia levels, and high peak levels of TDS during runoff events.
The Glendale treatment plant on Cherry Creek contributes significantly
to the base flow of Cherry Creek, which is in turn lowest during
winter. Most of the point source loads for ammonia and phosphate in
Cherry Creek come from the Glendale treatment plant. Point-source
loads account for 13 percent of total ammonia loads and 35 percent
of total phosphate loads in the Cherry Creek Basin. Removal of
phosphate from the Glendale treatment plant effluent would improve
water quality, but instream phosphate levels would still be high, and
potential water quality problems may occur. Removal of ammonia from
the plant effluent to below current small levels may be of limited
value without non-point source reductions. The high levels of TDS
during runoff events reinforces the conclusion that this is essentially
a non-point source problem. There is no current explanation as to
why peak TDS levels are highest on Cherry Creek. It is suspected that
the major source of TDS is Speer Boulevard, which parallels Cherry
Creek on both banks for over three miles downstream from Glendale.
Discharges of roadway runoff, carrying traffic generated pollutants
and deicing chemicals into Cherry Creek, may constitute a major non-
point source.
Sand Creek Basin — The water quality problems associated with
TDS, fecal coliform and fecal streptococci have been previously dis-
cussed and are principally a non-point source problem. The remaining
major and potential problems on Sand Creek involved ammonia, phosphate
and to a lesser extent BOD_. Table II-I shows that the point source
contributions are 20 percent, 18 percent and 2 percent, respectively,
of total basin loads on an average basis. However, during periods
of low or intermittent flow, point sources strongly determine water
quality in Sand Creek. The major point source on Sand Creek is the
Aurora treatment plant and it contributes significantly to water
54
-------
quality problems during base flow conditions. Effluent levels in 1972
for ammonia and phosphate were 10 mg/1 and 8 mg/1, respectively. Re-
ductions in these levels would benefit instream water quality, but
recommended levels would still be exceeded.
Clear Creek Basin — The major causes of water quality problems
associated with BOD5, ammonia, and phosphates are the point sources
discharging to Clear Creek. Water quality in Clear Creek is deter-
mined by a complex interaction of seasonal flow variations, divers-
ions, irrigation return flows and discharges from wastewater treat-
ment plants. Determining the importance of any one of these
influences in any detail is not possible with existing information.
Water quality modeling information from DRCOG's Clean Water Program
investigation is available only for the headwaters above Golden
and at the mouth of Clear Creek.
There are five wastewater treatment plants discharging to Clear
Creek. They are the Coors, Wheatridge, Clear Greek Valley, Arvada,
and Crestview treatment plants. In 1972, the Coors plant effluent
represented over 50 percent of total point sources loads for phos-
phates 12 percent for ammonia and 60 percent for BOD5- 1976 effluent
monitoring data indicates about the same percentages for phosphates
and ammonia, but that the BOD5 now represents about 40 percent of
total average daily point source loads.
The major diversions of irrigation water, some of which becomes
part of municipal water supplies, occur below the Coors plant. Further
downstream some additional diversions occur, but effluent from the
other four wastewater treatment plants and irrigation return flows also
occur. As a consequence, the influence of the Coors effluent on down-
stream water quality is seasonal, and is essentially significant only
during those periods of the year when irrigation water diversions are
small or non-existent (generally November through March). The data in
Table II-H illustrates this point. At the mouth of Clear Creek during
the winter of 1972, the level of phosphates was 3.2 mg/1; ammonia,
4 mg/1; and BOD,., 18 mg/1. During spring, summer and fall, these levels
were 1.4 to 1.7 mg/1 for phosphates, 1.2 to 1.5 mg/1 for ammonia, and
8 mg/1 for BODr. These decreases are due to increased flow in Clear
Creek causing dilution, instream processes which are temperature
sensitive and which reduce BOD5 and ammonia, and the upstream diversion
of most of the stream flow carrying Coor's discharged pollutants. Thus,
the downstream discharges from the other four wastewater treatment
plants are a major cause of poor quality in the lower half of Clear
Creek during spring, summer and fall.
South Platte — Point sources of BOD^, ammonia, and phosphate
clearly dominate over non-point sources in the South Metro portion of
South Platte River (upstream from Bear Creek). These loads come
from the Littleton and Englewood wastewater treatment plants. Although
55
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a new satellite plant to treat both Englewood and Littleton's waste-
water is now operating, these point sources will continue to
dominate water quality in this portion of the South Platte River.
In the South Platte, between Bear Creek and 38th Avenue (about
one and one-half kilometres [one mile] downstream from Cherry Creek),
non-point sources clearly dominate. The discharge from the South
Lakewood wastewater treatment plant does contribute significant quan-
tities of ammonia and phosphate, but the water quality is already
degraded because of discharges from the Littleton and Englewood
plants.
The impact of the discharge from the Metropolitan Denver Sewage
Disposal District No. 1 (MDSDD #1) plant on water quality is over-
whelming in the South Platte downstream from the Plant. This is not
surprising considering the fact that about 40 percent of the total
flow in the South Platte in 1972 was represented by the MDSDD #1 dis-
charge. The percentage becomes 60 to 70 percent during winter low
flow periods. As shown in Table II-I, pollutant loadings from the
MDSDD #1 plant represents about 75 percent of the total point and
non-point ammonia loadings in the entire Denver area. Comparable per-
centages for BOD5 and phosphate are 45 percent and 60 percent, respec-
tively. However, even if the MDSDD #1 plant discharged pure water,
instream water quality would not be adequate for State designated uses
of secondary-contact recreation and warm water fishery because of
pollutant contributions from other point sources and non-point
sources. The actual and potential pollutants of primary concern
would be ammonia, phosphate, fecal coliforms and fecal streptococci.
Biology
Human settlement in the plains area has greatly changed the
local ecology of the Denver area through alterations in land use and
the introduction of non-native vegetation and animals. Urbanization
to a great extent has removed many wildlife habitat areas from the
region. Despite these changes, several areas still retain much of
their original steppe community characteristics. Other areas,
modified by human land use, have actually replaced some previously
lost habitat and increased the diversity of the local environment.
These are special habitat areas which are important to plant and
wildlife ecology and do not tolerate great changes. A mapping of
these sensitive areas is shown on Map F.
Within the Denver area, sensitive biological areas are generally
associated with watercourses and bodies. While major river and
stream systems provide valuable wildlife habitat, the area's poor
water quality limits the populations and species diversity of the
area's wildlife. Channelization of streambeds has greatly reduced
this habitat along some stream sections. Gravel pit ponds, irrigation
56
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ponds, lakes and reservoirs provide important aquatic resting and
feeding habitats for waterfowl and shore birds. The fringe areas
of ponds and lakes, together with stream meanders, provide inter-
mittant marsh habitat for wildlife as well. Several heron rookeries
are located in protected areas. Cottonwood and willow groves create
gallery forests along watercourses which provide important wildlife re-
fuge areas and visual relief from the surrounding flat plains.
In the outlying areas, human activity is less intense and
many areas still retain much of their natural condition. Selected
prairie-grassland areas show examples of the native vegetation and
habitat prior to conversion to agriculture. Numerous prairie dog
towns are found in areas removed from human disturbance and invasion
by domestic animals. The historic range of the black-footed ferret,
which is protected by state and federal regulations, coincides
closely with its prey species, the prairie dog. The changing prairie
habitat and prairie dog control programs have indirectly, but strongly
affected the black-footed ferret by reducing its prey. Of the larger
grazing animals, mule and white-tailed deer are somewhat tolerant to
human presence and are often found in the lower foothills and grass-
lands area up to the periphery of developed areas. The formerly wide
ranging pronghorn antelope are found in the upland grassland and
prairie areas in the southern part of the study area. Elk and big-horn
sheep are generally confined to the higher elevation forest and bush-
land areas, but do descend to critical wintering areas in the foot-
hills during extreme winter weather conditions. Peregrine falcons,
an endangered species, have been occasionally observed in the moun-
tainous forest and brushland areas. The Denver plains area may have
some value as a feeding range for the species. Within Colorado,
the white pelican is considered endangered as a nesting summer resident.
White pelicans may be found at several reservoirs along the South
Platte River. River otters, which are on the state's endangered
species list, are very rare in Colorado and intolerant of human
presence. Scattered sightings in the past have been reported along the
South Platte River drainage in Weld County, outside of the Denver
area. It is unlikely that a breeding population is present today.
Endangered or threatened plant species, typified by those found
at White Rocks near Boulder, include Aspleniim andrewseii (a rare fern),
forktip three awn (Aifistida basiramea - a grass) and American potatoe
bean (Apios ameiricana - a legume).
Energy
In the Denver area nearly 75 percent of all petroleum products
are consumed by the transportation sector, compared to 50 percent
nationally. Petroleum products represent 42 percent of the total
energy supply utilized in the area, which is comparable to the
national percentage. The industrial, residential and commercial
57
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sectors of the economy have nearly 60 percent of their energy needs
supplied by natural gas. Natural gas supplies 41 percent of the
region's total energy demand, whereas natural gas supplies about 31
percent of national energy demand. Projected shortfalls in supplies of
natural gas may pose a constraint on growth, in the Denver region after
1980. In the long term, increased reliance on coal-based electrical
generation will force increased competition for available supplies of
water, especially Western Slope water, which are necessary for coal
mining and processing and air pollution abatement.
Historical Features
After becoming a part of the United States in 1803, as a result
of the Louisiana Purchase, the natural resources of the Denver region
attracted fur traders, gold miners, ranchers and farmers. Following
the discovery of lode deposits in the mountains during the mid and
late 1800*s, the region's population grew rapidly and the City of
Denver became a cultural, political and financial center. The region's
historical sites are concentrated and distributed in several areas
reflecting the influences of major events, such as the gold rushes
and statehood. Sites concentrated along the edge of the mountains
served as sources of supply and recreation for the mining populations.
The concentration of sites in the Denver downtown area developed as
Denver became the major supply point for the gold fields and even-
tually the state capital. Out on the plains, sites are situated
along the major cattle, stage coach and pony express trails, which
served the region before the advent of the telegraph and the railroad.
Individual sites, mostly farm and ranch houses, are scattered through-
out the plains area. The major historical sites in the Denver region
are mapped on Map G.
Outdoor Recreation Sites
Several types of recreation areas, such as the South Platte
Greenway, a proposed trail system along major streams linked to
the Greenway, and the Barr Lake and Barr Lake Duck Club, are located
near various existing and proposed wastewater facility sites (see
Map G). Some counties have acquired park and open space lands which
are to be developed as populations grow over the next fifteen or more
years. Numerous parks and open spaces are currently being planned
or proposed by the cities of Littleton, Denver, Lakewood, Wheatridge,
Arvada and Aurora. Major problems being experienced by the Denver
area's park agencies are vandalism and misuse of park and open space
areas. These problems may become more difficult to deal with in
the future as service areas become larger and uses become more
intense. The recreational potential of most streamside parks, hiking
trails and bicycle paths is limited by current water quality problems.
58
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Aesthetics
Amenities which make a strong contribution to the Denver region's
quality of life include: the temperate arid climate; visual relief
from the high plains topography by the abrupt face of the Front Range,
recreational potential of the Rocky Mountains; landscaped and semi-
natural areas within the urban area; open space areas surrounding
the city; and social, cultural and economic institutions which strongly
govern urban life styles. Of these, visual and open space amenities
are the least well-defined and also the most susceptible to change.
Visual perceptions range from panoramic background views, to areas
of immediate perception, to distinct scenic or contrasting features.
Further high-rise development in the central business district and
commercial activity centers can significantly alter these perceptions.
Examples of well-known scenic features within the Denver region are
shown on Map G.
Land Waste Disposal and Reuse
In many areas, sludge, the treated solid component of sewage,
is sold or applied to city-owned parks and other green areas as a
soil conditioner, or disposed in landfills. The largest producer
of sludge in the area, the Northside/MDSDD #1 wastewater treatment
complex, dewaters undigested sludge to reduce its volume and trucks it
to the Lowry Bombing Range where it is mixed with soil. Because of
the high volume of sludge disposed at the range, this practice must
be discontinued in the near future, and alternative plans are now
being developed.
Improvements are under way and plans are being made to remedy
the treatment complex's sludge disposal problems. Anaerobic digesters
are being constructed at the MDSDD #1 plant that could eventually
reduce the volume of sludge and make it more acceptable for land
application. A long-range plan is being considered to transport
sludge via pipeline to a drying distribution site in western Adams
County (see Figure II-J) for drying and subsequent sale to farms in
the area. EPA has issued a final EIS on this plan.
Direct and indirect reuse of treated wastewater for urban and
agricultural irrigation already occurs in the Denver region. Direct
reuse is the direct conveyance of treated wastewater from the treat-
ment plant to point of use. Indirect reuse involves the discharge
of treated wastewater to a stream which is subsequently diverted by
downstream users. The waters of the South Platte are used many times
by municipalities and agriculture before reaching the Nebraska State-
line, a situation not uncommon on most major rivers of the United
States. About 25.7 million cubic metres (20,800 acre feet) of treated
wastewater is currently directly reused. The vast majority, about
2.5 million cubic metres per year (19,900 acre feet), is used for
59
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-------
agricultural irrigation after diversion from the MDSDD #1 plant
to the Burlington Ditch by the Denver Water Board. This diversion
represents about 14 percent of the total yearly discharge of the
plant. A portion of the effluent conveyed to Barr Lake contributes
to the water quality problems of that recreational and wildlife
area. The remaining 1.1 million cubic metres (900 acre feet) is
used for urban irrigation of parks and golf courses. The cities of
Northglenn and Westminster are currently completing arrangements for
direct reuse of treated wastewater for agricultural irrigation in
exchange for upstream diversions of water for municipal use. Also,
Denver is planning to construct a 0.04 cubic metre per second (1.0
million gallons per day) pilot treatment plant for producing potable
water from wastewater effluent. Ultimate plans are for a 4.4 cubic
metre per second (100 million gallons per day) plant if safety consi-
derations and public acceptance permit.
All reuse schemes are, in effect, a means of increasing water
supply. They may also have the potential of improving stream water
quality by diverting relatively polluted discharges from streams to
some reuse, such as irrigation. Water quality "benefits" are some-
times difficult to define because a substantial portion of the flow
in a particular stream, such as Cherry Creek, may depend on point
source discharges. Benefits from improved quality in terms of pol-
lutants may be offset by diminished flow. The communities in the
Denver region are interested in reuse schemes because they stretch
or augment existing water supplies. This interest will continue
and intensify.
Traffic
In 1974, 97 percent of all intracity trips in the region were
made by automobile. The existing highway system becomes overloaded
at peak traffic times in several areas, and the situation is expected
to worsen due to further population growth, and suburban development
patterns and situations. The nature of these overloaded conditions
is generally a reduction of traffic flow speeds by 16 to 48 kilo-
metres per hour (10 to 30 miles per hour). The "linear parking lot"
traffic jam situation is not as common in Denver as in cities such
as New York and Los Angeles. Some of the major highways and arterials
presently experiencing rush hour overload conditions include:
1. Broadway from the Central Business District
(CBD) to Englewood.
2. 1-25 (Valley Highway) from the Denver-Boulder Turnpike
Interchange south past U.S. Highway 6.
3. The I-70/I-25 interchange, nicknamed the "mousetrap".
61
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4. Federal Boulevard, Speer Boulevard, Alameda Avenue, and
Santa Fe Drive as they approach the inner city.
5. Wadsworth Boulevard, Hampden Street, Sheridan Boulevard
and Colorado Boulevard as they approach the major thorough-
fares carrying traffic in and out of the CBD.
Present attempts to remedy traffic problems include further highway
construction, such as that being planned in the southwest area of
the region to relieve traffic congestion. Also, the Regional Trans-
portation District (RTD), the Colorado Department of Highways (CDH)
and DRCOG are in the process of developing a transportation system
management plan that will make better use of the existing trans-
portation system. Such things as ramp metering and preferential
treatment of high occupancy vehicles are only two of many strategies
being .investigated to help conserve energy and improve air quality.
Plutonium Contamination and Radiation Hazards
The extent and significance of soil and airborne contamination
caused by the plutonium processing plant at Rocky Flats is under
intense investigation by state and federal agencies. Various agencies
are concerned that plutonium contamination may have occurred as a
consequence of the fire at the Rocky Flats Plant in 1969. The trans-
port of plutonium contamination easterly from the plant is known to
have occurred. Whether contamination levels are hazardous to human
health has not been decisively determined. Investigations are now
underway to determine the extent of contamination of the ground surface,
Great Western Reservoir, Standley Lake, and whether wind pickup of
surface contamination represents a hazard. Ultimately, certain land
areas generally east of Rocky Flats may be banned from residential
development.
The Colorado Health Department (CHD) is currently investigating
the radioactive material content of wastewater treatment plant dis-
charges and sludges. CHD is concerned that radioactive materials may
be entering wastewater treatment systems from sources such as hospitals
and universities, as well as some industries. CHD is also concerned
about the possible contamination of water sources by runoff from
uranium mining areas in the mountains.
SOCIO-ECONOMIC ENVIRONMENT
The term "socio-economic" embraces all of those conditions and
activities that relate to man's habitation and use of his environment.
Housing, employment, community services and facilities and the
62
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institutional structure, through which demands for these goods
and services are communicated, all form a part of the socio-economic
setting. This section presents first basic data on the regional
economy, population and land use. Subsequent sections discuss
community services and facilities, agricultural land use, and
regional planning policies.
Regional Economy, Population and Land Use
The Economy —
The Denver region enjoyed significant economic expansion in
the past three decades, and particularly in the 1960's. Employment
in all major nonagricultural sectors of the region's economy grew
at a faster rate than in the nation during the second half of the
1960's, and is expected to continue to surpass national growth
through the 1970's (Reference 905). During the 1940-1970 period,
employment in the five-county Denver region increased at an average
rate of 3.7 percent per year, while state and national employment
grew at rates of 3.0 percent and 1.7 percent, respectively (Reference
259). In 1970, about 60 percent of Colorado's employment was located
in the five-county Denver region.
In 1975, nonagricultural employment in the Denver region numbered
about 661,400. About 65 percent of these jobs were concentrated in
three sectors; trade, services and government (including military).
Denver's economic mix is more strongly concentrated in the service-
producing sectors than in the goods-producing sectors. In the U.S.
as a whole, 23.8 percent of nonagricultural employment is in manu-
facturing; in Denver, the comparable proportion is 14.3 percent
(Reference 999 and 259). However, a few manufacturing activities are
significant exceptions. Machinery, electrical products, luggage and
rubber manufacturing are considered major contributors to the "exports"
of the Denver region; that is, economic activities which result in
the sales of products to markets outside the region. With these
exceptions, however, most of Denver's export activity is in the
service sectors: TCU (transportation, communications and utilities),
trade, services and FIRE (finance, insurance and real estate).
Employment concentration in these sectors reflects Denver's role as
a regional finance and distribution center for the Mountain States.
Recent trends in employment suggest that strength in the service
sectors is becoming more marked. While there has been significant
growth in all economic sectors since the mid-1960's, growth in trade,
FIRE and services has been much more rapid than in manufacturing, as
Table II-J indicates. However, construction employment continues to
grow quite rapidly - a tangible indicator of growth in all sectors.
63
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Table II-J. RECENT TRENDS IN NONAGRICULTURAL EMPLOYMENT BY
SECTOR IN THE FIVE-COUNTY DENVER REGION
Sector
Mining
Construction
Manufacturing
TCU (transportation, communications
and utilities)
Trade
FIRE (finance, insurance, real estate)
Services
Government (including military)
Total Nonagricultrual Employment
Annual Growth
1964-70
2.8
3.6
4.7
3.0
4.5
4.1
5.9
4.4
not
tabulated
Rates, %
1970-75
5.7
5.6
1.7
2.3
4.8
6.9
5.4
3.9
4.2
Current
Employment
7,800
42,500
94,700
42,100
161,600
44,900
143,400
124,400
661,400
Source: DRCOG. Figures for 1964-70 cited in Reference 304 and figures for 1970-75 cited
in Reference 259.
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A significant recent trend in employment growth is in the mining
sector. This sector includes extraction of minerals occuring naturally
(coal and ores, liquid petroleum and natural gas), quarrying, well oper-
ation-exploration and development, and related off-site employment.
Much of the recent growth in the Denver region's downtown office
employment is reportedly in the extractive industries, with a number of
major firms using Denver as the base from which to supervise exploration
and energy development activities in the Mountain States. This trend
has been experiencing very low vacancy rates; downtown office construc-
tion is expected to continue to prosper, at least in the short run
(Trenka, personal communication).
The distribution of employment among the counties of the region
has been changing over time: as the four outer counties have urbanized,
the City and County of Denver has represented a decreasing share of
the region's employment. Figure II-K depicts shifts in county shares
graphically.
Population —
In recent years, Denver has been one of the nation's fastest
growing metropolitan regions. During the 1960's, the Denver Metro-
politan Area grew annually between 3 percent and 4.6 percent, consi-
derably more rapidly than the state's 2.3 percent average annual
growth. Over half of Colorado's population lives in the five-county
region (Reference 304). Figure II-K presents a graphic depiction of
distribution of the region's population by county in 1960 and 1970.
Table II-K presents demographic characteristics of the Denver region's
population in 1970.
Population growth is composed of two elements: the excess of
births over deaths, (net natural increase) and the excess of in-
migrants over out-migrants. While death rates remained fairly stable,
birth rates have dropped over 40 percent since 1960. A majority
(60 percent in 1975) of the total population increase in the Denver
region is attributable to net in-migration. Table II-L presents
county estimates of population change of both types in 1975.
In the period from 1940 to 1970, annual net in-migration to the
region averaged 15,000 (Reference 401). Recent years have seen the
suburban counties - particularly Jefferson - attracting the lion's
share of net in-migrants, as Table II-M indicates. It should be kept
in mind, however, that net migration figures do not reflect total
movement. The City and County of Denver may be receiving a large
absolute number of newcomers, but its loss of residents to the
suburban counties may exceed the number of new residents it receives
from outside the region, at which point its absolute population
declines.
65
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EMPLOYMENT
POPULATION
I960
1970
1960
1970
ON
t - ADAMS
2 - ARAPAHOE
3 - BOULDER
4 - DENVER
5 - JEFFERSON
"EXCLUDES EASTERN ADAMS AND ARAPAHOE COUNTIES
AND WESTERN BOULDER COUNTY. SOURCE: REF. 262.
REGIONAL EMPLOYMENT
AND
POPULATION BY COUNTY3
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Table II-K. DEMOGRAPHIC CHARACTERISTICS OF THE DENVER SMSAC
POPULATION, 1970
Family Income Age
Number of
Income categories Families Percent
Less than
$3,743b 20,572 6.8
Less than
$4,999 43,172 14.2
From $5,000
to $14,999 185,713 61.0
Mo re than
$15,000 75,580 25.0
Median $10,777
.Categories
Less than 15
Less than 19
From
20 to 54
Older
than 55
Older
than 65
Median 26.5
Distribution
Number of
Persons Percent
362,195 29.5
477,904 38.9
564,078 46.0
185,547 15.1
95,046 7.7
Ethnic Distribution
Ethnic Number
Group of Persons Percent
White 1,021,477 84.6
Spanish
surname 138,928 11.3
Black 50,159 4.1
a. The Denver Standard Metropolitan Statistical Area (SMSA) includes Adams, Arapahoe, Boulder and
Jefferson Counties.
b. Poverty level.
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Table II-L. COMPONENTS OF ESTIMATED RESIDENT
POPULATION CHANGE, 175
County
Adams
Arapahoe
Boulder
Denver
Jefferson
TOTAL
Births
3,721
2,880
1,965
6,468
4,289
19,323
Deaths
1,110
1,060
879
4,918
1,578
9,545
Net Natural
Increase
2,611
1,820
1,068
1,550
2,711
9,778
Net In-
Migration
389
5,280
3,614
-4,950
12,711
16,622
Total
Increase
3,000
7,100
4,700
-3,400
12,289
26,400
Source: Reference 208
Table II-M.
DISTRIBUTION OF NET IN-MIGRANTS
TO FIVE COUNTIES, 1970-1972
Year
1970
1971
1972
Adams
County
20.0%
19.5
13.3
Arapahoe
County
18.2%
24.1
25.9
Boulder
County
13.8%
16.4
16.5
Denver
County
2.3%
2.7
1.5
Jefferson
County
45.7%
37.3
42.8
Source: Reference 128
The general pattern of population change in the region has been
that of a central city (Denver) representing a declining proportion
of the region's population. Since 1960, the population of the City
and County of Denver has grown more slowly than at any other time in
the twentieth century. One study points to the increasing resemblance
between Denver's patterns of population change and those of older
urban core cities, especially in the East and Midwest.
The overall picture presented is one of Denver
as an aging urban core city increasingly popu-
lated by the poor; less educated; the minorities;
the less easily employed; the elderly; and the
working young adult households. It is also one
of Denver surrounded by a solid suburban ring
populated by the white majority; the affluent;
68
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the better educated; the family households with
children and with adults in their most productive
years; and the higher skilled and more easily em-
ployable. (Reference 905)
In-migrants to Denver tend to be the elderly, minorities, and
young adults; this pattern may be accompanied by higher unemployment,
lower levels of educational attainment and lower household incomes.
The pattern will cause the existing social dochotomy between core city
and suburb to become more pronounced over time. However, there are
some indicators that the "white flight" to suburbia is slowing with
more affluent families moving back to the city center.
Land Use —
The most striking characteristic of regional land use is its
dispersed pattern and low density. In the City and County of Denver,
population density was about 3,37J persons per square kilometre
(5,418 persons per square mile) in 1970, with about 125 persons per
square kilometre (200 persons per square mile) in the four suburban
counties for an SMSA average of 210 persons per square kilometre
(335 persons per square mile). Of the 34 metropolitan regions hav-
ing populations exceeding 500,000 in 1970, only five (Dallas-Fort
Worth, Houston, San Diego, Riverside-San Bernadino, and Portland)
had lower densities. In fact, population density in the Denver re-
gion was less than that in many suburban counties of other regions.
Isolation from other urban areas, preference for open space and
the high mobility made possible by the extensive highway network
are reasons given for the overall suburban density of this urban
region (Reference 304).
Growth in recent years has shifted the distribution of many land
use categories from the City and County of Denver to the outlying
counties. In the case of single-family residential, the regional
concentration of this development shifted to Jefferson between 1960
and 1970. Multi family housing, too, has increasingly been a subur-
ban phenomenon, and retail/service commercial activity has followed
the shift in population. Suburbanization of major industry has begun
recently and is expected to continue (Reference 905). Agricultural
land use declined by about 9 percent; this decline is discussed in
Section IV. Table II-N presents a land use tabulation by county for
1960 and 1970.
Many local officials have observed that land use patterns in
the region have thus far developed more in response to economic
pressures than as the result of conscious planning. This has occurred
in part because existing zoning is in conflict with the regional plan:
while a regional population forecast of 2.35 million has been adopted
DRCOG found in 1972 that the population holding capacity of zoned
land exceeded six million. The study of existing zoning concluded
that the region was greatly overzoned: "at present, every city and
69
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Table II-N.
COUNTY LAND USE SUMMARY,
(1000 acres)
1960 AND 1970
County*
& Year
Adams
1960
1970
Change
Arapahoa
1960
1970
Change
Boulder
1960
1970
Change
Denver
1960
1970
Change
Jefferson
I960
1970
Change
Total3
1960
1970
Change
Single-
family
6,266
9,947
+ 59*
6,688
11,797
+76*
5,935
9,773
+65*
15 , 146
16,918
+12*
11,325
18,148
+60*
43,360
66,585
+47%
Multi-
family
265
928
+250%
343
653
+90*
382
951
+149*
2,306
2,998
+30*
411
892
+117*
3,707
6,422
+73*
Commer-
cial
482
994
+106%
360
760
+111*
564
910
+61*
1,253
1,672
+33*
638
1,338
+110%
3,297
5,674
+72*
Ser-
vices
54
177
+228*
120
310
+158*
72
153
+112*
539
613
+14*
951
966
+2%
1,736
2,219
+28%
Industrial,
Transporta-
tation & Com-
munications
10,813
14,155
+ 31%
7,990
10,190
+27%
7,510
9,236
+23*
19,781
23,000
+16*
13,738
17,834
+30*
59,832
74,415
+247.
Parks &
Recrea-
tion
320
1,173
+267%
4,642
5,187
+12*
46,897
47,781
+2*
3,079
3,559
+16*
125,497
128,127
+2%
180,435
185,827
+3*
& Semi-
public
18,676
18,642
0*
13,077
7,760
-41%
3,128
3,781
+21%
4,802
3,813
-21*
6,059
6,648
+10*
45,742
40,644
-11*
Agricul-
tural
189,542
177,241
-6%
80,161
74,923
-6*
138,958
133,867
-4%
7,403
1,985
-73*
76,867
71,335
-7%
492,931
459,351
-7%
Vacant
16,590
19,751
+19*
13,428
15,229
+13%
79,474
76,466
-4*
9,122
8,873
-3%
262,680
252,878
-4%
381,294
373,197
-2%
Total
243,008
126,809
282,920
63,431
498,166
1,214,334
a£xcludes western Boulder and eastern Adams and Arapahoe Counties.
Source: Reference 205
-------
county has zoning far in excess of that needed to accommodate its
present population" (Reference 258). See Map H.
Under these circumstances, zoning has not been an effective
tool in implementing land use planning. Much of this overzoning is
reported by local jurisdictions to have been the result of pre-zon-
ing when annexations took place. As a practical matter, rezoning
cannot easily be accomplished until the land is proposed for develop-
ment, and even the rezoning may not be possible. Many local public
officials interviewed in the course of this study expressed the view
that a state law requiring zoning to be consistent with comprehensive
planning would help to solve this problem; however, some also pointed
to the common acceptance of the zoning map as the community compre-
hensive plan. No ready solution to the over-zoning problem was
identified.
Community Services and Facilities
A wide variety of government services are provided by local
jurisdictions in the Denver region. These jurisdictions include 25
municipalities and 201 special service districts within a four-coun-
ty area of the region (Adams, Arapahoe, Denver and Jefferson Counties).
A recent study of taxation and finance in the region (from which the
data in this section are taken) found that these jurisdictions spent
approximately $920 million in 1974 ($747 per capita) as compared with
total revenues to the State of Colorado of $958 million in fiscal
year 1974-1975 (Reference 987).
The major local cost is for public education, which ranges from
$232 (Denver) to $320 (Arapahoe) per capita; total county per capita
expenditures (that is, total expenditures of all local service agencies
and municipalities within county boundaries) ranged from $571 (Jeffer-
son) to $835 (Denver) per capita. The service ranking second in per
capita cost is water and sewerage. For a number of reasons, includ-
ing the fact that costs paid to private water and sewerage agencies
are not included in the estimates of public costs, average water/
sewerage costs were found to vary widely throughout the Denver region.
Compared to a regional average of $70 per capita, the county averages
(1974) are $92 (Adams), $75 (Arapahoe), $60 (Denver), and $48 (Jeffer-
son). Among municipalities, even greater variability was observed:
Commerce City has per capita water/sewerage costs of $142; Englewood,
$93; Golden, $66; Arvada, $46; and Wheatridge, $28.
The Denver Metropolitan Study report on finance and taxation
(Reference 1005) considers several issues related to revenue, expendi-
ture and service delivery organizations. On the question of distri-
71
-------
butional equity (taxation burden relative to ability to pay) the
study found that the City and County of Denver, with 43 percent of
the population in the four-county area of the region, accounts for
42 percent of the gross personal income. "This suggests that on the
aggregate, the City/County is not seriously disadvantaged in terms
of ability to pay as measured by gross personal income1'. The study
did point to a disparity among counties in terms of personal income
per capital; Arapahoe, $4,994; Jefferson, $4,718; Denver, $4,260;
Adams, $3,516. "The real disparity within the region is between
Adams County and the other three counties".
A second important issue is that of the organization of service
delivery. The 201 special districts in the four counties account
for 10 percent of all local revenues. Because these districts cut
across municipal, county and other special service district boundar-
ies, they make efficient planning and administration of services
extremely difficult. Even obtaining information from such districts
(one-third have no paid staff) proved very difficult to the Metro-
politan Study research team. The study concluded that fractionated
districts (1) make accountability uncertain; (2) result in higher
costs; and (3) involve double taxation. It is the special district
system which is responsible for the wide variation in municipal
property taxes, with the resulting unevenness in the cost of public
services to individual taxpayers.
Table II-O presents a summary of user and service charges im-
posed by the local agencies proposing new wastewater facilities.
Agricultural Land Use
There are three terms, frequently used in analyzing the effects
of urbanization on agriculture. They are "agricultural land",
"prime agricultural soils" and "prime farmland". Agricultural land
is a term most frequently used by land use planners and generally
refers to any land being used for agricultural purposes. This
could be anything from hilly range land to irrigated truck farms.
Prime agricultural soils are land areas which have all the necessary
physical, chemical and topographic characteristics, except suffi-
cient moisture, to support high-quality agricultural production.
Within the context of the arid Denver region, prime farmlands are
areas of prime agricultural soils under irrigation. The distinction
between prime agricultural soils and prime farmland is made in this
EIS because of the need to identify potential as well as existing
highly productive agricultural resources. Land is an in-place
resource whereas the water required to fully use the land resource
is relatively transportable.
72
-------
Table II-O. SUMMARY OF AVAILABLE INFORMATION ON USER CHARGES
bJ
_ _
Facility Plan
Agency serv.ftx1 arfM/|rmjt'Ct
Sou til Vlanis County Koutli Adams
VnL^r .ind Rnn!f:.'i-
M.ni District
<:ft.v of Littleton
U ttlRtrMX/linjlU'Wiod
city oi: Kn".!owoo.l
City and County of Cherry Cr«-.:l Dry Crf'^k
"''i!f.f,. reive 976 and ''i-ffercuc..- 13", IM/i1; ':rr
GCDPW.
User ch.nr^e rate structure
Service charge lap fee
Ke:iid<;iiti.i.l Cm-mv.rclfil Industrial Residential Commercial
^2.80/moa v2.HO/mr>a + [iHrcent of $235/unHa per unit™
:15°< of water niolereil water
chnri'.on above consumption
$2.75/noa SJ.7ri/mo^ par ncLer nljir'1 S.lOO/unit" per sq ftb
7, of water cipilvalent or nepoti-
htllb tlwc-lHiiR unit ateJ
il.25/moa ?1.25/mu" ~. of v:U.er S300/unlta per sq ft^
within city hill »r ncrcnp.e
$1.75/mob
c Ity
101% of 'y'i'!. of water 150* ol water $.iOO/imitfl f-
water rate6 l)liln rate plus
water rate « surcharuif
$.49/1,000
•n.ri()/mob ppr unit" + per unltb + SSSlO/unit'1 per unit1'
/', of water 7. of water
hill. 1)111
$.65/1000 negotiable ne|',ot.i,-]ble $720/tmita per plpn
gnl./mn. contract contract slxe
nori'1 nrMic- none $^Ul/unit -
fercucp ')!;*, l'.'7r»; ^jicrsotin 1 i.-oriimniicat ioa, John Krus, -I Ftbmary 1;J77
Industrial Remarks
per unitb received ^ 47.0? of
(negotiable) revenue from mill
levy in 1972b
negotiated
pel' sq ftb
or acreage
f.
MDSDDC1 charges
user on following
basisc:
flow @ 45.51%
BOU @ 30.88%
SS 9 23.61%
per unltb
per pipe
size
A.16-mlll levy for
general revenue
. ejn effect as of 31 Uec. 73
f
f.,,
T;ip fees ;iri' Kt;l pcT r.iu- scli<.-du It- «H tk'vel <>i>fd l>y I !><• i'hiii.iRi'r "I" 1'uMlc Unrks.
-------
Land in Agricultural Use —
The fringes of the Denver Metropolitan Area contain a great pro-
portion of highly productive farmland. Soils are generally deep,
friable, well-drained, flat and fertile. Table II-P shows a total
of 122,130 hectares (301,790 acres, 1973) of land in the agricultural
areas likely to experience growth pressures before the year 2000.
The figures shown are for DRCOG's "empiric counties", i.e. those
urban and urbanizing portions of the political counties in the region
which provide the areal basis for population projections. Of the
122,130 hectares (301,790) total shown in Table II-P, 35,600 hectares
(88,000 acres) have been identified as prime farmland (Reference 265).
Table II-P. 1973 ESTIMATES OF AGRICULTURAL ACREAGE BY
EMPIRIC COUNTY IN THE DENVER REGION
County
Adams
Arapahoe
Boulder
Denver
Douglas
Jefferson
Weld
TOTAL
Rangeland
10,750
38,940
30,000
3,470
41,540
124,700
Non-Irrigated
Cropland
16,070
20,550
10,950
1,100
No Available
10,750
No Available
59,420
Irrigated
Cropland
32,790
830
74,120
2,510
Data
7,420
Data
117,670
Total
Agricl.
Landsb
59,610
60,320
115,070
7,080
59,710
301,790
Empiric County boundaries designated by DRCOG, 1973.
3Total agricultural lands within Empiric Counties (Reference 257)
74
-------
Table II-Q shows a total of 158,650 hectares (392,040 acres) of
existing agricultural lands in the region beyond the boundaries of
the empiric counties. More simply stated, Table II-Q is an estimate
of agricultural lands in the region which are generally, but not
exclusively, beyond the leading edge of the urbanizing fringe.
Table II-Q.
1973 ESTIMATES BY POLITICAL COUNTY OF
EXISTING AGRICULTURAL LAND WITHIN THE
REGION'S MAJOR DRAINAGE BASINS, aBUT
OUTSIDE THE EMPIRIC COUNTY BOUNDARIES
County
Adams
Arapahoe
Boulder
Denver
Douglas
Jefferson
Weld
TOTAL
Rangeland
0
0
51,300
0
137,560
41,140
1,430
231,430
Non-Irrigated
Cropland
2,790
24,130
8,230-
0
34,960
10,300
3,540
84,050
Irrigated
Cropland
41,470'
11,410
4,120
0
7,700
1,720
9,240
75,660
Total
Agricl .
Lands
45,260
35,540
63,650
0
180,220
53,160
14,210
392,040
aMajor drainage basin boundaries designated by DRCOG, 1973
Total agricultural lands outside of empiric counties, but within
the region's major drainage basins (Reference 257).
Using published and other available soils information, the
lands with prime agricultural soils, i.e. those lands having the
fewest limitations for various agricultural uses, were mapped as
shown on Map D. This map was prepared principally for regional
impact assessment. Criteria used to determine prime soils included
the U.S. Soil Conservation Service soil capability rating and pre-
dicted crop yields. They did not include such site-specific
75
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variables as economic feasibility and value, land ownership, avail-
ability of irrigation water, and energy requirements for crop pro-
duction. These criteria for both irrigated and dryland operations
were mapped as accurately as the available soil maps permitted.
Areas currently in urban development were excluded from considera-
tion. However, current zoning and political boundaries did not
influence the mapping.
The Economic Value of Agricultural Activity —
Denver is a major agricultural and livestock trading center.
Beef cattle dominate the livestock market, while major crops include
alfalfa, small grains, corn and sugar beets (Reference 104). Agri-
culture accounts for 6 percent of the region's employment (as com-
pared with 3.5 percent of the nation's employment) (Reference 994
and 995). In terms of crop values, the most important single crop
is winter wheat, which in 1974 accounted for almost 43 percent of
the value of regional crops as indicated in Table II-R.
Table II-R. VALUE OF CROP POPULATION BY COUNTY, 1974
(in 000*s of Dollars)
County
Adams
Arapahoe
Boulder
Jefferson
TOTAL
Source :
Winter
Wheat
13,329.
4,070.
706.
293.
18,399.
0
0
6
4
0
Reference
Corn (Grain
& Silage)
3,458.0
394.3
3,357.0
136.0
7,345.3
984
Hay
2,359
718
2,219
829
6,126
.5
.1
.0
.5
.1
Sugar
Beets
1,333.0
2,390.0
3,723.0
All Other
Crops
3
2
7
,866.
601.
,694.
369.
,530.
2
5
2
0
9
Total
24
5
11
1
43
,345.7
,783.9
,366.8
,627.9
,124.3
Agricultural activity in the region creates jobs in other sectors
of the economy, as Denver region firms in such sectors as manufactur-
ing, finance and trade provide goods and services to agriculture. One
study traced the economic effects of agricultural activity on irrigated
lands in Adams County and found that 100 agricultural jobs create the
demand for 82 nonagricultural jobs, with the majority of these in the
manufacturing and service sectors (Reference 986). This estimate in-
cludes only the direct economic effects of agriculture; it excludes
jobs generated within each nonagricultural sector due to demand by
76
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other nonagricultural sectors for goods and services needed to meet re-
quirements of agriculturalists. If all these inter- and intra-sectoral
economic linkages were quantified, the result would be an estimate of
an agricultural "multiplier" for the Denver region: a measure of the
total economic impact of regional agriculture on the regional economy.
No research on this subject was found; however, for the State of
California, an agricultural multiplier has been estimated as between 3
and 4, meaning that for each $1 of agricultural production, the state
enjoys $2 to $3 of additional economic product related indirectly to
agriculture (Reference 991).
Future Prospects for Regional Agriculture —
Denver's role as a regional center of finance and trade will
permit it to continue to capture agriculture-related jobs in non-
agricultural sectors, even as agriculture activity becomes increas-
ingly distant from Denver due to urbanization and other factors.
Loss of agricultural employment in the five-county regions is a
reasonable expectation. DRCOG forecasts that this decline will be
the order of about 12 percent between 1975 and 2000 (Reference 259).
This need not necessarily mean loss of production, as historically
productivity increases have more than made up for reductions in farm
labor. However, loss of agricultural land or water supply to urban
uses may result in a decline in agricultural output.
MUCH of the Denver region's growth since 1950 has taken place
on land formerly in agricultural production. In Adams and Arapahoe
Counties in the 1960's, about 56 percent of the gross addition to
urban land came out of the cropland category (Reference 719). Not .
withstanding the conversion of agricultural land to urban uses, the
total area in cropland did not decline, because land and other open
land categories (primarily pasture and range land and open idle
land) was converted to cropland. However, total land in the agri-
cultural category did decline 13,510 hectares (33,580 acres) or 7
percent. Similar patterns have been noted in other regions (Refer-
ence 719 and 127).
Indirect effects of growth are causing further pressures.
These indirect pressures are manifested principally through in-
creases in the cost of water and the increased demand for water by
municipalities. This latter point is illustrated by the current
condemnation proceedings initiated by the cities of Thornton and
Westminster to affect conversion of agricultural irrigation water
rights to municipal use. Loss of waeer would probably result in
the conversion of irrigated cropland back to dry land farming and
grazing, increased land speculation, and an overall decrease in pro-
ductivity and amount of land in agricultural production. Coupled
with these pressures, the current drought, and the unsatisfactory
returns on cultivated land farmers have experienced in the last few
years are causing serious difficulties for the agricultural sector
of the region's economy. The prognosis is not favorable.
77
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Regional Planning Policies
Regional planning for the Denver Metropolitan Area has had an
interesting and sometimes even turbulent history. Until re-
cently, land use and transportation planning were done jointly by
an organization known as the Joint Regional Planning Program or JRPP.
The three participants in this program were the State Division of
Highways (CDH), the Regional Transportation District (RTD), and the
Denver Regional Council of Governments (DRCOG). Early in 1977, the
DRCOG was designated as the Metropolitan Planning Organization by
the Governor and, as such, is now responsible for transportation
planning. Additionally, DRCOG has had a history of being the re-
gional land use planning and population forecasting body, and also
provides many other regional planning functions. The Denver Regional
Council of Governments represents 37 local governments throughout
the metropolitan area. In 1973, DRCOG adopted a year 2000 regional
land use plan (see Map I) along with a set of policies which outline
the population and land use guidelines for growth in the region.
One of the most significant of these policies is the statement that:
"A population level below 2,350,000 should be encour-
aged for the Denver Metropolitan Statistical Area by
by year 2000".
The DRCOG issued in July 1977 for public discussion, a Draft
Regional Growth and Development Plan which is intended as a refine-
ment and restatement of the current Regional Land Use Plan. Action
on the draft plan is not expected until March or April 1978. The
draft policies from the draft plan are included as an appendix to
Volume 1 of this EIS. Various approaches to implementing the Draft
Plan were analyzed in a separate Implementation Prospectus issued
in September 1977. The most feasible appeared to be the creation
of a metropolitan/policy making organization which would supercede
DRCOG, but be governed by a body of directly elected and appointed
locally elected public officials.
The Council of Governments is also the designated agency respon-
sible for water quality management planning in Denver under Section
208 of the Federal Water Pollution Control Act of 1972. In develop-
ing the Clean Water Plan, the DRCOG adopted an allocation by muni-
cipality of the year 2000, 2.35 million population forecast.
Another agency responsible for regional water planning in the
metropolitan area is the Urban Drainage and Flood Control District.
The Flood Control District is responsible for comprehensive and pro-
ject planning for urban flood and runoff control to safeguard the
public and property. The District was formed by the state legis-
lature in 1969. Although responsible for flood control for urban
runoff events, the District has been reluctant to assume responsi-
bility for urban runoff water quality.
78
-------
Presently, no single agency is responsible for regional planning
of water supplies for Denver. However, the Denver Water Board pre-
sently supplies nearly two-thirds of the municipal raw water used in
the region.
The Regional Transportation District (RTD), which was formed by
the state legislature, has the responsibility for improving bus
service within the region and for developing a new fixed-line transit
system for metropolitan Denver.
The Colorado State Government also has an important role in
planning and policy-making which directly effects the Denver region.
The State Division of Highways is responsible for many areas relating
to transportation planning in Colorado and Denver, including road
improvements and construction.
The Colorado Division of Planning serves as an advisory and
coordinating agency. It was created within the Department of Local
Affairs, to, among other things, prepare planning:
"For meeting problems in areas of highways, air and
water pollution, water supplies, sewage disposal,
recreation, urban and non-urban growth, transpor-
tation, education, industrial and commercial develop-
ment and related matters".
In addition, the Colorado Land Use Act established within the
Office of the Governor, the Colorado Land Use Commission in order
to provide the leadership to encourage planned and orderly land use
development. In a related matter, Governor Lamm issued a policy
statement on growth in Colorado in 1976. Probably the most signifi-
cant portion of this policy, relevant to this EIS, is that relating
to future growth. The three most pertinent objectives of this
policy are moderating net in-migration into the state, encouraging
economic growth in areas other than the Front Range, and minimizing
urban sprawl.
Planning for air quality is the responsibility of the Air
Pollution Control Commission and the Air Pollution Control Division
(APCD) of the Colorado State Health Department. The APCD is in the
process of developing an air quality maintenance plan for the Denver
area. This work will be closely coordinated with other planning
agencies through the policy bodies of these various agencies.
Obviously, such cooperation is a necessary prerequisite for develop-
ing an implementable air quality attainment and maintenance plan,
since it requires assumptions as to future population, land use and
transportation modes.
79
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The State Water Quality Control Commission is the central
authority in all matters pertaining to water pollution control in
the state and the Denver region. The Commission sets water quality
standards and classifies waters of the state for various beneficial
uses. The Water Quality Control Division of the Department of Health
is the administrative arm for water pollution control activities.
Their principal responsibilities include: state water quality plan-
ing, administration of discharge permits, enforcement of water qual-
ity regulations, and review of applications and plans for new waste-
water treatment plants.
PUBLIC VIEWS OF ENVIRONMENTAL PROBLEMS
EPA executed a program of public information and involvement
in connection with the publication of the draft of this EIS. An
analysis and report was prepared of the views expressed by Denver
region residents in response to that program (Reference 130).
Following is the portion of that report which discusses what Denver
region residents perceive as environmental problems.
Air Quality
Air quality is generally perceived as Denver's most severe
environmental problem. Air and water pollution were indicated as
the major regional problems in opinion surveys conducted by a Denver
television station in the spring of 1973 and in the survey conducted
in late 1973 for the United Bank of Denver. The latter survey found
that 47 percent of the sampled population believed air quality to
be a major problem facing the Denver region; younger respondents (25
to 34 years old) were more likely than other age groups to hold this
view, while members of minority groups tended to find such problems
as crime and the cost of living more severe than environmental
problems. Nearly two-thirds of the respondents anticipated further
deterioration in air quality over the succeeding five years.
The 1976 voter surveys also found air quality a major issue.
The Denver Urban Observatory survey found 81 percent of the elector-
ate believe air pollution a very serious (52 percent) or fairly
serious (29 percent) problem; services for the elderly was the only
other issue of as great concern. The Denver Metropolitan Study
reported that a total of 57 percent of the voters find air pollution
a very serious problem, which was the highest level of concern re-
ported for any problem.
These opinions of a random sample of residents/voters are
supported in EPA's workshop and newspaper questionnaires. Air qual-
ity was the topic on which most workshop participants (77 percent)
expressed dissatisfaction. As far as the likely future effects
80
-------
of regional growth are concerned, citizens responding to the news-
paper questionnaire found air quality a very significant growth
impact, over 87 percent expressing that view, and about 40 percent
found air quality the most important single impact of growth.
Water Quality
The public, as a whole, as based on random surveys of residents
and voters, does not find water quality problems nearly as severe
as air pollution. For example, sewage disposal was felt to be a
very serious problem by only 18 percent of the respondents to the
Denver Urban Observatory survey; water supply, on the other hand,
was mentioned by 27 percent as a serious problem. In the Denver
Metropolitan Study's survey (also 1976), the views reported were
nearly parallel; on water supply, 35 percent felt there is a serious
problem, while sewage disposal was recognized as a serious problem
by 18 percent of the respondents.
In part of this low level of problem recognition stems from
the survey's use of the narrow term "sewage disposal" rather than
the broader term, "water quality". However, even those closely in-
volved in water quality planning have not found attainment of clean
water objectives as a high priority need. The participants in DRCOG's
water quality meetings in five basins generally split on this issue
with about a third finding clean water an issue of medium importance;
about 31 percent found it of high importance and 37 percent of low
importance.
Of the six major areas of environmental concern covered in EPA's
newspaper questionnaire, water quality was considered the most
important impact of growth by about 21 percent of the respondents.
Water quality ranked second on this measure, well below the 39 per-
cent who felt air quality would be the most serious impact of growth.
Just over half of the workshop participants expressed strong
dissatisfaction with water quality problems, in the Denver region.
However, some of the problems ranking lower in the scale of impor-
tance (energy and land use) prompted a higher proportion of respon-
ses of dissatisfaction with current programs. This means that,
while water quality may be seen as a serious problem by a signifi-
cant proportion of the public, other functional areas appear to the
public to be less effectively addressed by current programs.
Land Use
Land use is the physical disposition of human activity. Land
use decisions may relate to the type of use (residential, commer-
cial, recreational, and so forth), the scale of the use (size and
number of structures or operations) and how one use relates to other
81
-------
uses. In its most general definition, land use includes both open
space and built space, and it includes transportation facilities as
well as all the kinds of uses which would be destination points.
In the 1976 surveys of random samples of voters and residents,
respondents were given a. list of areas of government activity, and
were asked to indicate which areas posed very serious problems;
multiple answers were accepted. These "problem lists" included both
planning and zoning with about one-fourth of the respondents select-
ing urban planning and one-fifth mentioning zoning. (These percent-
ages cannot be added together because the respondents could select
as many problem areas as they thought appropriate.)
The 1974 report by Bickert reports that a 1973 Junior League
survey yielded similar results: about one-fifth of all local com-
munity leaders in the Denver region considered land use and zoning
to be among the major problems facing the region.
EPA's survey responses broke land use into two categories, urban
and agricultural. Dissatisfaction with urban land use programs in
the region was higher (64 percent) than with agricultural (54 percent);
both of these were higher than dissatisfaction with water quality
programs (51 percent). Urban land use planning was considered by
20 percent of the newspaper questionnaire respondents to be the most
important problem area faced by a growing Denver region, just slight-
ly less than the 21 percent who found water quality the most impor-
tant.
The EPA questionnaires did not list transportation separately
from land use as a potential problem area. In the earlier opinion
surveys, transportation and been mentioned by a large majority of
the respondents as an area posing serious problems: 58 percent in
the 1973 Junior League surveys, over 60 percent in one of the 1976
surveys. (The other 1976 survey offered as separate items on the
problem list parking and traffic, 36 percent; public transportation,
27 percent; and streets and roads, 23 percent.
EPA's respondents, in their comments, frequently called atten-
tion to the relationship between transportation and environmental
conditions. Most of the comments respondents made on the subject
of transportation were in the context of air quality, with improve-
ment of rapid transit and curtailment of auto use recurring recommen-
dations. Many of the comments offered at the workshops and on their
EPA questionnaires suggest that respondents considered the term
"land use" to include transportation. For example:
"We need better land use planning, particularly
in relation to density, air quality and trans-
portation."
82
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The issue of agricultural land use was less stressed by EPA's
respondents than the issue of urban land use, with less than 5 per-
cent seeing the former as the most important problem facing the
growing Denver region. Neither agricultural land nor open space in
general had been included on the "problem lists" of the 1976 surveys.
Other Environmental Issues
The two 1976 opinion surveys asked for respondents' evaluations
of two other environmental problem areas, and the proportions identi-
fying those problems as "serious" were dbout the same in both
surveys: Solid waste disposal, 16 percent and 17 percent; recrea-
tional programs and parks, 9 percent and 17 percent. Animal control
is not wholly a matter of environmental concern, although animal
waste is one factor in non-point source water pollution. Interest-
ingly, animal control was considered a serious problem by 74 percent
of the respondents in one of the 1976 surveys.
The EPA questionnaire solicited views on two other specified
environmental issues, energy and recreation/open space. Neither
of these areas received many mentions as the most important problem
facing the Denver region in the future, although over 80 percent
felt energy to be a very significant problem. Only half thought
recreation/open space very significant; that was the lowest percent-
age of the problem areas listed.
In soliciting comments, EPA also offered respondents the oppor-
tunity to indicate other areas of environmental concern which had
not been specifically listed on the questionnaire. While most of
the comments, both on the workshop questionnaire and on the news-
paper questionnaire, focused on the issues already discussed, other
issues were also identified. There were many comments on the need
for improved public information and education on environmental
problems. Research on environmental problems was also advocated,
as well as training in environmental administration and management.
Other environment problems mentioned by three or more respondents
were: water runoff (including drainage and flood control); water
supply, conservation and reuse; noise; solid waste; and wildlife
protection.
Both EPA's research and investigation by other researchers
identified certain nonenvironmental problems as being of serious
concern. Rising housing costs, services to the elderly and crime
were among these; but if the variety and extent of environmental
concerns expressed by the region's residents in all these studies
are taken collectively, there appears to be a consensus that environ-
mental problems constitute the major impediment to the enjoyment of
the good life in Denver.
83
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84
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XXX. Proposed Projects
and Alternatives
-------
SECTION III
THE PROPOSED PROJECTS AND ALTERNATIVES
PROPOSED PROJECTS
This section of the EIS presents proposed and alternative ap-
proaches that have been examined for meeting regional water quality
goals.
BACKGROUND
This EIS has been prepared simultaneously with the Clean Water
Plan prepared under Section 208 of the Water Pollution Control Act
Amendments of 1972 (P.L. 92-500). The Clean Water Plan is commonly
referred to as the 208 plan, and was prepared by the Denver Regional
Council of Governments (DRCOG), the region's 208 planning agency. The
Clean Water Plan is concerned both with non-point sources of water
pollution and with point sources. The Clean Water Plan and sup-
porting Technical Report were approved with conditions and submitted
to EPA for review by the State of Colorado in January 1978. Plans
for controlling point sources of pollution from the region's munici-
pal wastewater treatment plants are called "facility plans" or "201
plans", and are prepared under Section 201 of the Water Pollution
Control Act Amendments of 1972.
The major non-point source of pollution in the Denver area is
urban runoff. The study conducted during the preparation of the
Clean Water Plan has identified the effect of urban runoff on in-
stream water quality for each of the fifteen subbasins. The con-
clusion reached by the Clean Water Plan is that, even with adequate
point source controls, non-point sources in the form or urban/agricul-
tural runoff would probably prevent year-round achievement of
desired water quality for all of the streams in the metropolitan
area, except for the South Platte above Chatfield Dam. A detailed
analysis was not undertaken for the Eastern Plains subbasin by the
208 study. As a result of this conclusion, the 208 study investi-
gated the feasibility of implementing structural and non-structural
control measures which would yield the desired water quality, stream
segment by stream segment, throughout the urban study area.
The major point sources of water pollution in the Denver region
are effluent flows from regional and subregional wastewater treatment
85
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plants. Two basic approaches are being considered for control of
these sources. One approach would transport wastewater to a large
regional plant; the other would involve the operation of several
subregional and local satellite plants. The latter approach is
presently favored by DRCOG because of the greater opportunity for
reuse of the region's wastewater, and because it allows local con-
trol over water quality and allocation decisions. This preference
is reflected in the point source recommendations of the Clean Water
Plan.
Alternative and Preferred Non-Point Source Control Strategies
Basically, non-point sources consist of urban and rural storm-
water runoff. The Clean Water Plan has estimated that non-point
source control, which would result in the achievement of the 1983
water quality goals, would cost the region approximately 284 million
dollars per year by 1983. The conclusion of the Clean Water Plan
is that this cost is excessive for the "minor" improvement in
water quality that would be expected.
About 50 percent of the 284 million dollars for non-point
source controls would be structural controls designed to collect,
store, treat and discharge stormwater. Therefore, a non-structural
"program" approach to controlling non-point sources is being recom-
mended by the Clean Water Plan. The goals of this approach would
be to maintain and improve the quality of runoff in the region by,
for example, such typical measures as improved street sweeping
services, catch basin maintenance and leaf disposal. As part of
this approach, the Clean Water Plan recommends that implementation
of structural non-point controls be held in abeyance until specific
problems can be pinpointed. The Clean Water Plan suggests that
more monitoring of stream water quality is needed to make this
assessment and that such a program should be completed in several
years.
Alternative and Preferred Wastewater Treatment Facility Designs
The following sections summarize the major known features of
the individual facility plans being collectively examined in this
EIS. The description of each facility also includes a discussion
summarizing the feasible alternatives from which the preferred
design was selected, and a statement of reasons why the preferred
design was considered superior. Planning areas for these facilities
are shown on Map J. Table III-A presents lists of the facilities
and their design flows, effluent standards and feasible alterna-
tives based on best available information.
86
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Table III-A. CURRENT FACILITY PLAN ALTERNATIVES
(*indicates plan recommendation)
00
Design
flow,
Facility mgd.
South 6.0
Adams .
plant
expansion
and inter-
ceptor
sewers
Englewood/ 40
Littleton
advanced
wastewater
treatment
plant
South 3
Lakewood
plant
expansion
Effluent
Quality
BOD: 20 mg/1
SS: 20 mg/1
NH,-N: winter,
3.0 mg/1,
summer ,7.0
fecal colifonn:
6000/100 ml
residual Cl:
0.5 mg/1.
BOD: 20 mg/1
SS: 20 mg/1
NH3-N: 3 mg/1
. fecal coliform:
1000/100 ml
residual Cl:
0.01 mg/1.
BOD: 20 mg/1
SS: 20 mg/1
NH3-N: 3 mg/1
Fecal coliform:
1000/100 ml
residual cl:
0.05 mg/1.
Alt. 4: primary sedi-
mentation, existing
trickling filters
(2.5 mgd); 1978, add
1.75 mgd RED without
nitrification; 1983,
add 4.25 mgd RBD nitri-
fication; 198ft, 1.75 mgd
RBD with nitrification;
sludge anaerobically
digested, marketed.
present worth:
$7.29 million
Alt. 1: Reactivate
Englewood plant and
add ammonia and
chlorine removal
facilities at joint
Englewood/Littleton
plant by 1980. Ex-
pand joint plant to
30 mgd by 1982, and
to 40 tagd by 1992.
present worth:
$35.6 million
*Alt. 1: Improve and/
or enlarge existing
treatment plant to
3 mgd with biological
nitrification in 1978.
For flows from South
Lakewood , Bonvue ,
Daniels and part of
Lakewood; parallel
some outfall sewers
within these dis-
tricts. 4 Remainder
of area flows to
MDSDD #1.
present worth:
$3.95 million
Alternatives
Alt. 5: Same as Alt. 4
except nitrification
by infiltration/per-
colation at site south
and adjacent to plant.
present worth:
$7.08 million
Alt. 2: Same as Alt. 1
except Englewood plant
not reactivated.
present worth:
$38.6 million
Alt. 1A: Same as
Alt. 1 except in-
clude flows from
East Lakewood
Sanitary District.
present worth:
$4 million
Considered
Alt. 6: Same as Alt. 5
except infiltration
percolation site
located near 1—76 and
96th avenue.
present worth:
$7.2 million
*Alt. 3: Same as Alt. 2
except ammonia and
chlorine removal facili-
ties not added until
capacity expansion for
1982.
present worth:
$33.3 million
Alt. 3: Abandon ex-
isting plant; lay
larger trunk sewer
to connect to Metro
District Intercep-
tor line (i.e., all
flows to MDSDD tl
for treatment).
present worth:
$1.0 million
*Alt. 7: Same as Alt.
4 except nitrifica-
tion by land appli-
cation through dis-
charge to O'Brien
canal and Burlington
Ditch.
present worth!
$6.64 million
Alt. 5: Enlarge ex-
isting plant to
serve entire area.
construct AWT facilities
and improved
sludge handling facili-
ties. Expand plant to
10 mgd by 1980.
present worth:
$16.9 million
-------
Table III-A (Continued). CURRENT FACILITY PLAN ALTERNATIVES
oo
00
Facility
Cherry
Creek
and
Goldsmith
Gulch
intercep-
tor sewer
Lower
South
Platte
treatment
plant and
Intercep-
tor sewers
Design
flow Effluent
msd. Quality
1985: To be Alt. 2: System oE
53 mgd, determined sewers to carry en-
2000: tire area flow to
95 mgd. NorthBide plant;
upper half parallels
eastern bank of S.
Platte River, lower
half parallels ex-
isting Delgany main;
no pumping station
required.
present worth:
$25.2 million
26 (in- BOD: 20 mg/1 Alt. 4: New plant at
eluding SS: 20 ins/1 164th Ave. and S.
6.0 NIU-N: Platte River to treat
SACWSD) 3.0 mg/1 flow from Brighton,
fecal coliforro: Lower Thornton and 1st
1,000/100 ml 2nd and 3rd creeks!
residual Cl: flow from Upper
0.05 mg/1 Thornton and NWSWSD
pumped to MDSDD (fl
(1981 plant: 8.3 mgd,
1990 to MDSDD #1: 8.3
mgd, 2000 to SACWSD; 6
mgd); SACWSD to remain
independent; effluent
discharged.
present worth :
$25.1 million
Alternatives Considered
Alt. 3: Same as Alt.
2, except sewers
routed to eaat of
downtown area rather
than parallel to
Cherry Creek outfall
and eastern h-ink of
S. Platte RJ.ver.
present worth:
$26.2 million
Alt. 5: Same as Alt. 4
except flow from Lower
Thornton also pumped
to MDSDD Cl (1981 plant:
3.7 mgd, 1990 to MDSDD
Si: 13.3 mgd); effluent
discharged.
present worth:
$25.2 million
Alt. 4! Same as Alt.
2, except flow routed
directly to MDSDD #1
instead of Northside
via Sand Creek.
present worth:
$28.5 million
*Alt. 14: Same as Alt.
5, except flow from
Lower Thornton pumped
to Big Dry Creek
Treatment Plant (City
of Westminster) for
treatment and
agricultural exchange.
present worth:
$24.4 million
*Alt. 5: Same as Alt.
2, except capacity
based only on 1985
projected flow (49
ragd); additional
future capacity pro-
vided by construc-
tion of Cherry Creek
satellite plant and
staged expansion of
plant as required;
plant effluent to be
reused; 1985 design:
4 mgd, 2000; 16 mgd.
present worth:
$25.9 million
Alternative 4 has been
designated the alterna-
tive recommended plan
for purposes of pre-
deslgn pending the re-
solution of Institution-
al and management
problems concerned with
implementing Alt. 14.
-------
Table III-A (Continued). CURRENT FACILITY PLAN ALTERNATIVES
Facility
Clear
Creek
Design
flow, Effluent
mud Quality
37 BOD: 20 *Alt. 1: Parallel
mg/1 Clear Creek intercep-
SS: 20 mg/1 tor to transport all
NH.-U: basin flow to MDSDD
3.0 mg/1 01 for treatment.
fecal coliform:
1,000/100 ml
residual Cl :
0.05 mg/1
Alternatives Considered
Alt. 2: New plant
near Youngfield St.
and 40th Ave. to
provide treatment
through NH,-N re-
moval for flows
from N. Table
Mountain, Golden,
Applewood and Pleas-
ant View (air acti-
vated sludge; sludge
anaerobicalJy di-
gested; drying bed;
sold); 1983: 6.56
mgd; effluent for
urban reuse; remainder
transported to MDSDD
fl for treatment.
Alt. 5: Same as Alt.
2 except treatment
by infiltration/
percolation basins
located near 44th Street
and Mclntyre.
Note: Golden has
proposed its flows be
treated locally, by a
new plant, for reuse
oo
Sand
Creek
present worth:
$15.6-20.8 million
present worth:
$18.5-25.1 million
BOD: 20 rag/1
SS: 20 mg/1
NH-.-N:
3.0 mg/1
fecal con-
form:
1,000/100 ml
residual Cl:
0.05 rag/1
Higher quality
may be required
for Alt. 3 and 4
Alt. 1: Parallel
Sand Creek intercep-
tor to transport
flow from entire ba-
sin to MDSDD #1.
*Alt. 3: Expand ex-
isting Aurora plant
from 1.5 mgd to 2 mgd
for primary through
advanced treatment for
established flow
volumes for urban,
domestic, agricultural
or industrial reuse,
preferably domestic
reuse in Qulncy reser-
voir; remainder of
flow to MDSDD 111 for
treatment (40 mgd).
present worth:
$18.7-22.9 million
Alt. 4: Same as Alt.
3, except all flow
from Sand Creek in-
terceptor treated at
expanded Aurora plant.
Plant expansion to
17.2 mgd by 1981 and to
to 24 mgd by 1990.
Remainder of flow to
MDSDD *1 for treatment.
24
present worth:
$18.2-23.3 million
present worth:
$23.0 to 25.B million
present worth:
$24.3 to 27.5 million
-------
Table III-A (Continued). CURRENT FACILITY PLAN ALTERNATIVES
Design
f !r
AHornnt: i VPS <>ons irk'tcd
Groom-
rtold/
Wrst-
Klnister
rrj* fnmi 1
p I tin t
North-
R l«?nn
208 pvo-
pn.srd t-'I f 1 unit
1 ImltM*
IU1H: 20 nij'/l
SS: ?(> mj-,/1
NH3 -N:
['rlmiity M tornnl tvr :
Kxprinrl W^wt™ Inst i1 TF?
KlK "rv Creek pl.-iof
From 2.5 to 16. ft i^d
tn t rent T 1 ows 1 rnm
WrsfmlhHtcr (6 mud) ,
^Toopnf U'Ul ^.i fflKd) ;ni*5
Tliornl on ;intl Ndrl (if- 1 1'Hii
9-1ft 208 pro- Primary M torruil Ivr: Sernnriiiry Alternative:
Iixp;ind Westminster's Big
Dry Crunk pl.int From 2.5
m#d tn 9 mji [rl rind
Wc»sl mi ns Ler . ART I m I tur.i I
cxrhanRO willi Fnrmpr*s
Mi>j,hl Inc (*:in.'i I cfni'ln^
0. 0? mn/ I ( !. (\ fnfid) . Wt'sMn Ins Ift"T H Irrigation siMflon . III srh^rgn
rne:;il rnllform: portion of rFFlnciU fur 10 Rl;'. Dry Crepff chirinR
IOOO/10n ml fiKrfriilturnl r*Hi:mr,r rnnwrfntlcr of yonr.
Frr JIRI Hrnltur;!l w I Hi Fnrmcr's llf^hllm*
pxrli.inpp i srcon- C.-in:i1 diir I t\y, t rr t f,,-i t Inn
ihirv I rtja|-mcnl. SP.IHOTT. tl I •?'h.-i rjic In |U K
l>fv Hrrrk rciu.i Iiuh'r ol
yf.-ir . 'Dior ii I on/Norl h-
^Icnn F I m; Ury r;rt-rk , Wi-st mtnsrpv' s Kip, Dry Nnrt hj»lnnn en I Ire 'Led Ju ru-w
2 DH propi'Kt'H (> rrt'k pi mil v I ;\ new rent- rvo i r nml usnd , -,t I onj;
o( F 11 it1 nt f ntor< t'pr tirn , pump with ground vnlrr , to sup pi «-
I. ini i I ;i I i I>I>B nri* st nt lon« fiittl furco m.i I HK rnt'iU VJJIK) cwatnr F I ows f tt»"
mm : ^0 niK/ t , for trenLm^nt nncl -i^r I - n^r 1 ml tnra I cxc-h.inftcw . Fiircp
fc'rn I ru 1 i f nroi: cu I tnr;] 1 i>xrh;mj;'' • Kttl 1 'tin In From nrw Nor tK^trnn
Uinn/lOO in I. C;3ii,'il linod frum »EK Dry rcwnrvolr to Bull C.-maJ ircHt-rvoIr
For ji^tf I rn.U urn 1 Crrok luTul^nlo to now in Wo I tl County for prct r«*nt mnni
pxcliiinnc , spfftn- stornp,p roKervni r. and simmer of was I ew.i tpr" pri nr
ilnry level I ronl- This a I tfriuit !vt; Is the to aKrlcnl t lira I reuse.
ntnnt. Siinu"1 ;is rproincntMidect Alt. 1 h
of Lowrr South Pintle.
FnrllJty plaa started
hut wnrk .suHp^nded
p**nd i ng i-oorci inat i on
with Thornton, North-
Rfenn, UroomFicid
and MHSDU #1 on
NorthgJeiin and Lower
South Plntte facility
p t .tn H .
-------
Table III-A (Continued). CURRENT FACILITY PLAN ALTERNATIVES
Design
flow, Effluent
Facility mgd. Quality
Metro 170- To be
Denver 240 determined
Uewage
Disposal
District
Plant 11
Facility plan.
present worth:
$27.9-29.9 million
($11.4-18.5 including
water supply
benefits)
Alt. 1: Treatment
and discharge con-
sideration will be
given to various
methods and levels
of ammonia removal
Discharge to the
South Platte River.
Alternatives
present worth*:
$24.0 million
($7.5 million
including water
supply benefits)
Alt. 2: Land Applica-
tion consideration
will be given to
irrigation, high-
rate irrigation,
overland flow, and
infiltration/perco-
lation.
Considered
present worth:
$22.7 million ($6.2
million including
water supply benefits)
Alt. 3: Treatment
consideration of
domestic reuse by
the Denver Water
Board and successive
use for Irrigation via
Burlington Ditch.
These evaluations will
also Involve all per-
tinent water rights
issues.
Capacity needs in
future dependent upon
alternatives imple-
mented for South
Lakewood, Cherry Creek
and Goldsmith Gulch,
Clear Creek and Sand
Creek.
-------
South Adams County Water and Sanitation District Service Area —
The South Adams County Water and Sanitation District (SACWSD)
encompasses about 4,500 hectares (10,000 acres) of south Adams
County and currently operates as an independent district. The
present facilities consist of a 0.11 cubic metres per second (2.5
million gallons per day [mgd]) plant using primary sedimentation,
followed by trickling filters. The sludge is anaerobically digested,
dewatered on drying beds, and disposed of on land. The plant needs
expanding and upgrading if it is to meet future effluent standards
and to handle the service area's projected flow.
Two basic expansion and upgrading alternatives were considered.
One was abandonment of the present plant, pumping all wastewater to
the Metropolitan Denver Sewage Disposal District #1 plant (MDSDD #1).
The other was expansion and upgrading of the current plant to handle
future flows. The latter course was chosen (Alternative 7), with
phased construction of a 0.08 cubic metres per second (1.75 mgd)
expansion in 1978, and a 0.08 cubic metres per second (1.75 mgd)
increase in capacity in 1986. This will provide a total plant
capacity of 0.26 cubic metres per second (5.94 mgd). Plant effluent*
will be pumped to the Burlington Ditch by 1983 for land treatment by
agricultural irrigation. The first phase expansion is now under con-
struction.
Englewood/Littleton Advanced Wastewater Treatment Plant —
The cities of Littleton and Englewood entered into a joint
contract to build a treatment plant to handle the sewage from both
cities. The new 0.88 cubic metre per second (20 mgd) capacity
plant began operation in 1977 and is located adjacent to the present
Englewood sewage treatment plant. The existing Englewood and Little-
ton plants have been mothballed.
Currently, a facilities plan is being prepared for advanced
wastewater treatment at the joint plant. The plan considers ammonia
and chlorine removal by various techniques, and the provision for
capacity expansions to 1.31 cubic metres per second (30 mgd) by
1982, and 1.75 cubic metres per second (40 mgd) by 1992. Alter-
native 3 is currently preferred by the cities of Littleton and
Englewood because of lower costs. However, ammonia and residual
chlorine effluent limits would continue to be exceeded until 1982.
Compliance by 1980 would occur under other alternatives.
*Effluent is the term used to describe the discharged treated
wastewater.
92
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South Lakewood Service Area —
The Lakewood service area encompasses approximately 4,600
hectares (11,300 acres). The area is extensively developed, having
a present population of about 68,000 and a maximum projected popu-
lation of 80,000 to 85,000. The area is presently served by
eleven sanitary districts of which only the South Lakewood District
treats its wastes before discharge to the South Platte River. The
existing treatment plant operated by the South Lakewood Sanitation
District serves about 37 percent of the existing population, or
25,000 people. The remainder of the area flow is transported to
and treated by the MDSDD #1 plant.
The facility plan for the area is complete and under EPA review.
The plan focuses on four alternatives. All alternatives include nitrifi-
cation in addition to secondary treatment prior to discharge to the
South Platte River. The alternatives are either treatment of a portion
of area flows in an upgraded plant, or treatment of all area flows
possibly with a portion of the effluent being used for urban irrigation.
The first alternative has been recommended.
Cherry Creek and Goldsmith Gulch Service Area —
Improvements to the wastewater collection system for the upper
Cherry Creek service area are being planned and should be considered
in conjunction with the proposed improvements to the Nor-thside
treatment plant. This area is under the limited jurisdiction of the
Metropolitan Denver Sewage Disposal District #1 for planning treat-
ment plant expansion.
Alternatives in the Cherry Creek and Goldsmith Gulch planning
to date consider both the transport of all area flows to the Denver ,
Northside/MDSDD #1 treatment complex, and the transport of some
wastewater to the Northside complex with the remainder of the waste
going to a satellite advanced wastewater treatment (AWT) plant to
be constructed in 1985. (Wastewater from the AWT plant would be
reclaimed through domestic, agricultural or industrial use, which-
ever is most feasible at the time.) The latter alternative has been
recommended, Alternative 5, with the option of building the satel-
lite plant in 1985 only if it is deemed feasible at the time. In
lieu of a satellite plant, additional sewers could be constructed
to the Northside plant. This alternative provides maximum flexi-
bility, requires the lowest initial capital investment, provides
for wastewater reuse and reduces future flow to the Northside/MDSDD
#1 complex. The satellite plant would consist of secondary treat-
ment, followed by tertiary treatment which would be applied only
when effluent is discharged into Cherry Creek. Domestic reuse,
industrial reuse and irrigation were suggested as possible options.
93
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Lower South Platte Service Area —
The Lower South Platte basin occupies the western part of
Adams County and lies generally northeast of metropolitan Denver.
It is divided into nine subareas. The service area is administered
by the MDSDD #1.
The facility plan originally considered 14 alternatives but
narrowed these down to three for final consideration. All three call
for a new wastewater treatment plant to be built at 164th Avenue and
the South Platte River, and for the South Adams plant to be expanded
and to continue operating as a separate district. The major dif-
ferences in the three plans concern the amount of the area's waste
to be treated at the new plant, how much is to be pumped to MDSDD #1,
and whether or not any waste can be pumped to the City of Westminster's
treatment plant in the Big Dry Creek Basin for treatment and agri-
cultural use as part of a proposed water exchange with Farmer's High
Line Canal and Reservoir Company. The selected alternative, Alter-
native 14, provides for treating the greater portion of the remaining
area's waste by the new plant, with flows from lower Thornton going
to the Westminster plant. The chosen alternative is considered com-
pa,rib.le with Northglenn's successive use proposal. Alternative 4 was
chosen as an alternative recommended plan for purposes of predesign
because Alternative 14 poses management and institutional problems
which must be resolved before it can be implemented. It was assumed
for comparison purposes that the treatment plant would provide
secondary treatment, with ammonia removal, sludge handling by anaero-
bic digestion, air drying and subsequent marketing. Agricultural
use was not considered seriously because of its projected cost.
Sand Creek Service Area—
The Sand Creek Basin encompasses a large portion of Arapahoe
County, smaller portions of Adams County and the City and County
of Denver. It is divided in five subbasins, administered by MDSDD#1
except the Westerly Creek subbasin which is administered by the
City and County of Denver. The flows within this subbasin are
transported to a MDSDD #1 interceptor and plant for primary and
secondary treatment.
The facility plan focused on basically two alternatives: Alter-
native 1 involves transport of all area wastewater flow to MDSDD #1
for treatment; Alternatives 3 and 4 involve advanced treatment of
varying quantities of flow by a new plant and reuse of the water for
domestic purposes. Since a large portion of the water currently
received by the City of Aurora is "new" western-slope water, a por-
tion of this water can be successively used by the City before dis-
charge. This water would be treated and pumped to the Quincy
Reservoir, a domestic raw water supply.
94
-------
Alternative 3 was selected as the preferred alternative. This
plan provides advanced treatment and reuse of a smaller portion
of wastewater than under Alternative 4, but is significantly less
expensive. It has several advantages over Alternative 1 by providing
for reuse and successive use of water, reducing the amount of sewer
construction along Sand Creek, and continuing the use of existing
facilities. For purposes of comparison, the new treatment plant
was assumed to provide secondary treatment with ammonia removal,
sludge handling by anaerobic digestion, air drying, and subsequent
marketing.
Clear Creek Service Area —
The Clear Creek planning area, which occupies portions of
Jefferson and Adams Counties, lies generally northwest of metropoli-
tan Denver and includes 11 subbasins. It is administered by the
MDSDD #1. The facility plan selected two alternative approaches,
one involving transport of all area wastes to MDSSD //I, the other
involving treatment through ammonia removal of some of the area
flow with successive use of the effluent, or treatment by infil-
tration/percolation basins. On the primary basis of costs, Alter-
native 1, the transport of all area wastes to MDSDD #1 was selected.
,'
The cities of Golden and Arvada have protested the implemen-
tation of Alternative 1, transport of all flows to MDSDD #1 for
treatment. Their concerns involve the foreclosure of options for
successive use of wastewater derived fron nontributary water rights
they hold.
Broomfield/Westminster Service Area —
This service area encompasses the cities of Broomfield, West-
minster, and portions of Thornton. The City of Northglen is not
included as it has selected an independent course of action. Exist-
ing facilities include a 0.16 cubic metres per second (3.6 mgd)
plant operated by the City of Broomfield and a 0.05 cubic metres
per second (1.25 mgd) plant operated by the City of Westminster.
Both plants discharge into Big Dry Creek.
The Westminster plant is currently operating at or near capa-
city and an expansion to 0.11 cubic metres per second (2.5 mgd)
is under construction to prevent the imminent pollution of Big Dry
Creek. A facility plan is being prepared to consider further ex-
pansion of the plant. An expansion to 0.39 cubic metres per second
(9 mgd) would provide adequate capacity to treat flows from Broom-
field in excess of 0.16 cubic metres per second (3.6 mgd) as well
as all other area flows. An expansion of up to 0.70 cubic metres
per second (16 mgd) would accommodate additional flows from portions
of Thornton and all of Northglenn.
95
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A contract was signed in 1977 between the City of Westminster
and the Farmer's High Line Canal Company for an exchange of water
rights. Under this agreement, secondarily treated effluent will be
discharged to the canal and used for irrigation of crops, and an
equivalent amount of raw water will be diverted from the canal to
Standley Lake, which is the city's municipal water supply (Reference
972). Under this exchange agreement, plant effluent would be used
during the irrigation season, and discharged to Big Dry Creek the
remainder of the year.
Northglenn —
In an effort to thwart the efforts of adjacent cities to con-
demn agricultural water for municipal purposes and to show that
cooperation is superior to condemnation, the Northglenn City Council
entered into an agreement in 1976 with the Farmers Reservoir and
Irrigation Company Board of Directors which allows Northglenn to
borrow water from Standley Lake, use it for municipal purposes,
collect the sewage, treat the sewage, and store the winter flows
for summer irrigation by farmers. Urban drainage, lawn irrigation
return flow, deep well water and South Platte alluvial well water
will also be collected, treated if required, and transported to a
storage facility in such quantities as to return all of the borrowed
water to the farmers plus provide a 10 percent "bonus".
Sewage from Northglenn would be treated after piping it to an
aerated lagoon/storage reservoir in Weld County. A small catchment
reservoir would be required for urban runoff control. The develop
able areas of Thornton to the northeast are considered within this
plan for possible inclusion at some time in the future.
The Northglenn facility plan, submitted for review, compares
primarily Northglenn's proposals with Alternative 14 of the Lower
South Platte facility plan, and recommends implementation of North-
glenn's proposals.
Expansion of Metropolitan Denver Sewage Disposal District
No. 1 Plant
An expansion of MDSDD #l's plant to include additional secondary
treatment was completed in 1977, which increases the treatment capa-
city to 7.45 cubic metres per second (170 mgd). Ammonia removal
facilities may have to be added to this plant by 1983. The addition
of ammonia removal capacity could increase the plant capacity to
approximately 8.32 cubic metres per second (190 mgd). No further
capacity expansions are currently planned, but planning will depend
upon actions taken on other facility plans.
96
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The facility plan for additional treatment has not yet been
prepared; however, the plan will consider three basic alternatives:
treatment and discharge to the South Platte River; land application
of effluent; and treatment and reuse. Under the treatment and dis-
charge alternative, various methods of ammonia removal will be con-
sidered. Under the land application alternative, methods to be
considered will include irrigation, high-rate irrigation, overland
flow, and infiltration/percolation. Under the treatment and reuse
alternative, consideration should be given to domestic reuse by the
Denver Water Board and to successive use for irrigation via
Burlington Ditch, including considerations of water rights issues.
The Clean Water Program's Recommended Plan for Municipal Wastewater
Treatment Plants
Table III-B identifies the cost and effluent levels for the
major facilities in the Denver Metropolitan Area, as estimated
during the 208 Study. The costs are total capital costs for all
aspects of municipal wastewater control through the year 2000.
EIS ALTERNATIVES - POINT SOURCES
s
In keeping with the regional overview of this EIS, three basic
strategies were assembled from the various alternatives examined in
completed and ongoing facility planning efforts. One of these
strategies, no-action, is required by the National Environmental
Policy Act. Each of these alternative strategies are assessed in
subsequent sections of this report for their environmental impacts.
The three basic facility plan strategies addressed in this EIS
are termed LOCAL, REGIONAL and NO ACTION. They are summarized in
Table III-C. The extensive review of the draft EIS, where these
strategies and impacts were first presented, by public agencies,
special interest groups and individuals served to sharply focus
several issues. These issues and their resolution are discussed in
Volume 1, Sections III and IV of this EIS where the evolution of a
final set of EPA actions is documented.
The Local Alternative
This alternative generally consists of the recommended alter-
natives of the completed facility plans, and the alternatives
examining expansion and/or upgrading of treatment levels for exist-
ing wastewater treatment plants with facility plans now in progress.
The exception is that the recommended alternative for the Clear Creek
service area, a parallel interceptor to MDSDD //I plant, is replaced
by the alternative (2) calling for a new plant serving North Table
Mountain, Applewood, Golden and Pleasant View, with the remainder
served by interceptors to the MDSDD #1 plant. Figure III-A illus-
trates this alternative. This alternative closely resembles the
recommendations of the Clean Water Plan.
97
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Table III-B. CLEAN WATER PLAN RECOMMENDATIONS FOR MUNICIPAL
WASTEWATER TREATMENT PLANTS
VO
00
Facility
Littleton/Englewood
South Lakewood
MDSDD #1
South Adams County
Brighton
61 en dale
Sand Creek
Golden
Big Dry Creek
Louisville
Lafayette
Erie
Boulder
Longmont
Cost1
(Millions)
46.2
1.3
42.5
7.9
5.5
1.6
18.1
9.9
36.4
2.7
6.3
1.9
19.3
10.0
Effluent Requirement
BOD NHo-N
(mg/1) (mg/1)
30
30
30
30
30
30
30
30
20 1
30
30
30
20 1
30
Cl9
(mg/D
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.02
0.5
0.5
0.5
0.02
60.5
Fecal Coliforms
(org/100 ml)
1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
200
1,000
''"These present worth costs reflect capital for facilities and interceptors through
the year 2000.
Source: "Clean Water Plan" DRCOG July 1977
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Table III-C. SUMMARY OF ALTERNATIVES
Service Area
Local Alternative
Regional Alternative
Ho-Action Alternative
South Adams
Englewood/Llttleton
Souch Lakewood
Cherry Crunk/
iliililsml th (,ul>-li
VO
Cl.ai Creek
Sand Cree
Bl-.oint laid/
Westminster
Northglenn
Maintain existing plant, add 1.75 mgd
1978, and final 1.75 mgd capacity
addition in L98b for a total capacity
of 6 mgd.
Addition of ammonia and chlorine
removal for 20 mgd rapacity by 1979.
Further expansion of joint pl.-int to
total capacity with AWT tu 30 mgd In
1982 and 40 mgd in L mgd by 1983.
Option for reuse and successive use.
Add 1.25 mgd activated sludge capacity
in 1977. abandon plant In 1985, all
flows to MDSDD #1.
Same as local alternative except flows
over 20 mgd transported to MDSDD II.
Abandon existing plant and transport
all flows tu Northside/MDSDD tl
rumpjex.
Same as local alternative except
additional Interceptors added in 1985
In lieu of AWT Cherry Creek satellite
plum.
All flows transported to MDSDD ill
except flows t rom Brighton, 1st,
2nd and Jrd creeks to new plant.
Parallel Clear Creek interceptor to
transport all basin flow to MDSDD HI
lor treatment.
Parallel Sand Creek interceptor to
transport flow from entire basin to
M:>SUU #1. Abandon existing Aurora
plant.
Maintain existing plants with excess
Tlow to MOSUu 01.
All flows to MDSDD ill.
Plant expansion with ammonia removal
for total capacity by 1990 of 260-
270 mgd.
Add 1,75 ngd capacity In
1978, final 1.75 mgd added
in 1990.
Addition of ammonia and
chlorine removal delayed
until L9B2. Kxpanslon to
30 ingd delayed to 19H6.
Maintain existing plant, and
service area, transport
effluent to Northslde/MDSDD
01 complex.
Same as local alternative
except construction of
interceptors delayed two
years, plans lor satellite
plant abandoned.
Same as local J 1 tcrnat 1 ve.
except delayed fmir years.
and lower Thornton flows to
Westminster.
Same as region.-]) alternative
except delayed three years*.
Same as regional .ilterciat 1 ve
except delayed three years.
Expansion of existing Big
Dry Creek plant Iron 2.5 mgd
by 1985.
Same as roglotial alternative
Addition of ammonia removal
facilities delayed until
1985.
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FIGURE III-A
TO SOUTH
PLATTE
Rl1
LOUDER S. PLATTE
1981 3.7 mgd - 1991 5.2 nigd
BROOMFIELD 3 mgd
BIG DRY CREEK
AURORA 1.5 mgd
I960 2.0 mgd
CLEAR
CREEK
D
NORTHGLENN
1982 5 mgd '
SOUTH ADAMS
2.5 mgd
1978 4.25 mgd
1986 6.0 mgd
MDSDD#1 170 mgd
SAND CREEK INTERCEPTOR
NORTHSIDE
DELGANY
CLEAR CREEK
INTERCEPTOR
1983 6.5 mgd
1991 8.0 mgd
C
• 2.0 mgd
I960 3 mgd
PLATTE RIVER I
WEST AND
SOUTHWEST
MAIN
GULCH
INTERCEPTOR
LITTLETON ENGLEHOOD
REGIONAL PLANT
SAND
CREEK
BEAR CREEK
\\
CHERRY CREEK
1985 8 mgd
1995 16 mgd
20 mgd
1962 30 mgd
1993 40 mgd
' EXISTING MAJOR SEWERS
- - PROPOSED MAJOR SEWERS
• EXISTING MAJOR TREATMENT FACILITIES
o PROPOSED MAJOR TREATMENT FACILITIES
100
SOUTH PLATTE RI»ER
SCHEMATIC OF
LOCAL ALTERNATIVE
-------
The Regional Alternative
This alternative generally consists of alternatives examined
in the completed and in-progress facility plans which call for cen-
tralized treatment at the Northside/MDSDD //I treatment complex.
Figure III-B illustrates this alternative.
The No-Action Alternative
This alternative assumes that no EPA grant funds for design
and construction would be received by local agencies. As water
quality standards would still have to be met, this alternative
assumes that wastewater treatment facilities would still have to
be constructed. Financing would be borne entirely by local agen-
cies, primarily by the City and County of Denver and MDSDD #1, pro-
bably by some revenue bonds retired by user charges and connection
fees. Some costs may be met through other revenue sources.
ALTERNATIVES TO STREAM DISCHARGE
Land application of wastewater effluent may be used with exist-
ing irrigation or by development of new irrigation on cropland,
rangeland, or forested areas and .parks. In general, two basic
approaches are involved; ownership and operation of a land treat-
ment system, or distribution of effluent to an existing agricul-
tural or other operation. The latter system is a more realistic
possibility for the eastern Colorado area. Excessive costs, water
rights problems, and the complications of entering the agricultural
market have made wastewater treatment agencies reluctant to use
land application.
Systems involving reuse are being looked upon with increasing
favor by Colorado communities. Some communities view wastewater
reuse as a potential means of increasing their domestic water
supplies, and/or as a means of avoiding the condemnation of agri-
cultural water rights. Generally, only those communities owning
nontributary (West Slope diversion) water are legally entitled to
"reuse" water for their own purposes. Other potential systems,
however, have the capability of increasing water supplies for muni-
cipalities using South Platte tributary water.
EPA's chief concern is protection and enhancement of water
quality. If the potential reuse or land application systems have
positive water quality benefits that would result in attainment of
relevant stream standards, such systems are eligible for construction
grant funding.
101
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FIGURE III-B
TO SOUTH PLATTE RIVER
p LOWER S.PLATTE
981 3.7 mgd
991 5.2 mgd
BROOMFIELD
3 mgd
BIG DRY
CREEK
CLEAR
CREEK
WESTMINISTER
SOUTH ADAMS
ABANDON BY 19B5
CLEAR CREEK
INTERCEPTOR
OUTH LAKEWOO(L----~""i1
•- —'
TO BE ABANDONED
v.x CHERRY CREEK
N\ INTERCEPTOR
PLATTE RIVER
INTERCEPTOR
NEST AND
SOUTHWEST MAIN
GOLDSMITH \
GULCH
INTERCEPTOR \
MDSSO#1 1990 260-270 mgd
EFFLUENT TO SOUTH PLATTE WITH SOME REUSE
.AURORA PLANT TO BE
ABANDONED
SAND
CREEK
BEAR
CREEK
CHERRY CREEK
LITTLETON/ENGLEWOOD
REGIONAL PLANT
20 mgd
SOUTH PLATTE RIVER
EXISTING MAJOR SEWERS
PROPOSED MAJOR SEWERS
EXISTING MAJOR TREATMENT FACILITIES
PROPOSED MAJOR TREATMENT FACILITIES
SCHEMATIC OF
REGIONAL ALTERNATIVE
102
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There are a number of ways wastewater reuse systems could
operate. Most reuse systems proposed or in operation use one or
a combination of four basic approaches. These are:
• Potable reuse; The direct reuse of wastewater
effluent after special treatment for domestic
purposes, including human consumption.
• Industrial reuse; The reuse of wastewater
effluent for several industrial processes or
cooling water after various degrees of treat-
ment to suit each use.
• Urban irrigation: The irrigation of parks, golf
courses, school yards, or boulevards with second-
ary treated wastewater.
• Agricultural reuse; The reuse of effluent for
agricultural purposes after a certain degree of
wastewater treatment.
According to Colorado water law, nontributary water to a basin
can be completely reused; tributary water can be reused only if
that reuse does not injure the rights of other users. Reuse of
water tributary to the South Platte basin is usually accomplished
through a water exchange agreement which avoids injury to the rights
of other users. These exchange agreements, for example, exchange
treated wastewater for water normally diverted for agricultural
irrigation. This approach can be used to increase a municipality's
water supply and may also result in a reduced effluent discharge to
a stream. In-stream water quality may therefore be improved, but
reduced flows in the stream may be detrimental to in stream uses.
All of the potential reuse schemes discussed are under consid-
eration in the Metropolitan Denver Area. The water exchange and
reuse arrangements are currently used at times by MDSDD #1 and the
users of the adjacent Burlington Ditch. In addition, Westminster
and Northglenn have proposed systems of the water-exchange type
for increasing water supply. Recycling is being seriously consid-
ered by the Denver Water Board and the City of Aurora. Reuse for
urban irrigation is now practiced by Aurora and South Lakewood,
and Aurora is also considering the possibility of industrial reuse
of effluent.
103
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CLEAN WATER PLAN MANAGEMENT ALTERNATIVES
Section 208 of P.L. 92-500 requires that any plan prepared
under its authority recommend management agencies which would be
responsible for plan implementation. In response to this require-
ment, DRCOG in its draft Clean Water Plan, evaluated eight water
quality "management" alternatives for point sources. They are:
1. General Purpose Governments
2. County Management Agencies.
3. Continuation of the Existing System.
4. Basin or Area Approach.
5. Regional Service Authority.
6. Metropolitan Council.
7. State-Oriented Approach.
8. Single-Purpose Agency Approach.
For non-point sources, the Clean Water Plan considered exist-
ing institutions only.
The State of Colorado generally prefers that general purpose
governments be designated as management agencies in order to pro-
mote integration of planning for land use, non-point source con-
trol and future wastewater treatment facilities.
Point Sources
DRCOG has recommended for municipal point sources that all
districts and municipal treatment agencies as of July 1, 1977, be
designated management agencies. Exceptions to this are the cities
of Longmont and Lyons, the Niwot Sanitation District, which will be
included within the St. Vrain-Left Hand Conservancy District, and
the Highland Park and Water and Sanitation District, which will be
represented by the Supervisory Group of the Littleton/Englewood
Management Agency. Single purpose collector agencies and treatment
agencies with wastewater flows under 3,785 cubic metres (1 million
gallons) per day are not being recommended for designation by the
Clean Water Plan.
The DRCOG is concerned that the 34 agencies proposed for desig-
nation coordinate their future wastewater activities. Therefore,
the Clean Water Plan is recommending that a Water Quality Advisory
Committee be formed with representatives from each management agency
and six others representing two other existing DRCOG water-related
committees. The primary function of this coordinating group would
be to set priorities for wastewater treatment projects within the
regional planning area.
104
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The Clean Water Plan has identified short-term and long-term
goals for future consolidation of these management agencies. The
short-term goals are: (1) to form immediately within each subbasin,
a cooperative organization which consists of all the designated
management agencies within that basin, and (2) at the end of five
years, after approval of the initial Clean Water Plan, to have only
one designated management agency per subbasin. The long-term goal
is to establish a form of metropolitan governance which has enforce-
ment and veto power, as well as responsibility for municipal waste-
water management.
The Governor of the State of Colorado approved with conditions
the DRCOG recommended Clean Water Plan in a January 10, 1978,
letter to the EPA Region VIII Administrator. The DRCOG had recom-
mended that fifteen municipalities and nineteen special districts
be designated as water quality management agencies grouped into
eight basin or area associations. The Governor concurred in the
designation of municipalities, but designated only five special
districts, four for a two year period. The state conditions also
required that the management agency recommendations not concurred
in be reevaluated within one year with the objective of strenghten-
ing the role of general purpose governments including the counties.
Two primary reasons for this condition are the capabilities of
general purpose governments "to relate decisions between growth
and development and associated services", and to "provide for coor-
dinated management over both point and non-point sources".
Non-Point Sources
DRCOG Clean Water Plan recommended that no new agencies be
designated at this time to have management responsibilities for the
water quality aspects of non-point sources. This recommendation
was based on the following factors: (1) non-point source problems
were identified on a regional basis, but specific sources were not
identified; (2) the logical agency for urban stormwater control,
the Urban Drainage and Flood Control District (UD&FCD) does not
have statutory authority for water quality; and (3) the UD&FCD was
reluctant to assume responsibility for the water quality of urban
runoff. DRCOG is suggesting that designation of non-point source
management agencies be postponed pending further analysis of the
specific non-point problems within the regional planning area.
The approval by the State of Colorado of DRCOG's recommended
plan was conditioned to require the first annual update of the plan
"to include a definition of the processes that are or will be
followed in identifying and controlling non-point sources". The
definition of processes "is to include the objectives, long and
short-term remedial measures, management agencies and functions
and possible regulatory controls".
105
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106
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XV. Probable
Environmental
Impacts
-------
SECTION IV
PROBABLE ENVIRONMENTAL IMPACTS
The future of the Denver region will be shaped by the growth
the region experiences in population, production of goods and ser-
vices, and supportive facilities. The expansion of wastewater
collection and treatment capacity affects the amount and distri-
bution of growth in a region by increasing the supply of developable
land. Because growth may generate significant secondary impacts in
terms of the natural and social environment, this chapter begins with
an examination of the region's likely future growth as the basis for
facilities plans and the Clean Water Program.
SOCIO-ECONOMIC IMPACTS
Regional Population and Economic Impacts
Sources of Regional Growth—
The growth of a region starts with the creation of jobs ser-
ving markets outside of the region. Agriculture, manufacturing and
military activity form part of Denver's export economy (basic
demand). As people move into the region, jobs serving the local
market are created in activities, such as retail trade, entertain-
ment and construction (local demand). The number and diversity
of firms serving the local market grow with the increase in basic
demand and in population. The purchase of locally produced goods
and services leads to continued production using local labor, land
and capital. This results in additional locally produced goods
and services. The creation of jobs in basic demand sectors provides
the base for population growth, but population growth provides the
labor force to fill the jobs and creates additional jobs serving
the local market. Thus, population growth and economic growth
become interdependent.
The relationship between job growth and economic growth is
subject to a number of influences. One of these is imperfect
labor mobility. Inadequate information about changing economic
conditions results in a lag in response which may differ among
age and skill groups in the labor force: the more mobile, highly
educated segments of the labor force respond to such information
more rapidly, while in-migration of the less educated and/or less
107
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skilled may be slower to taper off. Some in-migration may occur
even in the face of adverse local economic conditions because the
newcomer may be coming from a location where economic conditions
are even worse. Interregional commuting may also affect migration.
In-migrating newcomers to the labor force are primarily attracted
to an area by job opportunities, either real or imagined, and not
by social amenities. However, this is not to say that social
amenities are not major factors in decisions to move to an area.
It is simply an economic reality that for the aggregate of a labor
force, job opportunities must exist before individuals can move to
and remain in an area. In contrast to the labor force components
of migration, there is a component of migration that is not
predictable on the basis of economic factors. This migration com-
ponent is made up of such groups as retired persons and students
who move for reasons unrelated to employment. For these groups
and others, such amenities as the relative attractiveness of the
region may be the primary incentives to move there. Less desir-
able living environments are less likely to have a "growth problem"
attributable to this migration component.
Economic Impacts of Growth—
The economic effects of growth are expressed in terms of
the increase in the production of goods and services that provide
people with satisfaction, and with the increases in jobs and
income that are created in the production of these goods and
services. Fiscal impacts - changes in the cost and quality of
public goods and services - are a component of overall economic
effects and are discussed separately below. Unlike fiscal or
physical impacts, which are often confined to limited spatial
areas or political jurisdictions, the effects of growth on the
economy cannot adequately be analyzed in terms of local impact
because growth in one locality will have economic effects that
ripple outward through the region.
The benefits derived from the increase in the production of
goods and services as a result of growth affect different interests
in society depending upon their role within the regional economy.
Table IV-A summarizes many of these effects. Consumers receive
satisfaction from the increased choice, quantity, type and price
of goods and services, such as agricultural products, housing,
shopping and convenience goods items, personal services, repair
services, entertainment and cultural functions, and outdoor
recreational functions. Labor force members benefit from the
increase in jobs to produce these good and services, and from the
incomes thereby generated. Investors experience increased income
benefits as a result of the production process, including incomes
from the land values that are created. The profit potential of
industrial and commercial interests benefits from economies of
108
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Table IV-A.
INCIDENCE OF THE ECONOMIC IMPACTS OF GROWTH
GENERATED BY INCREASES IN THE PRODUCTION
OF GOODS AND SERVICES
Positive Impacts
Negative Impacts
Housing consumer
Consumers of goods
and services other
than housing
Labor force
members
Capital investors
and landowner s
Industrial and
commercial interests
and firms
Low income
households
Greater number of housing
options of different types
and prices.
Improved quality of housing
units.
Increased choice of goods
and services available in
terms of quantity, type
and price.
Increase in job opportuni-
ties. Growth in real in-
comes.
Growth of incomes.
Increases in profit through
increases in productivity
and lower costs resulting
from: economies of scale,
advantages of specializa-
tion, plentiful labor supply,
readily available markets
and ease of communication.
Labor force members; Job
opportunities and real in-
come growth. Greater choice
in housing and consumer
goods.
Retired; Slower increase in
housing cost due to expand-
ing supply. Increased value
of local investments (if any).
Increase in congestion as
a result of the increase
in size and complexity of
area. Increase in depen-
dence on neighbors and other
members of society.
Difficulty in identifying
consumer options,
Difficulty in identifying
consumer options. Less
independence.
Increase in competition
for jobs. Increase in
need for specialized train-
ing and experience. In-
crease in congestion and
travel distances.
Higher risks from increased
competition, increased
specialization and more
rapid technological change.
Higher risks and increases-
in failures as a. result of
more competition, difficulty
in discerning market pre-
ference and sizes, increased
specialization, and more
rapid technological change.
Same costs as identified
above for consumers and
labor force- members,
Same costs as identified
above for consumers.
109
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scale, advantages of specialization, development of readily available
markets within short distances and increases in the ease of
communication.
While each type of participant is able to realize a different
type of benefit, any one person or entity in society is likely to
be able to realize several different types of economic benefits
depending upon the roles in which he/she participates. The same
is true of the costs of economic growth which arise as a result
of the increasing specialization, complexity, size and scale of an
urban area. People and firms become more dependent on each other
since there are more of them in one area, they are more specialized,
and they see each other and must interact more often and with more
other people and'firms. Choice creates opportunities, but may also
increase risk. These negative aspects of economic growth are
summarized in Table 1V-A.
Evaluating the Economic Costs and Benefits of Growth—
It has been argued that, at some point, the economic advantages
of growth are offset by economic disadvantages. Despite the in-
tuitive evidence that from a social standpoint, large metropolitan
areas are unpleasant, noisy, congested and timewasting, economic
research has yet to find that any city in the United States has
reached the point at which, in the aggregate, marginal economic
costs of the combined public and private sectors exceed their mar-
ginal economic benefits (Reference 1000).
However, economic and population growth can assume an infinite
variety of forms, the noneconomical impacts of which may
significantly differ. These noneconomical impacts, whose costs
often defy incorporation into quantified economic analyses, require
policy approaches for assessment and resolution. Policy approaches
available to cope with these noneconomic impacts include planning
to accommodate anticipated growth in a manner so as to minimize '
marginal economic costs by the adoption of "no growth" or "slow
growth" strategies. It should be pointed out'that these non-
accommodationist approaches cannot guarantee either the maintenance
of present standards of living or environmental quality; "no growth"
does not mean "no change." It must be emphasized that implementation
of a no growth or slow growth objective limits or precludes the
economic benefits to be derived from expansion and may alter the
structure of the local or regional economy and the economic opportuni-
ties available to local residents.* The alternative available to a
*By whatever means achieved, a restriction on the rate of population
growth will have an impact on the number and type of employment
opportunities (the demand for labor) and on the composition and size
110
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region's populace which wishes to avoid the adverse effects of "no
growth" as well as "growth at any cost", is to identify and mitigate
potentially deleterious environmental impacts of land use activities
while guiding development toward the attainment of regional land
use patterns which are environmentally sound.
Future Economic Growth in the Denver Region—
The Denver Regional Council of Governments (DRCOG) has forecast
that employment in the five-county region will more than double
during the period from 1970 to 2000, with total employment reaching
a level of 1.13 million by the end of the century. Employment is
expected to grow most rapidly during the initial portion of the
forecast period (increasing 2.7 percent per year between 1975 and
1980) and level off toward the end of the period (increasing 1.8
percent per year between 1990 and 2000) (Reference 255).
The DRCOG forecast is based on projections of historic regional
(1958 to 1975) total employment and employment by industry group;
the results of the trend projection were adjusted in line with
observations of the previous (1958 to 1965) effects of national
growth, industry mix and regional influence on employment growth.
Adjustments also were made to insure compatibility between employment
and population projections. The industry-by-industry forecast is
presented in Table IV-B; the table also includes a projection of the
labor force participation rate.
The DRCOG forecast shows declining agricultural employment, which
is consistent with agricultural land conversion estimates presented
elsewhere in this chapter. All other sectors show significant in-
creases with the service sector leading the way. Overall, the
economy will continue to be oriented more toward the production of
of the labor force (the supply of labor). A reduction in the growth
rate will impact industries differentially depending on whether
their level of operation is more closely related to the total size
of the economy (for example, retail trade) or to the rate of economic
expansion (on which the construction sector is primarily dependent).
Costs of no-growth to individuals are therefore dependent on their
investments and the economic sector(s) on which their livelihoods
depend. Corollary to the earlier discussion in Sources of Regional
Growth, regarding economic attractions for a labor force, is the
empirical fact that reduced new job opportunities discourage in-
migration and encourage out-migration, and out-migration normally
affects the more highly skilled first, as discussed previously.
Ill
-------
Table IV-B. SECTOR EMPLOYMENT FORECAST FOR THE
DENVER REGION, 1975-2000
ts>
Industry
Sector
Agriculture
Mining
Construction
Manufacturing
Transportation,
Communications
and Utilities (TCU)
Trade
Finance, Insurance
and Real Estate
(FIRE)
Services
Government
(including military)
TOTAL
Labor Force Partici-
pation Rate (total
employment 7 total
population)
1975
6.7
7.8
42.5
94.7
42.1
161.6
44.9
143.4
124.4
668.1
.453
Jobs in
1980
6.5
8.3
48.1
107.1
45.8
185.5
52.1
167.0
142.8
763.2
.462
Thousands
198 5
6.4
8.9
53.6
118.2
49.8
206.8
58.4
188.0
158.6
2000
5.9
11.0
71.5
154.6
62.9
275.6
78.2
260.6
210.2
848.7 1130.5
.471
.481
% Change
1975-2000
-11.9
+41.0
+68.2
+63.3
+49.4
+70.5
+74.2
+81.7
+69.0
+69.2
% of Total
Nonagricultural
Employment, -2 000
1.0
6.4
13.7
5.6
24.5
7.0
23.2
18.7
Source: Reference 255
-------
goods, as was discussed in Section II. The sectors of mining, con-
struction and manufacturing are forecast to decline slightly in
terms of their collective share of total nonagricultural jobs, while
increases in the service and FIRE (finance, -insurance and real
estate) sectors will come primarily from reductions in the share of
manufacturing and TCU (transportation, communications and utilities).
The current DRCOG forecast has not been allocated to counties.
Employment forecasting by DRCOG has considered distributions to
urban service areas, and Table IV-C presents an estimate of what
the distribution of forecast employment might be, given the county
shares projected in the course of analysis (Reference 258 and 266).
Figure IV-A shows the changing shares of county employment and
population in 1976 and 2000. While Adams and Boulder Counties retain
their relative shares of the total, and Arapahoe and Jefferson coun-
ties increase their share significantly, Denver's share is forecast
to decline substantially.
Future Population Growth in the Denver Region —
A year 2000 population forecast of 2.35 million has been adopted
by DRCOG as the basis of all its planning activities. This "policy
population forecast" incorporates elements both of regional policy
and of forecasting. The antecedent of the forecasting element is
an earlier forecast by DRCOG of 2.175 million in the year 2000; this
forecast was based on (1) the continuation of the 1972 rate of net
national increase (8.5 persons per 1,000 population annually) and
(2) a gradual tapering off of net in-migration from the high levels
(42,000 per year) of 1970-1973. (In the 1975-1980 period, net in-
migration is forecast to be 15,700 annually, which was the 1960's
rate; by 1980-2000, a further reduction to 15,100 annually is fore-
cast, which was the average during the 1940-1970 period.)
This DRCOG staff forecast was reviewed by the Council, with
Council members bringing to the consideration of this issue infor-
mation from their local jurisdictions. After extensive discussion,
the Council of Governments revised the staff forecast upward by
175,000 resulting in the 2.35 million total. The southeastern part
of Jefferson County received the bulk of this addition. In January
1973 the amended total was adopted by DRCOG as regional policy.
The net natural increase rates experienced in the last six
years are within the range underlying the DRCOG forecast. Net
natural increase declined from 8.5 per 1,000 in 1972 to 6.3 per 1,000
in 1974, but rose to 7.5 per 1,000 in 1976. Net in-migration has
dropped from a 1972 high of 61,400 to about 16,000 per year in 1974
and 34,000 in 1976. The addition of 175,000 to the original forecast
results in an implicit change in the forecast of in-migration, which
would have to be 22,000 persons per year if the year 2000 forecast of
2.35 million is to be attained (Reference 993). Whether the net
113
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Table IV-C. EMPLOYMENT PROJECTIONS FOR
THE FIVE-COUNTY DENVER REGION
County
Adams
Arapahoe
Boulder
Denver
Jefferson
Total
Current (1975)
Employment
72,200
68,400
60,400
371,400
95,700
668,100
DRCOG
1980
85,400
86,100
71,600
407,600
112,500
763,200
Employment
1985
94,500
106,500
78,300
435,100
134,300
848,700
Forecast
2000
125,900
175,800
101,200
513,600
214,000
1,130,500
Source: Totals from Reference 255; distribution to counties by Gruen
Gruen & Associates based on Reference 258.
-------
EMPLOYMENT
POPULATION
1975
2000
1975
2000
1 - ADAMS
2 - ARAPAHOE
3 - BOULDER
4 - DENVER
5 - JEFFERSON
SOURCE: EMPLOYMENT ESTIMATES FROM TABLE IV-C
AND POPULATION ESTIMATES FROM REF. 231.
REGIONAL EMPLOYMENT
AND
POPULATION BY COUNTY
CD
-------
natural increase rate will stabilize at a lower level, or the net
in-migration will continue to decline, is not known. However, the
DRCOG forecast can be seen as describing a reasonable upper limit to
regional population growth.
Community Services and Facilities
The increase in population and economic activity forecast to take
place by the year 2000 has implications for the provision of public
services and facilities through the region. Among the services which
will face increased demand are sewage collection and treatment;
water supply; fire and police protection; garbage collection and
disposal; roads and other transportation services and public works
projects; education; general governmental services; and parks and
recreation. One study of growth in the Denver area found that, to
serve an additional 1,000 persons, an additional 4.9 hectares (12
acres) of public institutional uses and parks, 5.3 hectares (13
acres) of streets, seven school classrooms, 570 cubic meters of water
per day (150,000 gallons), two firemen and three policemen would have
to be supplied (Reference 307).
The added community services and facilities will result in an
increase in the costs of the government agencies which supply them.
At the same time, new development will increase the local tax base.
The fiscal impact of growth is individual to the service-providing
entities; the regional fiscal impact of growth is only the aggregate
of the local impacts, a point receiving further discussion in the
next section. The investigation of the impacts of growth on public
service requirements in the Denver region is part of the study
program of the Deliver Metro Environmental Analysis commissioned by
the U.S. Department of Housing and Urban Development; whereas this
study has not attempted to quantify these impacts.
Costs, Financing and Fiscal Impacts
The major fiscal issue related to growth is that of whether the
provision of public services to new users will affect the quality
or quantity of services to existing users, and of whether existing
costs will be affected. The often-heard question of whether growth
pays for itself is usually directed to the concern that the provision
of public services to new users could increase the costs to all those
paying taxes and user charges without increasing or improving the
service outputs to existing users. For example, the Boulder Valley
Comprehensive Plan establishes a policy that "new growth should bear
the major expense of self-created needs for community services and
facilities to the immediate neighborhood" (Reference 1012).
As shown in Table IV-D, there are circumstances in which the
costs of providing additional public services exceed the revenue
generated by the new users and new taxpayers, so that the net result
116
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Table IV-D. INCIDENCE OF THE FISCAL IMPACTS OF GROWTH
GENERATED BY AN INCREASE IN THE DEMAND FOR
PUBLIC SERVICES
Interest or Actor
Benefit
Cost
Recipients of additional public
service outputs (such as new
residents).
Existing taxpayers and existing
recipients of public services
in jurisdictions providing the
additional public service
outputs.
Local municipalities and
special purpose districts
providing the additional
service outputs.
Local municipalities and
special purpose districts
other than those providing
the additional public
service outputs.
Public service out-
puts.
Reduced taxes and
user charges if new
users generate a
net surplus of
revenue over costs .
A net fiscal surplus
if revenues exceed
costs.
Avoidance of service
system expansion (if
efficient levels of
operation have been
reached).
Existing taxpayers and
existing recipients of public
services in jurisdiction other
than those providing the
additional public service outputs
Public taxes and
user charges.
Increased taxes
and user charges
if new users
generate a net
deficit of costs
over revenues .
A net fiscal
deficit if
costs exceed
revenues.
Failure to
achieve efficient
levels of
operation (if
now operating
at lower than
optimum rate
of output).
Indirect benefits or costs
depending upon which of the
two conditions above apply.
Circumstances under which these conditions would be experienced are
discussed in the text.
117
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of fiscal impact is an increase in costs to all users and taxpayers
within the relevant public service jurisdiction.
It is not possible to generalize as to whether new development in the
region will have a positive or negative fiscal impact on existing service
users and taxpayers. The fiscal outcome is determined by five vari-
ables:
• the make-up of the existing population and development;
0 the type of development experienced (scale, type and value
of land used);
9 the state of capital facilities in the relevant service
districts at the time the demand for service increases
(i.e., the presence or absence of unused capacity);
• the laws and policies concerning the types of taxes that
are used to pay for the various kinds of public services;
and
• the policies that the relevant service districts apply to
the setting of tap fees and user charges.
COST CONSIDERATIONS
There are two factors which largely determine the impacts of
growth on the cost of a particular public service. These are (1)
the proportion of total costs represented by fixed or capital costs,
and (2) the excess capacity of existing facilities.
A sewage treatment plant provides a service where a high pro-
portion of total costs are fixed. Therefore, if the plant has
excess capacity, the per unit cost (dollars per unit of wastewater
treated) would decrease with population growth because fixed costs
are spread over a larger base. However, if existing facilities are
operating at capacity, new facilities would have to be built to
accommodate additional population and per unit costs would go up.
For services with low fixed cost compared to total cost, an
increase in demand is unlikely to increase per unit costs. Police
protection and schools are examples of these kind of services.
The per unit costs of these services are more affected by the quality
of service demanded by a community than by population growth.
118
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REVENUE CONSIDERATIONS
The net fiscal impact depends on the particular nature of the
user charges and tax rates for generating service revenues as well
as on the relationship between the revenues generated and the
applicable set of costs, determined as discussed above. Many local
public services are supported primarily by property taxes. While
it is true that higher valued properties can generate higher tax
revenues than can those of lower value, there is no property value
level at which, as a rule of thumb, one could say that a net fiscal
surplus will or will not result. It is the present and future mix
of land uses - in terms of type and value - that determines net
fiscal impact. There are differences among land use categories in
terms of their demand for services and the revenues they generate.
Industrial and commercial uses, for example, do not directly
generate demand for educational services although they generate
revenue to the school districts providing those services. Residen-
tial uses, on the other hand, do generate education costs; whether
they also generate enough revenues to offset those costs depends
on the value of the development and the number of school-age
children it houses.
Net Fiscal Impacts and Land Use Planning
The type of growth a particular community experiences will in-
fluence its future service requirements and costs, and will de-
termine its revenues as well. When viewed from a regional per-
spective, growth per se is likely to bring a mix of uses, including
residential uses which provide housing for the workers in the
industries and commercial establishments. "Less fiscally desirable"
uses must go somewhere within the region if the "more fiscally
desirable" ones are to continue to exist there. But, though a
balance of uses may exist in the region as a whole, a local community
may have a higher than average share of either type of development,
depending on the community's location, market assets and the historic
land use mix. An individual community may attempt to influence its
fiscal condition by attracting "high value" development (such as
major retail or industrial uses) and discouraging "low value"
development (such as inexpensive housing with high demand for public
education). This kind of fiscal rivalry can result in less
efficient regional land use patterns.
On a local area basis, land use patterns can be planned to
minimize the costs of providing government services. For example,
higher density residential development may have lower per-unit
road requirements and thus lower unit costs for roads; this results
in lower unit costs for street lighting and street maintenance.
119
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However, even where land use patterns are designed to minimize
costs, this does not guarantee that revenues will exceed costs or,
more important, that development in that location would be the
least costly. Certainly, that development would not be least costly
in the short run if it requires the construction of new facilities,
while excess capacity for services exists elsewhere in the region at
a location which the new use would accept.
While fiscal impacts are of importance to taxpayers and to
public service users, public decision makers would be aware that
fiscal impact is only part of a project's economic impact. Fiscal
impact analysis considers only those costs and benefits which
appear as cash flowing in and out of a particular local government
treasury. It omits privately received costs and benefits as well
as the interdependencies between types of land uses and among
different public service jurisdictions. It also says nothing about
the economic desirability of land uses. Thus, the question "does
growth pay for itself" cannot be answered from the rather narrow
perspective of fiscal impacts alone. A development with a
negative fiscal impact may still be desirable, and a development
which promises to be a local fiscal asset may nevertheless be un-
desirable. There are other impacts against which the fiscal impacts
must be balance.
Impacts of Wastewater System Costs
The costs Denver communities will pay for wastewater facilities
described elsewhere in this report are summarized in Table IV-E.
The Clean Water Plan has estimated the amount of capital
expenditures through the year 2000 for municipal point source con-
trol at $672 million. Of this total, $319 million would be for
treatment plant construction and interceptors, and $353 million would
be for collection systems. Costs through 1985 for plants and
interceptors would be $291 million, and for collection systems would
be $113 million. Assuming that 75 percent of plant expenditures and
68 percent of interceptor cost would be paid by federal grants, $349
million of the $672 million total cost would be borne by local
agencies and ultimately local citizens. These locally borne
capital costs plus costs for operating and maintaining the systems
results in an annual cost of $40.6 million in 1982 and $48.2
million in the year 2000 compared to an annual cost of $28.3 million
in 1977.
Some portion of these costs will pay for expansion of waste-
water treatment capacity, and these are the costs associated with
growth. The remainder of the costs will finance changes in waste
treatment operations to result in a treated waste product less
damaging to the environment. This represents an increase in
120
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Table IV-E. ESTIMATED AGGREGATE CAPITAL COSTS OF WASTEWATER FACILITIES
ALTERNATIVES (MILLIONS OF 1977 DOLLARS THROUGH 1983)
N5
Planning Area
South Adams County
Englewood/Littleton
South Lakewood
Cherry Creek -
Goldsmith Gulch
Clear Creek
Sand Creek
Wes twins ter/Bloomf ield
Lower South Platte
Northglenn
MDSSD No. 1
Total Capital Cost
Local Agency Share
EPA Grand Funds
Construction Employment
Person-years 3
Local
4. 3
14.6
1.5
12
12
7
It
5.8
18.5
14
93.7
23.4
70.3
,230
Regional
3.6
3
0.8
12
9.8
6.7
5
4.4
2.0
17
64.3
16.1
48.2
2,215
No-Action
3.6
1.6
0.7
8
0
0.5
4
1.0
2.0
14
35. 4C
35.4
0
1,220
2000 Facility Plan Primary Objectives
Accommodated Capacity Improved Treatment
2.6% X
22.4%a X X
less than 1% x
2.3% X
12.2% X X
10 % X
9.9% X
6.3% X
X
b X
a. The new Littleton/Englewood joint plant is expected to accommodate growth till 1982 (20mgd).
b. MDSSD No. 1 would treat, under the local alternative, partial flows from Clear and Sand Creeks, flows from Cherry
Creek/Goldsmith Gulch after primary treatment at the Denver Northside Plant, as well as flows from other areas
not covered by listed planning areas. Capacity expansion completed.in 1977. Further additions to capacity would
be to accommodate growth.
c. Additional funds would be expended after 1982 because of deferred expenditures.
d. Actual amount of grant funds will depend on negotiations over eligible costs for each facility plan.
-------
service quality (though it is being undertaken more in response to
federal regulation than to local demand) and is therefore appro-
priately borne by native and new resident alike. The facility plans
have not broken costs down by these two categories—system expansion
and upgrading of treatment levels. The additional information on
growth accommodation and facility plan objectives presented in Table
IV-E provides a basis for making this type of determination. It
must be kept in mind that other projects such as the Denver North-
side and MDSDD #1 wastewater treatment complex expansion and the
new Little/Englewood regional plant are now in operation. From
the information presented in Table IV-E, it can be estimated that
about one-half the total estimated cost for the next five to seven
years is for growth accommodation.
The Clean Water Program study has estimated that approximately
64 percent of the total uninflated costs through the year 2000 are
growth induced costs. In total dollars this would amount to about
$204 million out of the $319 million projected for capital improve-
ments excluding collection system, operation and maintenance costs.
The Clean Water Plan has projected an average 1985 per capita
cost of about $97 of which $20 is for control of municipal point
sources based on the 1985 projected population of 1.8 million people.
Of the ten facility plans, only the South Lakewood plan presents per
capita costs, $16.94 for the recommended alternative.
The data presented in Table IV-E cover estimated costs of
wastewater projects in the ten service areas. The South Adams
County Water and Sanitation District has already received federal
funds for Phase I of the current facilities plan. The plan presumed
that 75 percent of the cost will be federally funded, with the local
portion to be financed by the sale of bonds. The district meets all
requirements for federal grant funds.
Englewood and Littleton have already received federal funds
for construction of a jointly operated plant to provide treatment
up to the secondary level and will probably apply for grants for
future improvements to that plant. The cities are financially
sound and appear to meet all requirements for federal grant-funding.
The City and County of Denver proposes additional interceptors
in the Cherry Creek area. The only source of long-term debt financ-
ing available to City and County of Denver is revenue bonds of the
Wastewater Management Division. The sale of revenue bonds must be
approved by the City Council, as must any increases in user charges
(Reference 225).
122
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The Metropolitan Denver Sanitary Disposal District Number 1
(MDSDD #1) proposes future expansion of its main plant and upgraded
treatment to be financed in part by state and federal grants and in
part by the sale of revenue bonds (Reference 318). For MDSDD #1 to
qualify for federal grant funds, all the user districts must conform
to federal grant standards. Apparently not all conform at present,
although recent amendments to the Clean Water Act may change this
situation. This problem has caused delays in allocation of federal
grant money in the past (Reference 225), and MDSDD #1 does not have
any control over the means by which member districts raise revenues.
The MDSDD #1 itself was authorized to issue some $30 million in
revenue bonds, of which $20 million had been sold by 1973 for capital
improvements currently being completed. This means that about $10
million worth of additional bonds can be issued without further
voter approval. Beyond that amount, MDSDD #1 would have to obtain
voter approval for a subsequent bond issue. It has been reported
that there may be some resistance by district users to any further
service charges or additional revenue bonds in the future (Reference
225). Given the likelihood of voter resistance to substantially
increased charges, if federal grant funds are not forthcoming, it
is unlikely that MDSDD #1 would be able to raise sufficient capital
to pay for much more construction.
Future treatment plant expansion by the Cities of Broomfield
and Westminster is proposed to be financed in part by federal
grants. Both cities have received federal funds in the past, and
both seem to meet requirements for future federal funding. However,
if grant money were not made available, the cities would probably
raise substantial capital by sale of more revenue bonds. The extent
to which each city would be willing and able to sell these bonds is
not known.
The South Lakewood Sanitation District (SLSD) intends to apply
for a federal grant for expansion of its treatment plant and upgrad-
ing of treatment to meet July 1977 standards. A facility plan is
currently being prepared for these improvements. In case the SLSD's
reliance and property tax revenue proves unacceptable for federal
funding purposes, discontinuation of ad valorem taxation would be
considered.
The City of Northglenn's plan to use treated wastewater and
urban runoff in a exchange for agricultural water is to be financed
in part by federal grant funds, and in part by a $31 million general
obligation bond issue approved by voters in 1977. Northglenn's
proposal presents certain policy issues regarding which portions
of the proposed system will be eligible for federal grant funds.
These policy issues cannot be resolved by EPA Region VIII alone.
123
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Estimates of effects of the costs of proposed facilities on
such things as user charges and tap fees are not available. Increases
will occur; their magnitude is not as yet known. Some estimates will
bear the majority of the capital costs of new facilities. Over a
twenty-five year period and a net growth rate of about two percent,
55 to 60 percent of the cost of new facilities would be borne by
new residents. At a higher growth rate of four percent, the cost
percentage increases to a range of 65 to 70 percent.
LAND USE CHANGE TO THE YEAR 2000
Between 1960 and 1970, the Denver region experienced an accelera-
tion in suburbanization as the City and County of Denver became less
dominant in terms of population concentration, though it continued to
be the region's main job center. In the late 1960's and especially
in the first part of the 1970"s, employment has also become more
widely dispersed through the region, with the City and County of
Denver accounting for a declining share of regional employment.
These changes have been accompanied by changes in land use patterns,
with the suburban counties (Adams, Arapahoe, Boulder and Jefferson)
experiencing increases in developed areas and losses in agricultural
and vacant areas. These kinds of changes are unique neither to the
1960's nor to Denver: the pattern is common throughout the country,
and it has every likelihood of continuing in the Denver region
through the end of the century.
Future Land Use Change
In tabulating land use data, eight use categories have been
established, and DRCOG has projected areas in each use by census
tract as a function of future population and employment. This
tabulation, aggregated by county, is presented in Table IV-F.
In reviewing the land use projections, the reader should keep
several factors in mind. First, the data does not cover the five
counties in their entirety, but only the portions which form part
of the Denver Metropolitan Area. Thus, eastern Adams and Arapahoe,
western Boulder and Jefferson Counties have not been included in the
tabulation. Second, the boundary delineating the Denver Metropolitan
Area for the purpose of land use tabulation was changed by DRCOG
after the 1960-1970 tabulation. The redefinition resulted in the
exclusion from the study area of large blocks of land in Adams,
Arapahoe and Boulder counties. In Table IV-F, the figures for 1970
have been reduced by appropriate amounts in the relevant categories
(generally agricultural, undevelopable and other vacant) so that
figures for 1970 and 2000 cover the same area, but the total area
figures differ from those in Table II-N. Finally, the land use pro-
jections of DRCOG are from the fourth-cycle runs of the EMPIRIC land
124
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Table IV-F. COUNTY LAND USE SUMMARY, 1970 and 2000
S3
County
and
Year
Adams
1970
2000
Change
Arapehoe
1970
2000
Change
Boulder
1970
2000
Change
Denver
1970
2000
Change
Jefferson
1970
2000
Change
Totalb
1970
2000
Change
Residential
Single-
family
9,249
20,547
11,298
8,498
18,456
9,958
9,427
17,000
7,573
21,505
23,167
1,662
15,020
26,684
11,664
63,699
105,854
42,155
Multi-
family
888
2,481
1,593
519
1,532
1,013
946
2,358
1,412
3,296
4,254
958
838
2,300
1,462
6,487
12,925
6,438
Industrial,
Transportation
Commercial Services Communications
956
1,825
869
595
1,498
903
892
1,697
805
1,975
3,019
1,044
1,174
1,983
809
5,592
10,022
4,430
145
306
161
254
527
273
153
332
179
720
788
68
966
1,146
180
2,238
3,099
861
12,268
16,392
4,124
7,115
12,589
5,474
8,251
13,471
5,220
28,687
32,761
4,074
15,430
20,348
4,918
71,751
95,561
23,810
Parks and
Recreation
1,151
2,439
1,288
2,951
4,054
1,103
6,726
6,919
193
6,102
6,578
476
1,754
3,074
1,320
18,684
23,064
4,380
Public and
Semi-Public
18,591
19,878
1,287
4,662
7,128
2,466
1,956
2,967
1,011
4,382
5,088
706
5,928
6,352
424
35,519
41,413
5,894
Agriculture,
Undevelopable
and Other Vacant total
103,292
82,672
-20,620
66,169
44,979
-21,190
135,949
119,556
-16,393
25,336
16,348
-8,988
93,011
72,234
-20,777
423,757
335,789
-87,968
146,540
90,763
164,300
92,003
134,121
627,727
Includes streets
Excludes portions of these counties lying outside Denver metropolitan region as defined by DRCOG (Reference 257).
Source: Acreage for 1970 from Reference 205 and for 2000 from Reference 257; figures for both years aggregated on the
basis of 1970 census tracts as described by DRCOG (Mugler, pers. comm., February 10, 1977).
-------
use forecasting model, which preceded the adoption of subarea
population projections. Notwithstanding this limitation, however,
much can be learned from the land use projections about the future
pattern of land development in the Denver region.
All categories of developed land show substantial area increases
over the 30-year period. The largest percentage increase is in
multi-family residential area, which is projected to double by the
year 2000. Single-family residential area will increase by about
two-thirds, and commercial area by almost 80 percent. Land use in
all other categories is projected to increase by at least 15 per-
cent with the exception of undeveloped (the category headed agri-
culture, undevelopable and other vacant) which is projected to de-
cline by about 21 percent.
Regional Development Patterns
The data presented in Table IV-G offer another way to consider
future land use change in the Denver region: the percentage of
total regional land in a given use category, represented by each
county's land in that category, is listed for both 1970 and 2000.
These data offer an indication of changes in the roles played by the
counties in the regional context. The last row shows the percent-
age of land in each county which was classified as developed in the
years 1970 and 2000. The most striking change between 1970 and 2000
is the increase in the percentage of developed land. In Adams,
Arapahoe and Jefferson counties, the degree of urbanization in 2000
as indicated by this measure will equal or exceed that of Denver.
Only Boulder County is projected to retain a comparatively rural
development pattern, with less than 23 percent of its land developed.
Even though Boulder is projected to lose 6,475 hectares (16,000
acres) of undeveloped land to development over the 30-year period,
it will have a slightly higher proportion of the region's undeveloped
land in 2000 (35.6 percent) than it had in 1970 (32.1 percent).
In the year 2000, the City and County of Denver will have a
reduced share of regional developed land in all categories, as shown
in Table IV-G; Denver's actual acreage increases, shown in Table IV-F,
are small compared to those of the other counties. Jefferson County
will become more "suburban" than it was in 1970: residential use
will rise by over 80 percent, while land use for employment activit-
ies (commercial, services, industrial, transportation and communi-
cations) is projected to grow only 34 percent.
Future land use is shown on Map I. This future land use map
was developed by DRCOG, and was based upon population and land use
computer projections which have since been superseded as previously
discussed. Figure IV-B shows a more recent DRCOG forecast of future
urban service area boundaries within which extensions to urban
126
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Table IV-G. PERCENTAGE DISTRIBUTION OF LAND BY USE CATEGORY, 1970 and 2000
Adams Arapahoe
Land use category 1970 2000 1970 2000
Residential 14. 4a 19.4 12.8 16.8
Commercial and Service U.I 16.2 10.8 15.4
Industrial, Transportation,
Communications 17.1 17.1 9.9 13.2
Parks, Recreation, Public
and serai-public 36.4 34.6 14.0 17.3
Agriculture, Undevelopable,
Other Vacant 24.4 24.6 15.6 13.4
% of Land Developed*3 28.7 41.9 23.8 46.0
Total Land
by Land Use
Boulder Denver Jefferson Category
1970 2000 1970 2000 1970 2000 1970 2000
14.8 16.3 35.3 '23.1 22.6 24.4 11.2
13.3 15.5 34.4 29.0 27.3 23.8 1.2
11.5 14.1 40.0 34.3 21.5 21.3 11.4
16.0 15.3 19.3 18.1 14.2 14.6 8.6
32.1 35.6 6.0 4.9 21.9 21.5 67.5
13.2 23.0 36.9 42.0 29.3 43.9 29.5
18.9
2.1
15.2
10.3
53.5
42.8
b.
10
'Represents county share of regional total for specified land use.
Includes all categories except (1) parks and recreation and (2) agricultural, undevelopable and other vacant, and
represents percentage of land developed in each county.
Source: Table IV-F.
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services, e.g. sewers would be expected to be confined until the
year 2000. Map I and Figure IV-B, nevertheless are useful in illus-
trating where future growth is expected to occur. Map I should be
compared to Map H, and Figure IV-B should be compared to Map B.
Map I incorporates certain planning policies which diminishes its
relationship to the real world. As an example, the future land use
shown excludes from floodplains and streamside areas development that
is clearly known and shown to currently exist on Map H of current
land use. Thus Map I shows not expected land use, but desired land
use given certain development policies.
The projections imply some changes in the density of new develop-
ment over the 30-year period. In 1970, there were about 42 persons
per hectare (17 persons per acre) of land in residential use; in
2000, the projections indicate about 49 persons per hectare (20 per-
sons per acre). This means that new development would be somewhat
more dense than residential development in 1970, with about 57 per-
sons per hectare (23 persons per acre) being the average density of
new development. Employment uses are also projected to be more
densely developed in the future, rising from about 1.7 employees per
hectare (0.7 employee per acre) of employment land (which includes
commercial, services, industrial, transportation and communications)
to about 2.5 employees per hectare (one employee per acre) in 2000.
(These estimates understate actual employee density because street
acreage figures are included in employment land use. However, that
does not affect the direction of change.)
The projections of land in park and recreation use indicate an
increase of over 1.6 million hectares (4 million acres) by the year
2000, an increase of 23 percent over the 1970 acreage. However,
residential development and population growth are projected to exceed
that rate of increase. This means that park acreage per capita is
projected to decline by 35 percent, from 6.2 hectares (15.2 acres)
per 1000 persons to 4.0 hectares (9.8 acres) per 1000 persons,
between 1970 and 2000. Although regional open space particularly
outside the urban areas will be ample, opportunities for active
recreation in the urban areas will be significantly diminished.
Even without an increase in recreational demand, recreation areas
will be more intensely used and degraded.
Regional Planning Issues
Land use patterns and environmental quality are intimately re-
lated. The magnitude, location, rate and spatial distribution of
new development has important effects on the provision of public
and private services, on environmental pollution and on the preser-
vation of stable ecosystems. Elsewhere in this report the impacts
of Denver's future growth on the natural environment (air quality,
water quality, ecosystems and production of food and fiber)
are described. In this section, the efforts of local and regional
131
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agencies to guide development so as to minimize its adverse environ-
mental effects are reviewed. State policies were enumerated in
early 1976 by Governor Lamm and planning policies of the Denver
Regional Council of Governments were adopted in 1974. Within the
context of these policies, possible steps to improve the effective-
ness of local and regional planning are discussed, particularly with
regard to wastewater facilities planning.
Efficiency of Future Development Patterns —
Recent literature in planning and urban geography has reported
on a number of studies of the relationship between the spatial con-
figuration of land development and its environmental consequences.
These studies typically have found that major land uses have dif-
ferent environmental effects, depending on the pattern of develop-
ment, and that a pattern of land development which includes dense
concentrations of mutally supportive, interacting land uses offers
important advantages not offered by dispersed development patterns.
The environmental effects of densely concentrated activity
are often readily apparent. The demand for utilities and energy
at a site of concentrated activity is high; traffic volumes result
in congestion, noise and concentrated emissions; high percentages
of impervious surfaces result in microclimatic changes, reductions
in ground water recharge capabilities and possible increased prob-
lems in accommodating stormwater runoff. However, these direct
effects may be the same whether the uses are concentrated or free-
standing; the concentration of activities draws our attention to
these impacts but does not necessarily increase the magnitude of
impacts. In fact, the indirect effects of concentration may result
in superior environmental impacts, both in reducing environmental
degradation below that which would result from dispersed patterns
of development and in providing improved economic opportunities.
Beneficial effects of concentrating land uses in "activity centers"
include (1) expansion of consumer choice by providing desirable
residential locations for those to whom high density living is
appealing, (2) increasing potential income to firms and
individuals due to gains in efficiency in communication and exchange
of goods made possible by proximate locations of activities, and (3)
reduction in the indirect effects of development on the environment
by making walking and collective forms of transportation reasonable
alternatives to the automobile.
The activity center concept is a key element in the year 2000
plan for the Denver region, and a number of areas have been
designated as activity centers or corridors; these are listed in
Table IV-H. These areas are not yet fully developed (compare
current population and employment to year 2000 population and
employment), but the development of a complex interaction of densely
concentrated land uses at these sites, supportive of higher density
living and public transportation service, is the objective.
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Table IV-H. REGIONAL SUBAREA POPULATION ALLOCATION BY SERVICE AREA (1977)
Service Area
Mountain
Boulder Co Mtn
Evergreen*
Jefferson Co Mtn
Morrison
Nederland*
Plains
Bennett*
Box Elder (Ad)
Box Elder (Ar)
Byers*
Deer Trail*
East Plains (Ad)
East Plains (Ar)
Strasburg*
Valley 1,
Adams Co (Uninc)
Adams Co (Urban)
Arap Co (Uninc)
Arap Co (Urban)
Arvada
Aurora
Boulder City
Boulder Co(E Uninc)
Bow Mar
Brighton
Brootnf ield
1975
29,600
5,900
7,800
14,200
500
700
4,400
900
400
400
400
400
200
700
1 , 000
439,800
10,500
62,500
700
35,900
80,800
121,700
92,200
13,300
1,100
12,900
16,400
Short-Term
1985
41,600
9,100
12,000
18,800
600
1,100
8,800
1,400
1,400
500
1,500
700
600
900
1,800
1,783,700
12,500
65,500
6,600
61,200
100,400
161,500
102,100
21,500
1,300
18,000
29,900
Long-Term
2000
53,800
9,400
16,800
25,300
800
1,500
11,400
2,000
1,800
600
1,800
700
600
900
3,000
2,264,800
18,000
80,000
19.500
73,500
125,000
239,100
135,100
25,000
1,300
25,000
49,600
Service Area
Valley (Cont'd)
Cherry Hills Village
Columbine Valley
Commerce City
Denver
Edgewater
Englewood
Erie**
Federal Heights
Glendale
Golden
Greenwood Village
Jefferson (A-P)***
Jefferson (SE Urban)
Jefferson (Uninc)
Lafayette
Lakewood
Lakeside
Littleton
Longmont
Louisville
Lyons
Mountain View
Northglenn
Sheridan
Superior
Thornton
Westminister
Wheat Ridge
5-County Region
1975
5,400
600
18,600
532,300
5,500
35,900
100
7,600
3,700
14,500
3,500
9,500
21,200
200
5,800
123,000
****
33,500
34,200
3,700
1,000
800
31,500
6,000
300
27,600
31,600
34 , 300
1,473,800
Short-Term
1985
6,000
600
18,000
552,300
5,300
40,900
200
9,600
8,700
17,600
8,500
11,600
59,700
4,800
10,200
163,600
****
35,400
51,400
10,000
1,600
800
38,500
6,900
400
42,500
59,500
38,500
1,834,100
Long Term
2000
7,100
600
20,000
603,700
5,900
45,900
500
12,200
8,700
26,000
14,900
15,200
111,700
12,000
14,000
220,100
****
45,600
74,200
13,600
2,500
800
40,600
11,400
500
61,400
80,300
44,000
2,350,000
* Community Service Area.
** Allocation for part in Boulder County only.
*** A-P - Applewood - Pleagantview.
**** Less than 50.
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The objective of encouraging a more efficient land use pattern
by encouraging activity center development faces a number of impedi-
ments. First, the local jurisdictions with direct land use planning
responsibility implement it unevenly. Arapahoe County is an
example of one jurisdiction which plans to work toward high density
levels along designated travel corridors, in part in the hope that
rail rapid transit service will eventually be provided (higher
density development may indeed be a precondition for it). Other
communities recognize advantages in higher density housing that
are economic as well as environmental: lower land costs per unit
put the higher density unit in the reach of more households; smaller
units are appropriate in a period of declining household size and
declining real incomes; and densely concentrated development
typically has lower public service costs per unit. But proposals
for dense residential development often meet public opposition,
with blockage of views, interruption of scenic corridors and changes
in community character given as reasons for public objections. With
the majority, especially of the suburban public, lukewarm to the
concept at best, it is not surprising that most planners in the
region report that the bulk of future residential development will
be low density and single-family ("the market preference of the
Denver region," according to a Westminster planner). Accordingly,
overall residential densities will increase only slightly by the
year 2000, as discussed in the preceding section.
A second factor working against the effectiveness of the
activity center as a planning tool is the increasing dispersal of
industrial employment. Recent history suggests that isolated sites
have a significant appeal to those making site-selection decisions
for major industrial facilities. Examples of industrial-location
decisions fitting this pattern include Storage Technology Corporation
(Louisville), Western Electric (Westminster), Michelin (Littleton)
and Johns-Manville (Jefferson County). The Johns-Manville location
has received considerable publicity, and is an excellent demonstration
of the role of corporate image in location decisions. The firm's
former chief executive officer - the man who selected the Ken Caryl
Ranch as the site for the J-M facility - described his decision in
these terms: "A company's headquarters is its signature. 1 wanted
a new signature for J-M" (Reference 999). Image, provision for
expansion space, and desirable local characteristics such as lower
taxes, lower land prices and more lenient development controls may
all play a role in the selection of isolated sites by major employers.
These factors may reduce the incentive for firms to locate in
activity centers.
A third factor which may be weakening the activity center plan-
ning strategy is the decision not to fund mass transit by the Urban
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Mass Transit Administration. Mass transit is not a precondition to
the success of an activity center's policy; however, the coordination
of land use planning policy with mass transit might have resulted
in local zoning and planning patterns more strongly reinforcing ex-
isting activity centers along the proposed mass transit corridor.
With hopes for rail mass transit dashed, there is a loss of incentive
to encourage high density uses - residential and commercial - in
the travel corridor (which would have linked together a number of the
designated activity centers).
A fourth factor which favors the dispersal of economic activity
throughout the region is competition among communities for property
tax revenues. Fiscal rivalry weakens the regional perspective in
land use decisions. The Denver Chamber of Commerce objected to
Michelin's decision to locate along the southern edge of Littleton
rather than at a site closer to the residential areas where most
Michelin workers will probably live (Payne, personal communication).
Of course, the cities of the Denver region cannot be faulted for
pursuing their fiscal self-interest in trying to attract industry
to locations within their perimeters, but local dependence on
property tax revenues represents a significant institutional impedi-
ment to the implementation of regional land use policies based on
nonfiscal environmental and social welfare-criteria.
r1
Population Growth—
As discussed in Section II, a policy population forecast for the
Denver region has been adopted by DRCOG which is expected to serve
as the basis for the planning of regional facilities throughout the
five-county metropolitan area. DRCOG has allocated a year 2000
population of 2.35 million persons to geographic units called urban
service areas, which generally correspond to local government plan-
ning areas. These service areas are shown in Figure IV-B, and the
population allocations are given in Table IV-H.
Local agency forecasts were one source of information to DRCOG's
allocation process. These forecasts vary widely in methods and
assumptions. A number of the local agencies expressed the view
that DRCOG ignored their work and questioned DRCOG's allocation
approach, which allocates shares of regional growth to counties.
Local planners feel this approach has often disregarded the demand
for development in their jurisdictions and their capability of
providing services and facilities supportive of new development.
DRCOG's communications with local agencies have stressed that local
area forecasts must take into account uncertainties with regard
to the future availability of wastewater treatment and how these
services would be financed.
135
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Disparities between regional and local forecasts are of con-
siderable concern to local governments because local agency appli-
cations for federal funds are subject to DRCOG review. The regional
council could, at least in theory, determine the size of the grant
or whether a given project would be funded. Local agencies believe
that, if they attempt to obtain federal funds for wastewater
treatment facilities sized to serve a planning period population in
excess of that indicated in DRCOG's allocation, they may be denied
funds or the amount of their grant might be reduced. Thus, a
difference in future population estimates is of importance both to
local agencies and to DRCOG. In order to resolve differences, a
Cooperative Forecasting Program Task Force was established which
included members of local jurisdictions and regional agencies.
This group developed a methodology and set of procedures for use
in the preparation of local population forecasts, which would be
applied both by DRCOG and the local agencies. This work was com-
pleted in March 1977, and was used in developing 1977 population
allocations.
The projected high growth areas are the urban areas in Arapahoe
and Jefferson counties, and the cities of Arvada, Aurora, Boulder
Broomfield, Lakewood, Littleton, Longmont, Northglenn, Thornton,
and Westminster. Those expected high growth areas which have local
agency population projections greater than the 15 percent margin
included in DRCOG policies are the urban areas or Arapahoe and
Jefferson Counties, Aurora, Boulder, Broomfield, Littleton and Long-
mont.
The population projections for the high growth areas prepared
by local agencies forecast populations of 884,800 in 1980 and
1,448,500 in the year 2000. The DRCOG adopted 1977 allocations for
the same years are 831,300 and 1,256,200, respectively. Thus, local
agency projections for high growth areas are five percent higher than
the DRCOG allocations for 1980, and fifteen percent higher for the
year 2000. The 1975 to 1980 growth rate, based on local agency
projections would be 5.4 percent per year compared to a 5.1 percent
growth rate implicit in the DRCOG allocations. The differences are
significant in that about 69 percent of the region's growth is
expected to occur in the high growth areas.
Several of the proposed wastewater treatment projects fall with-
in areas whose future populations are in dispute. The Broomfield/
Westminster area, for example, differs with DRCOG on what the future
population of the subregion will be: the local forecast for the
year 2000 for, the two-city area if 140,900 (Broomfield, 59,300;
Westminster, 81,600) while DRCOG's allocation is 129,900. The local
forecast exceeds DRCOG1s by about 8.5 percent. The difference for
Aurora, which constitutes the majority of the Sand Creek 201 facility
planning area is 19.2 percent. As the sanitary district boundaries
do not correspond with the boundaries of urban service areas, the
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extent of disagreement between the local projections and the regional
forecasts for the areas to be served by new wastewater facilities is
difficult to determine.
Impact of Wastewater Facilities on Land Use—
Major investment in public facilities frequently serves to
encourage growth, primarily by opening up land for development. The
growth-shaping effects of sewers have been noted in a number of studies
(References 983a and 1002), although most case study work has focused
on interceptors rather than on wastewater treatment facilities. Such
facilities influence an area's growth potential wherever new develop-
ment is required to be sewered, which is the case in most areas of
the Denver Metropolitan Area.
The lack of wastewater treatment capacity in any one area may
limit growth for that area, but viewed from a regional perspective, lack
of service capacity in one area often diverts growth elsewhere. Growth
will go where facilities are available to serve it, as a local build-
ing industry representative states (Wyckoff, personal communication,
28 December 1976).
Growth projections for the 201 facility planning areas are given
in Table IV-I. Nearly half of the projected growth will occur in the
Englewood and Littleton, Sand Creek, and Cherry Creek and Goldsmith
Gulch planning areas. See Map J. The most rapid short-term growth
rates will occur in the Westminster and Broomfield, Englewood and
Littleton, and Sand Creek areas. Generally, all of the planning areas
except for South Lakewood and South Adams County will each have a
significant share of future regional growth.
Viewing investments in public facilities as having a greater in-
fluence on the spatial distribution of growth than on the amount of
growth suggests that decisions on whether or not to provide urban ser-
vices should be viewed in terms of the chain of events they set in
motion beyond the service area. Thus, a decision not to serve one area
with expanded treatment capacity should take into consideration pres-
sures on the treatment capacity and sewage systems in other areas.
CONVERSION OF AGRICULTURAL LANDS
The "conversion of agricultural land" is the name given to the
process which results in a change in the use of land from agricultural
to urban. This process may be direct and immediate: autumn's corn-
field may be spring's subdivision; or it may be lengthy: orchards may
be replaced gradually by row crops and row crops by idle land, over a
period of years before construction for urban uses begins. In
the meantime, the land may have passed through several successive
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Table IV-I. POPULATION GROWTH FORECASTS FOR FACILITY PLANNING AREAS
oo
Facility Planning Area
South Adams County
Englewood and Littleton
South Lakewoocl
Cherry Creek and
Goldsmith Gulch
Lower South Platte
Clear Creek
Sand Creek
Westminster and
Broomfield
Northglenn
Planning Areas Total0
Population,
1975
27
121
100
66b
77
198
82
24b
30
725
Thousands
1985
36
199
111
78b
116
246
120
69b
43
1,018
2000
50
317
121
90b
132
305
170
lllb
48
1,344
Growth Rate
1975-1985
2.9%
5.1%
1.0%
1.7%
4.2%
2.2%
3.9%
11.1%
3.7%
3.5%
% of Total
Regional Growth
to 2000
2.6%
22.4%
2.4%
2.3%
6.3%
12.2%
10.0%
9.9%
2.1%
71.0%
a. Based on facility plan projections except as noted, rounded to nearest thousand.
b. Based on DRCOG projections, facility plans based on DRCOG projections not complete.
c. HDSSD No. 1 includes Cherry Creek/Goldsmith Gulch, Clear and Sand Creek, and flows from Denver Northside plant
and its inclusion would largely duplicate enumerated projects.
-------
owners, from the active farm owner to a farm leaser to an owner/
real estate speculator to a developer. Whatever the length of time
involved and the route taken, the outcome generally is the same:
once farm land is converted to urban use, its recoversion to agri-
cultural use is, under normal circumstances, impractical. This sec-
tion discusses why conversion of agricultural land takes place and
why this form of land use change is of environmental concern. It
then addresses this issue in the Denver context and discusses
historical and potential future conversion of agricultural land.
Causes of Agricultural Land Conversion
Farming is an economic activity. It supplies food and fiber
products traded in local, national and international markets,
and it provides a livelihood to farmers and farm workers. Obvious
to those in the business of agriculture, this point must be made
plain if it is to be understood why land is taken out of agricultural
use and what kinds of planning and institutional reforms would be
needed to affect this process.
The farmer's principal raw material is land. Finding farm
land at an acceptable cost is essential if a farmer is to stay
in business. "Acceptable" is meant to be a cost at which the
farmer makes a sufficient return to prevent him from diverting his
assets to some other kind of investment. The farmer faces out-
of-pocket costs for labor, fertilizers, pesticides, energy and
taxes; he faces fixed costs relating to structure and equipment,
as well as to land. A prolonged period of negative net return will
put the farmer out of business.
The value of the land is an important determinant of the
feasibility of agricultural activity. In the first place, the
purchase of land for agricultural use will take place only if
the purchaser finds the price low enough to permit him to make
a profit; land will be retained in farm ownership as long as its
price does not exceed a level at which the return on investment
in land falls below what capital invested elsewhere could earn.
In the second place, land value (a fixed cost) affects property
tax payments (an annual out-of-pocket cost). Rising costs of land
therefore increase the costs of operating a farm as well as the costs
of owning it. This can be a serious problem at the fringes of
urbanized areas, where the value that accrues to land which satisfies
the locational requirements of intensive urban uses is usually
considerably higher than the income the land can generate in agricul-
tural production. Land which would bring $1,250 per hectare ($500
per acre) for farming use may command $5,000 per hectare ($2,000 per
acre) for urban uses. While the farmer cannot influence the
changes in the price of his land which arise from its value to
others for nonagricultural uses, there are steps he can take to try
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to keep its agricultural value at or near its nonagricultural value.
He can grow higher value crops and/or farm more intensively; in
either case, the strategy would be to increase his net return, there-
by maintaining a constant capital/output ratio. He can also simply
hang on hoping that agricultural product prices will rise and com-
pensate for rising land values. A further mitigating factor for
farmers can be the increased land values of their farms. These in-
creased values enable some farmers to borrow money against their
increased equities, which allows continued operation. If these
approaches are impractical, he (or eventually his heirs) will sell
the land, either in small parcels over a period of time or as a
block. This is particularly true if the farmer is advancing in
years, because the opportunity to sell off small parcels for urban
development may provide income for retirement. This is one of the
reasons why farmers may object to restrictions on farm land con-
versions, as is reported to be the case in eastern Adams and Arapahoe
counties (Paul, personal communication).
The following discussion of the effects of the current drought
on agricultural land conversions is not a prediction of what will
be happening in the near future in the Denver region. Rather, it
is a discussion which reflects on some of the plausible consequences
to agricultural and urban land use patterns should the drought con-
tinue beyond this precipitation year. It is by no means com-
prehensive of all the possible socio-economic effects of which the
drought might be a factor.
The current drought could accelerate existing trends to dis-
continue agricultural activities as greater areas of farmland be-
come marginal due to a lack of adequate precipitation. Drought
conditions intensify competition for available supplies of water.
The farmer, faced with reduced precipitation, compensates by in-
creased irrigation or by growing crops requiring less water. The
latter course is limited because high value crops generally require
greater amounts of water. Also, the prices farmers have been getting
the last few years have often not covered production costs. Thus,
lower value crops are even less attractive. Drought conditions
also affect municipal and industrial water supplies. With these
competing demands, the farmer most often loses even if he or the
canal company hold senior water rights. This is because municipal-
ities can institute condemnation proceedings to convert agricultural
water rights to municipal uses. The cities of Westminster and
Thornton are now involved in such proceedings.
The farmer has limited flexibility in the amount of water he
requires given climatological conditions and the crops he must grow
to receive an adequate return. Consequently, urban growth and
drought conditions, coupled with low or nonexistent returns from
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farming have placed the agricultural sector under severe pressure.
Because few farmers can afford to retain their lands in fallow
for very long, many of them could be forced by financial considera-
tions to sell out.
In a situation such as this, in which neighboring farmers are
not likely to be in a position to acquire more land, a "buyers
market" can develop for corporate agriculture interests and land
speculators. Whenever there is potential for a change in the type
of land tenancy, in which lands could change from family farms to
corporate farms and speculative land developments, there is also
potential for a change in the agricultural economy of the region.
The agricultural capabilities of lands purchased by agricultural
corporations would not likely be changed. However, the family
farm sector of the region's agricultural economy would be further re-
duced by some degree. This is a great concern to many of Colorado's
family farmers (Reference 977).
In contrast, the agricultural capabilities of farmlands pur-
chased by land speculators are quite likely to be affected. Land
speculators operate under financial pressures resulting from sub-
stantial interest payments on mortgage notes and from a lack of
production income and investment dividends. A common strategy used
by speculators to realize returns on rural lands is to minimize
the time the land is held. Under this strategy the speculator
subdivides the property into the maximum number of parcels local
land use regulations and his financial resources will allow. He
then makes whatever minimum improvements are required and sells the
parcels as small farms, "ranchettes" or large lots. The effect of
these smaller parcels is to diminish or eliminate the capability
to continue the large scale agricultural operations that were
possible prior to subdivision. Although many smaller scale agri-
cultural activities are not precluded and some are actually made
feasible by the smaller parcel sizes, it is impossible to predict
the utilization plans of a diverse group of new land owners. While
some new owners may invest capital and labor into intense agri-
cultural activities, such as truck farming, others may desire only
to raise a portion of their own food and keep a few animals. It
is all too common, however, for a new owner to also be a speculator
who'will not use the land productively, but will attempt to divide
it further.
This type of speculative activity generally occurs just outside
the urbanizing fringe, where local jurisdictions are unwilling to
grant entitlements for dense, urban development. Despite such efforts
to control "leap-frog" development, the newly diminished, large-
scale agricultural capabilities and fragmented, small parcel owner-
ship patterns near the existing urban fringe establish many of the
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requisite conditions for leap-frogging. Once dense development is
introduced into such an area, thereby establishing a precedent for
further development, the urbanizing fringe is extended further in-
to the region's agricultural hinterlands. This process occurs with
or without drought conditions, of course. As stated at the beginning
of this discussion, the factor contributed by the drought is a
stimulation of the rate at which the process operates, so that farm-
lands are converted before the urban region has a well-defined need
for them.
To conclude, there is land value maximum beyond which it becomes
uneconomical to farm. After this point is reached, the land may still
remain in production for a time as ownership changes from the farmer
to a corporate agricultural interest or landowner who leases it back to
the farmer. It should also be noted that farmers are not always
motivated by economic reasons when deciding what to do with their
lands. They continue farming because they enjoy living and working
on the land, even though they may suffer financially. However,
when the point has been passed at which continuation of agricultural
use can be assured, it becomes increasingly certain that the land
will be urbanized. Farm ownership patterns are a good index of how
far the process has gone. In California coastal counties which are
still responsible for much of that state's agricultural production,
the number of farm owner-operators has fallen sharply since the 1950's.
In San Mateo County, a major center for production of brussels sprouts
and other vegetable crops, over three-fourths of the agricultural land
remaining in 1970 was already operated under leashold arrangements
(Reference 989). Conversion to urban uses under such circumstances
becomes a matter only of time.
Agricultural Land Conversion as an Environmental Issue
The competition between agricultural and urban uses is often
intense because both uses can frequently be provided most effi-
ciently on the same type of land. Urban uses and most crops can
be produced most economically on land with slight to moderate
slopes, good drainage, relatively little waste area and good
water availability. Concern about loss of agricultural land may
arise from a socio-economic perspective or from an ecological
perspective, or from both.
Socio-Economic Impacts of Agricultural Land Conversion—
As the present century has progressed, the United States has
become increasingly important in the international economy as a
food (especially grain) exporter. Maintenance of food production
both for domestic use and for export is a major concern of some
observers, who fear that continued conversion of agricultural lands
may ultimately cause a domestic food shortage, resulting in an
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international shortage: "There has been an overwhelming excess of
potentially arable land for all of history, and now, within 30 years
(or about one population-doubling time), there may be a sudden and
serious shortage" (Reference 998).
While this concern may have a theoretical validity, there seems
to be no real danger that the overall national supply situation will
be adversely affected by agricultural land conversion in the fore-
seeable future. In the period since World War II, both Canada and
the United States have witnessed a considerable increase in urbanized
lands, but at the same time North American grain exports increased
dramatically, from 21 million metric tons (23 million tons) in 1950
to 51 million metric tons (56 million tons) in 1970 (Reference 983).
This has been possible because of significant productivity increases
in both farm land and farm labor. Between 1931 and 1965, per land
unit wheat yield more than doubled, from 1.2 to 2.4 cubic meters
per hectare (13 to 27 bushes per acre); corn production per land
unit more than tripled, from 2.1 to 6.6 cubic meters per hectare
(23 to 73 bushes per acre) (Reference 990). At the same time, the
farm population fell from 30 percent to less than 5 percent of the
total population (Reference 998) . Given the overall decline in
cropland forecasted to take place by the end of the century, the
U.S. Department of Agriculture nevertheless finds that the nation1s
cropland resources can more than supply domestic and export needs
(Reference 720).
However, while the future supply may be adequate, the cost may
rise. Over most of the past 45 years, the percentage of disposable
income that Americans spend on food has declined. This trend has
recently been reversed: in 1972, 15f of each take-home dollar was
spent on food, but in 1974 that figure had risen to 17c. This
change is cause for concern because lower income families may have
food costs per-dollar-earned that are double or triple the national
average. Rising food costs are, in part, a land use problem: "part
of the rise in food costs can be traced to higher input costs,
especially land and structural imbalances in farm units found in
mixed land use areas" (Reference 992). In the Denver region and
in Colorado generally the cost and availability of water are added
problems affecting the economic stability of agriculture.
Farmers need farmers for neighbors. Farm practices and opera-
tions tend to conflict with urban uses. Expansion of farm size be-
comes difficult where farming is at the urban fringe, and farm
expansion may be necessary to permit the application of new
technology to increase productivity. Average farm size nationally
increased almost 30 percent between 1959 and 1969 (Reference 996).
The evolution of a land use pattern that intersperses actual and
potential urban uses with agricultural uses is inefficient and
costly both to food producer and consumer. The situation of
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agriculture is a local land use is therefore a legitimate environmen-
tal concern.
Impacts of Agricultural Land Conversion on the Natural
Environment—
Preservation of land in agricultural use results in a number of
benefits. Generally, the effect on air is positive since any green
cover contributes to oxygen supplies. However, if drought and/or
economic conditions result in significant areas laying fallow, wind
erosion and particulate air quality problems will result. Agricul-
ture jnay use significant supplies of fresh water, but some ground
water recharge takes place. While farm runoff can be a problem,
farmers try to minimize soil erosion. Farming also presents a
generally attractive landscape, representing a minimal departure from
the "natural state" of the environment. Finally, urban land uses
which replace fanning would typically have more adverse impacts on
the natural environment associated with them.
Agricultural land conversion is part of an overall assessment
of land use change which is to be addressed in environmental impact
statements. Farmlands classified as "prime" or "unique" are subject
to specific consideration under current federal and regional policies.
The U.S. Council on Environmental Quality has stated that "efforts"
should be made to assure that such farmlands are not irreversibly
converted to other uses unless other national interests override the
importance of preservations, or otherwise outweigh the environmental
benefits derived from their protection" (Reference 103). The bene-
fits cited include provision of open space, scenery and wildlife
habitat; it is also pointed out that prime lands by their nature
produce more food with less erosion and lower fertilizer and energy
requirements. Policy of the Denver Regional Council of Governments
calls for discouraging new development in these areas (Reference 204).
Conversion of Agricultural Land in the Denver Region
In the period between 1960 and 1970, land devoted to urban uses
in the Denver region increased by 12.3 percent while land devoted to
agriculture declined by 6.8 percent. In all, about 13,600 hectares
(33,600 acres) were lost to agricultural production, while 16,900
hectares (41,700 acres) were added to urbanized areas. Most new
urban land come out of the agricultural category, though some came
out of vacant and public use categories. The decline in agri-
cultural use affected every county, as Table IV-J shows. How much
of this loss was prime agricultural land is not known.
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Table IV-J.
AGRICULTURAL LAND USE IN THE FIVE-COUNTY
REGION; 1960, 1970 (1,000 acres)
County3
Adams
Arapahoe
Boulder
Denver b
Jefferson
Totalb
Year
1960
1970
1960
1970
1960
1970
1960
1970
1960
1970
1960
1970
Total
Acres
243.0
126.8
282.9
63.4
498.2
1214.3
Developed
36.9
46.0
33.2
36.7
64.5
72.6
46.9
174.0
158.6
174.0
340.1
381.7
Undeveloped
Agricultural Vacant
189.5
177.2
80.2
74.9
139.0
133.9
7.4
2.0
76.9
71.3
492.9
459.4
16.6
19.8
13.4
15.2
79.4
76.4
9.1
8.8
262.7
252.9
381.3
373.2
^Excludes eastern Adams and Arapahoe Counties and western Boulder
County.
^Detail may not be added to total due to rounding.
Source: Reference 205
The forces affecting agricultural activity, which were described
in the preceding pages, will continue to influence land development
patterns in the Denver region through the end of the century. It is
possible to project conversion of agricultural land to urban land
based on existing trends and plans as a way of estimating the magni-
tude of change which can reasonably be expected if a year 2000 popu-
lation of 2.35 million is attained.
Three approaches were used in making this projection. The first
was to extrapolate existing trends. The second was to calculate the
loss in agricultural acreage associated with each added unit of popu-
lation in the 1960-1970 period and to assume that the same association
will pertain through the year 2000. The third was to measure from
maps of future land use the acreage of land converted. Only the Denver
urban region was considered; eastern Adams and Arapahoe and western
Boulder Counties were excluded, as these areas are not expected to
experience urbanization.
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At this point in the discussion, certain definitions and dis-
tinctions must be made clear. There are three terms frequently
used in analyzing the effects of urbanization on agriculture. They
are "agricultural land", "prime agricultural soils" and "prime farm-
land". Agricultural land is a term most frequently used by land
use planners and generally refers to any land being used for agri-
cultural purposes. This could be anything from hilly range land to
irrigated truck farms. Prime agricultural soils are land areas
which have all the necessary physical, chemical and topographic
characteristics, except sufficient moisture, to support high-quality
agricultural production. Within the context of the arid Denver
region prime farmlands are areas of prime agricultural soils under
irrigation. The distinction between prime agricultural soils and
prime farmland is made in this EIS because of the need to identify
potential as well as existing highly productive agricultural re-
sources. Land is an in-place resource whereas the water required
to fully use the land resource is relatively transportable.
As Table IV-K indicates, agricultural land in the year 2000
would be between 131,500 and 145,300 acres (325,000 and 359,000
acres), depending on the trend line being considered. In the first
case, a reduction of 29 percent (54,200 hectares [134,100 acres])
in agricultural land is projected; in the second case, a reduction
of 22 percent (40,800 hectares [100,800 acres]) is projected. Note
that the coefficient of conversion (area converted per person added
to the population) rises the more urbanized the area. This is be-
cause in densely settled areas, such as Denver County, land develop-
ment tends to have a larger complement of nonresidential uses,
while in sparsely settled areas, such as Jefferson County, new
development is primarily residential.
The projections of agricultural land presented in Table IV-K
are trend projections based on the conversion experience of the
decade between 1960 and 1970. As is the case with any projection
based on past trends, there is an implicit assumption that the
conditions which applied in the historic period (1960-1970 in this
case) would also apply in the future. This assumption may not be
valid. The supply of agricultural land in 1970 differs in location
and type from the 1960 supply, and the spatial distribution of urban
growth between 1970 and 2000 is not expected to duplicate the 1960
to 1970 pattern. Thus, the projected totals may be reasonable, but
the distribution by county may be somewhat different. DRCOG, as
shown in Table IV-F, indicates that the total land in agricultural,
undevelopable and other vacant categories would be about 136,000
hectares (336,000 acres) in 2000. As this grouping includes addi-
tional land use categories, the total may be considered an upper
limit. Thus, the 131,000 hectares (325,000 acres) projection for
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Table IV-K. PROJECTED YEAR 2000 AGRICULTURAL LAND
IN FIVE-COUNTY REGION3 (1,000 acres)
Adams
Arapahoe
Boulder Denver
Jefferson
Total
Year 1970° 177.2 74.9
Year 2000 based on
extrapolation of
1960 to 1970 trend" 135.0 57.0
Year 2000 based on
per capita agri-
cultural land
conversion fjjom
1960 to 1970 129.5 46.0
Coefficient of
conversion 0.1885e 0.0906e
133.9
114.1
106.8
0.0947
2.0
0.5208
71.3
53.6
43.0
0.0552
459.4
358.6
325.3
0.1168
Excludes eastern Adams and Arapahoe and western Boulder Counties.
bFrom Table IV-J.
County projections have been proportionally adjusted to sura to totals.
One study (Reference 719) reporting on Adams and Arapahoe Counties found
coefficient of conversion for cropland of 0.148 for the two-county area.
Figures for this table cover land in a-1 agricultural usfes, not just
cropland.
eAcres converted per additional person
Source: Table IV-J and References 205 and 262.
-------
case 2 in Table IV-K appears more reasonable. The conversion of
54,200 hectares (134,000 acres) represents a 29 percent reduction
in agricultural land.
A comparison of future land use patterns with the distribution
of prime agricultural soils reveals the extent of possible loss of
existing and potentially productive prime agricultural land to
urban expansion. This comparison assumes that the prime agricul-
tural soils, as shown on Map D, are a limited irreplaceable re-
source and the future land use patterns as defined by DRCOG and
shown on Map I will in fact materialize. The results of the com-
parison are shown in Table IV-L. It is estimated that no more
than 2,000 hectares (5,000 acres) of prime agricultural soils would
be lost in Jefferson County for a total loss in the region of about
15,400 hectares (38,000 acres). This represents about 23 percent
of the prime agricultural soils in the region.
The DRCOG used a similar approach to forecast the loss of prime
farmland (Reference 265). Prime farmland, areas of prime agricul-
tural soils under irrigation, was identified and mapped, and then
compared to projections of future urban service areas (Figure IV-B)
rather than future land use as described above. A total of 35,600
hectares (88,000 acres) of prime farmland was identified of which
about 4,000 hectares (10,000 acres) would potentially be lost to
urbanization
Table IV-L. ANTICIPATED CONVERSION OF PRIME AGRICULTURAL
LAND AS A CONSEQUENCE OF URBAN EXPANSION TO
YEAR 2000
Number of acres expected
County to be urbanized
Adams 20,000
Arapahoe 8,000
Boulder 5,000
Denver Insufficient data
Douglas 400
Jefferson No published data (estimated 5,000)
Weld No published data
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These sharp declines in agricultural land use in the five-county
area represent only part of the likely future state of agricultural
activity in the region. As the agricultural lands on the fringe of
the Denver urbanized area are gradually converted to urban use,
there will be increased pressure to expand and intensify agricul-
tural activity in areas just beyond the metropolitan region. These
pressures would be felt most strongly in eastern Adams and Arapahoe
Counties, southern Weld County and northern Douglas County. If
supplies of water for agricultural use permitted, increase agricul-
tural production in those areas would take place, with little loss
in overall production despite urbanization of some cropland. How-
ever, water is a far more important constraint on agricultural
activity than is land in this region. Local agricultural experts
report that urbanization threatens continued agricultural activity
less because it absorbs agricultural land than because domestic
water users have priority over agricultural users in the allocation
of water. The condemnation of water rights may make farming eco-
nomically infeasible long before pressures for conversion of agri-
cultural land are experienced.
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AIR QUALITY IMPACTS
Introduction
For several years, it has been presumed that acceptable air
quality in Denver was one of the main limiting factors for future
growth in Denver. The "carrying capacity" of the Denver airshed
appears already to be exceeded, given current frequent violations
of air quality standards. It was anticipated that planned growth,
which required the support of wastewater treatment facilities,
would add to the problem and lead to unacceptable air quality in
Denver from the present to the year 2000. This was expected to
be true in spite of adoption of a Denver Transportation Control Plan,
under which specified measures might be taken to improve air quality.
For this reason, a detailed analysis of air quality was performed
for this EIS to investigate the probable future impacts of the
proposed wastewater projects and the Clean Water Plan. This analysis
was performed by Systems Applications Incorporated under contract
to EPA. A report of this work is available upon request and is
listed in the Bibliography as Reference 998.
A major goal of the Denver study was to predict the effect of
land use and population forecasts used in planning the eight pro-
posed wastewater treatment facility plans (201) and the Clean Water
Plan (208) on future Denver (1985 and 2000) air quality. In order
to assess the relative impacts of such actions, air quality was
modeled for future years for various pollutants to attempt to esti-
mate the air quality consequences of future growth.
Since urban growth and development and the attendant changes
in pollutant emissions( depend on factors in addition to the avail-
ability of sewage systems, and in particular, since urban develop-
ment depends on decisions not yet made, predictions of the air
quality effects of future growth are not simulations of complete
certainty. The analysis of Denver's future air quality has become
an exercise in hypothesis. The question is not so much "What will
Denver's air quality be?", but rather, "What will Denver's air
quality be if...?". There is no single unique analysis of future
air quality. The variation of air quality with changes in assump-
tions is an important aspect of the analysis, but to define these
changes, there must be an initial condition from which to measure
departure.
The initial or base condition of Denver's air quality for the
future years under study, 1985 and 2000, is taken to be the state
which would most probably be realized. This condition assumes
automobile emissions which do not strictly meet federally mandated
levels and future growth as projected by DRCOG. Since plans and
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projections for Denver's future have been formulated, examined and
accepted in the absence of this air quality analysis, those plans
become the "base" for assessing probable future air quality impacts.
Variations from this base case for future years are evaluated to
some degree in this EIS. Evaluations of other strategies for con-
trolling air pollution are and will continue to be done by state
and regional agencies.
Modeling Air Quality in Denver
The Denver Air Quality Model (DAQM, Reference 998) was utilized
to predict ozone concentration. Modeling of photochemical oxidants
is exceedingly complex. The major oxidant of concern, ozone, is
not generally emitted from man-controlled sources. Significant
background concentrations of ozone from natural sources can and do
occur. It is generally believed, however, that critical ozone con-
centrations in urban airsheds are produced by chemical reactions in
the atmosphere between atmospheric oxygen, nitrogen oxides, gaseous
hydrocarbons, and other less significant compounds. The primary
sources of nitrogen oxides and hydrocarbons in the urban atmosphere
are combustion machines, most importantly, motor vehicle engines.
The primary nitrogen oxide species emitted is nitric oxide (NO).
In the presence of large amounts of NO (relative to N02 quantities),
it typically takes from one to several hours for the N02/NO ratio
to become high enough for significant ozone to form. In such a time
period, precursor materials are likely to blow far from their sources
and become significantly dispersed. For this reason, ozone concen-
trations are likely to be quite sensitive to wind patterns and
atmospheric mixing. Concentrations of nonreactive pollutants such
as CO and particulates are often more clearly related to wind speed,
direction and stability near their source, than to regional wind
patterns, since they become quite diluted for long dispersion times.
Models which do not take account of wind patterns are not
expected to predict ozone patterns well; therefore, in this study,
a grid based physio-chemical model was used for the analysis of
regional photochemical oxidant.
Particulates and N02 were analyzed with the Gaussian Climato-
logical Dispersion Model (CDM); however, it is very important to
note that most N02 in an urban atmosphere is not emitted, but is a
product of photochemical reactions just as is ozone. Thus, CDM,
which does not include chemistry algorithms, assumes all emitted
NO to be equivalent to N02- This is probably valid for far down-
wind locations, but is clearly not even approximately true at the
times and places for which maximum N02 concentrations are computed
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with CDM. Therefore, the reactive model DAQM was also run to predict
hourly N0£ concentrations for the years 1974, 1985 and 2000. Annual
average N0£ concentrations were then inferred from the DAQM results.
See Reference 998.
Carbon Monoxide (CO) is inert and does not react in the atmos-
phere. As a result, carbon monoxide concentrations are generally
highest near the source (e.g., from automobiles, the highest con-
centrations occur along the roadway and intersections). A grid
model does not estimate "local hot spot" areas, but rather calcu-
lates averages within the area of the grid. However, for a regional
scale analysis, the DAQM grid model was utilized to evaluate future
CO levels.
Information on further localized "hot spot" CO concentrations
was taken from the 1-470 Air Quality Impact Study performed by the
Colorado Division of Highways (CDH). In these calculations, CDH
used the California Line Source Model to evaluate the microscale CO
effects.
Error Discovered
Since issuance of the draft EIS, an error has been discovered
in the emissions input to the Denver Air Quality Model. This model
was used to predict future ozone, N02 and CO concentrations reported
in the draft EIS. The effect of the error was the omission of major
quantities of NOX emitted by one large source and minor quantities
of all pollutants emitted by several smaller sources. Carbon mon-
oxide and hydrocarbon emissions and results were not significantly
affected by this error.
The nature of the error was that the list of point source
emissions, mainly from industrial smoke stacks, was only partially
added to the total inventory of emissions. Truncation of the list
varied from hour to hour and run to run, but some or all of the
emissions from the Cherokee power plant were omitted at all times.
This one source emits about 40 percent of the entire regional of
NOX. All vehicular, area source, small point source and aircraft
emissions were added correctly. Therefore, the error places in
question less than 42 percent of NOX, less than 3 percent of hydro-
carbons and less than 5 percent of CO emissions.
To determine the effect of this error, "base case" simulations
were rerun for 29 July 1975 and 3 August 1976 with corrected emis-
sions inventories. In addition, a year 2000 simulation was repeated
for 28 July meteorology to determine the effect of the power plant
emissions for a future case where other regional emissions were
much reduced.
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The results of these simulations showed noticeable differences
in ozone concentration in the path of the Cherokee power plant plume,
but no conclusions of the draft EIS were invalidated. This was
because validation comparisons between existing data and predictions
were made at observing station locations which were not often
directly impacted by the power plant plume. The peak ozone concen-
tration for 29 July 1975 was computed to be one part per hundred
million (pphm) less than previously reported (22 pphm versus 23 pphm).
The peak was computed as occurring at the same time (1200 to 1300
hours) and at the same place (just west of Green Mountain). Simu-
lations for 3 August 1976 also yield the same peak ozone time and
location as before, and the new peak concentration is 22 pphm rather
than 24 pphm. Areas of exceedances showed differences, but they do
not appear significant. In fact, the maximum area of exceedance of
the ozone standard remained virtually unchanged from that of the previous
results (780 to 1,040 square kilometres [300 to 400 square miles]).
For the year 2000 predictions, peak computed ozone concentra-
tion, location and time of day were unchanged by inclusion of the
power plant emissions. Computed areas of exceedance of the ozone
standard for the year 2000 are very small in either case.
Because there were no significant changes in the results
reported in the draft EIS due to this error in emissions input, the
values reported in the draft EIS have not been changed in this final
EIS. The minor differences in ozone concentrations which were found
to be attributable to this error do not change the conclusions which
were reported in the draft EIS or the reference report, and the
following discussions are considered still valid.
Data and Assumptions
For the purposes of evaluating and modeling present and future
air quality in the Denver Metropolitan Area, a number of emission
files of estimated present and future emissions of various air
pollutants were provided by the Air Pollution Control Division of
the Colorado Department of Health and by the California Division of
Highways.
In general, highway and nonhighway traffic account for a major
fraction of most of the pollutants emitted. While automobiles and
other vehicles do not directly contribute to the particulate prob-
lem, a large percentage of the particulate matter results from
materials on streets thrown up by vehicles (45 to 60 percent of
the total particulate emissions). Point sources contribute the next
largest percentage of emissions and these sources account for as
much as 50 percent of the total NOX emissions as well.
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The emissions which were utilized in the DAQM validation for
the days in 1975 and 1976, consisted of reactive hydrocarbon and
nitrogen oxide emissions to determine photochemical oxidant con-
centrations. To determine CO concentrations, estimates of these
emissions were also input into the DAQM model.
Future emissions were estimated with emission factors based on
recent auto emission test results. These emission estimates are
higher than the current and optimistic EPA vehicle emission factors
from AP-42 Supplement #5 for 1985 and 2000. This approach was used
because recent auto emission tests demonstrate an inability to
achieve the required emission reductions in new cars and the inade-
quacy of emission control system maintenance.
Point sources were projected to the years 1985 to 2000 by assum-
ing that increases in emissions were directly proportional to the
increase in area of industrially-zoned land. Future zoning changes
were determined from various land use plans and population projection
forecasts. Space heating and other area-wide emissions were computed
based on population forecasts and projected land use allocations.
The emissions that were used in predicting 1985 air quality are
presented in Table IV-M. Emissions were estimated in the summer and
winter months and revealed the following:
• Winter emissions exceeded summer emissions for
three pollutants (reactive hydrocarbons, nitric
oxides and carbon monoxides). This was due to
an increase in auto emissions in the winter.
The most significant differences were obtained
from carbon monoxide emissions.
• Automotive emissions of carbon monoxide, hydro-
carbons and NOX are higher than Supplement 5
estimates because of the lack of proper main-
tenance of emission control systems, the fail-
ure of emission controls equipment, and the
apparent inability to achieve the required
reduction of certain pollutants for new cars.
• Point sources contribute almost 15 percent of the
reactive hydrocarbon emissions and about 10 per-
cent of the carbon monoxide emissions.
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Table IV-M. DENVER EMISSIONS INVENTORY (Tons Per Day)
FOR 1985 AIR QUALITY PROJECTIONS
Reactive Particu-
Season HC NOX CO lates
Winter 171 304 2273 130
Summer 138 269 1508 130
TOTAL 309 573 3781 260
Source: Systems Applications, Inc.
Emissions utilized to project year 2000 air quality levels
are presented in Table IV-N. Emissions for this year were calcu-
lated on a summer and winter basis for different source categories.
An examination of this table reveals the following:
• Winter emissions exceed summer emissions for
three pollutants (hydrocarbons, nitrogen
oxides, and carbon monoxide).
• Emissions of carbon monoxide and hydrocarbons
decrease from 1985 but nitrogen oxides are
predicted to increase over 1985 levels.
Table IV-N. DENVER EMISSIONS INVENTORY (Tons Per Day)
FOR 2000 AIR QUALITY PROJECTIONS
Reactive Particu-
Season HC NOX CO lates
Winter 117 330 1220 158
Summer 105 277 1093 158
TOTAL 222 607 2313 316
Source: Systems Applications, Inc.
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Model Validation
Ozone Validation —
The Denver Air Quality Model (DAQM) was validated for ozone on
summer days, 29 July 1975, 28 July 1976 and 3 August 1976; since
these were the only days for which meteorological data were available
and for which sufficient air quality data were available with which
to compare the simulation results. The 1975 day did not approximate
a worst day for 1975, but significant violation (11 pphm) of the
ozone standard (8 pphm) was observed. The second (18 pphm) and third
(16 pphm) highest ozone observations of 1976 were on the two days of
that year simulated. The two 1976 summer days were subsequently
used with future emissions to predict 1985 and 2000 air quality.
The simulation for 28 July 1976 yielded a peak computed ozone
level at any monitoring station of 16 pphm, the same value as was
actually measured. However, the peak ozone level computed for that
day occurred elsewhere in the region, and was 22 pphm. The simula-
tion for 3 August 1976, computed a station peak level of 15 pphm.
The observed value was 17 pphm. Again, the peak computed anywhere
in the region was higher than any observed value, namely 24 pphm.
Therefore, there is no assurance that current monitoring stations
are recording the peak ozone levels occurring in the region, or that
they will do so in the future.
Nearly 300 comparisons were made between hourly-average concen-
trations computed for grid cells, and concentrations observed in the
atmosphere at corresponding points. These comparisons are presented
and discussed in Reference 998. Although there were substantial
differences between computed and observed concentrations on some
occasions, on the whole, impressive correspondence between them was
noted. The differences were not so large as to distinguish between
simulation and observational error.
The plots in Figure IV-C show differences between computations
and observations averaged over time at stations, over stations at
each hour over both time and place for each simulation day and for
all days. The averages were examined for evidence of regularities
that would suggest correctable error in the formulation of the model.
Computed results did average lower than observations early in the
morning and late in the afternoon. Generally, the model predictions
compared very well with observations.
156
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CL
r-j
D OBSERVATION AVERAGES
o PREDICTION AVERAGES
TIME OF DAY, hourly averaging periods start hour
stop hour
THE VARIATION OF AVERAGES OVER ALL
STATIONS OF OBSERVATIONS AND PREDICTIONS
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Carbon Monoxide Validation —
The carbon monoxide validation actually did not produce as
favorable results as did the DAQM ozone model. At certain monitor-
ing locations for some of the simulated days, good agreement between
simulated and observed concentrations was found. In other cases,
substantial differences exist between observations and simulated con-
centrations. In part, this is due to the nature of the computer
model used. The model simulates average CO concentrations over a
11.4 square kilometre (four square mile) grid cell, whereas air
quality monitoring stations sample air at a single point. Therefore,
the model predicts regional scale CO concentrations while monitoring
stations are greatly influenced by very local CO emissions from near-
by road and traffic intersections.
N0y Validation —
Available N02 information was totally inadequate for validation
of the models for these species. Since the Climatological Disper-
sion Model (CDM) was not used in this study for drawing inferences
relative to future NOX levels, no attempt was made to validate CDM
for purposes of N02 prediction. The inferences drawn for N0/N0£
probable impacts and mitigations have not been scientifically vali-
dated and merely represent best estimate.
Particulate Validation —
The CDM was used to predict particulate concentrations and was
previously calibrated by the Colorado Department of Highways. Back-
ground levels and the calibration coefficients previously determined
were utilized for the CDM runs in the Denver study and no attempt
was made to validate the background or calibration coefficients.
Denver Air Quality Projections
Estimates of present and future air quality in the Denver region
were made from model computations using the Denver Air Quality Model
(DAQM) and the Climatological Dispersion Model (CDM) . Computations
were made for comparison with each National Ambient Air Quality
Standard (NAAQS). The DAQM, a "real time" model was used to estimate
the highest occurring hourly average concentrations of ozone, carbon
monoxide and nitrogen dioxide. The DAQM results were used to make
inferences regarding potential violations of the annual average N0£
standard. A much more complete description of the air quality model-
ing efforts discussed here can be found in Reference 998.
158
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Ozone —
As described previously, two of the three summer days for which
data were available were reasonably representative of worst case
ozone episodes. Results of future simulations using meteorological
data from these days and compared with 1976 simulation results show
that peak ozone concentrations are predicted to drop from 24 parts
per hundred million (pphm) in 1976 to 15 pphm in 1985 and 11 pphm
in 2000. For each of these years, the predicted ozone concentrations
exceed the standard of 8 pphm.
Results of the model simulations also showed decreases in the
area extent of violation over time. In 1976, the area computed as
exceeding the ozone standard covered a maximum of 780 to 1040 square
kilometres (300 to 400 square miles) at any one hour. By 1985, the
computations show only about 340 to 480 square kilometres (132 to
184 square miles) in violation of the standard. By 2000 the area is
reduced to 70 to 100 square kilometres (24 to 40 square miles).
Carbon Monoxide —
Carbon monoxide concentrations were computed with DAQM for a
bad (poor dispersion) winter day in November 1974. Winter days in
the Denver Metropolitan Area tend to be most crucial for nonreactive
pollutants, since the low solar intensity and low wind speeds permit
the shallow morning mixing layer to last longer and sunlight is not
required for production of the nonreactive pollutants.
The concentrations gradients of nonreactive pollutants can be
much larger than for ozone. This is because peaks occur very close
to the sources (primarily traffic for CO) before dispersion dilutes
the pollutant material. As a result, the definition of peak concen-
trations of CO is very difficult. CO monitors on opposite sides of
a heavily travelled street can easily show concentrations differing
by a factor of two or even an order of magnitude. The DAQM compu-
tation has a two-mile resolution and, therefore, the microscale street
effects would be suppressed.
Under present conditions, CO violations can surely be found in
any major urban area at particularly critical spots such as industrial,
shopping centers or stadium parking lots or at busy intersections.
This is known to be true for Denver. The DAQM predicted on a regional
scale, that the average CO concentration over an eight-hour period was
16 parts per million (ppm) for 1985, and 5 ppm for 2000. The eight-
hour standard is 9 ppm. Therefore, on a regional scale, CO concentra-
tions will exceed the standard for 1985, but be below the standard by 2000.
159
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1985 and year 2000 analysis utilizing the California Line Source
Model were conducted by the Colorado Division of Highways to evaluate
the microscale effects for its proposed 1-470 alternatives. The
analyses of the modeling results indicated that the highest level of
CO for the years 1985 and 2000 will be experienced along the Santa
Fe Drive. The one-hour CO standard was predicted to be exceeded in
the Cinderella City area in 1985 and is exceeded for most traffic
concentrations in year 2000. Since the results of these analyses
by the Highway Department were based on optimistic emission factors,
it is probable that these results are low. Also, calculations in
the analyses were made on a one-hour basis and it would be expected
that many eight-hour "hot spots" violations would occur in 1985 and
2000, since the eight-hour air quality standard is more often exceeded
than the one-hour standard.
Nitrogen Dioxide —
Estimates of long-term nitrogen dioxide (N02) concentrations
are difficult to determine. The primary emitted species is NO.
After entering the atmosphere, NO is typically oxidized to N0£ in
the same complex photochemical reaction that generates ozone.
Because NO eventually becomes N02, the typical standard violation
analysis computes, not N02, but NOX concentrations assuming all
NOX emissions are N02- Since an annual average is desired (the
standard for N02 is annual average), NOX modeling is usually done
with the EPA Climatblogical Dispersion Model (COM) or other annual
climatological models.
While all NO may eventually oxidize to N02, all emitted NO is
clearly not N02 at all positions along its downwind path. NOX is
particularly not N02 while ,it is still near its source where it is
most dense. COM can therefore be expected to seriously over esti-
mate N02 in the dense source areas of a region. CDM estimates
should be more accurate near the periphery of the modeling region.
CDM is a calibrated model; that is, its results are multiplied
by a factor to make them correlate with observed conditions. The
Denver region has had just one N02 monitoring station which is the
center of the downtown NOX source area. CDM results were calibrated
with data from this station and they should be equivalent to the
observation at that site for the calibration year. The results from
CDM should be progressively more in error (under-predicting) with
distance from the calibration site. Since the emissions of all
interacting species change differently years into the future, the
calibration should not be valid for future years.
160
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The problem of the complex photochemical reactions for N0£ for-
mation could be resolved by using DAQM; in fact, NO and N0£ concen-
trations are computed by DAQM. Use of this model does not, however,
give annual averages and therefore direct comparisons with the N0_
standard cannot be made. Peak N0_ hourly average concentrations
computed with DAQM for worst case summer days show decreases in N0£
from 1976 to 1985 and again to 2000. This is in contrast to pre-
dictions of steady increases of N0£ using the erroneous assumptions
of CDM. The conclusions that may be drawn are:
• Observations show current compliance with the NAAQS
standard of 5 pphm N02 on an annual basis; however,
the one station recording N02 concentrations may not
be located in an area of high concentration.
• Annual average N0£ concentrations may not increase in
future years. They may decrease somewhat.
Particulates—
Annual average particulate concentrations were computed with
CDM. The model results were calibrated with observational data.
The predicted concentrations are so high (four to five times the
State standard) that current and future violations are expected.
The NAAQS for particulates was predicted to be exceeded over 1190
square kilometres (460 square miles) in 1974, 1420 square kilometres
(548 square miles) in 1980, 1780 square kilometres (688 square miles)
in 1985, 1850 square kilometres (716 square miles) in 1990 and 1880
square kilometres (724 square miles) in 2000. Figure IV-D shows the
average annual particulate concentration projections for various
areas around the Denver Metropolitan Area.
A summary of the results of the analysis of future Denver
region air quality is presented in Table IV-0.
Uncertainty of Results
Air quality impacts previously discussed assume that emissions
for future automobile model years will be higher than required by
the Federal Emissions Control Program. This assumption is based on
the present experience indicating that a fraction of vehicles expe-
rience early catalyst failure, another fraction have engine maladjust-
ments, and the remaining fraction are properly tuned vehicles with
operating catalyst. It is also assumed that as a model year becomes
older, more vehicles experience catalyst failure and become malad-
justed. If these fractions are all taken into account, it results
in limited success of the emissions control program. Any signifi-
cant variance from these assumptions could result in different
results as explained in the discussion of the effectiveness of a
vehicle inspection and maintenance program.
161
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FIGURE IV-
o DENVER
A LAKENOOD
• NORTHGLEN THORNTON
a BROOMFIELD/WESTMINSTER/ARVADA
» ENTIRE REGION
• S. METRO
X AURORA
A JEFFCO URBAN
180
160
140
120
100
80
60
40
1975
1980
198S 1990
YEAR
1995
2000
AVERAGE PROJECTED PARTICULATE
CONCENTRATIONS 1974 TO 2000
162
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Table IV-0. DENVER AIR QUALITY PROJECTIONS
Model
DAQM
DAQM
DAQM***
COM
Pollutant
Ozone
CO
CO
N02
Part.
Federal State
standard standard
8 pphm 1-hr.
35 ppm 1-hr.
9 ppm 8-hr.
82 pg/m3
annual average
75 yg/m3 45 yg/m
annual average annual average
Computed maxima
1976
24
26
79
168
1985
15
27
75
217
2000
11
6
74
229
Area of exceedance
(mi2)
1976
300-400
A
A
A
460
1985 2000
132-184 24-48
A A
A A
A A
688 724
* Not calculated
** Observed Value
*** Annual averages determined from peak hour values based on proportionality between
observed values. See Reference 998.
-------
The vehicle emissions used in this analysis also assume some
delay in the required implementation date for emission control
limitation. It was assumed that the implementation dates for carbon
monoxide and hydrocarbon standards of 3.4 grams per mile and 0.41
grams per mile, respectively, would be delayed one year from 1978
to the year 1979. The required implementation date for the NOX
standard was assumed to be delayed until 1981. The presently re-
quired date is 1978. Now the Clean Air Act Amendments have been
passed and the standards for the next several years have been
established. Unfortunately, the assumptions used in this EIS now
appear to be very optimistic with respect to air quality in future
years. For the first time, 1977 cars were required to meet emission
standards at Denver's altitude as well as at sea level. Congress has
since delayed that requirement until 1984 and accordingly, cars sold
in Denver are not required to be compensated for altitude until that
time. There are, however, provisions for regulatory interim stand-
ards for new high altitude vehicles as well as other provisions
allowing EPA to require the auto makers to provide high altitude
"fixes" for some vehicles now in use. Both provisions would require
EPA to go through the standard rule-making regulatory processes and
therefore could not be brought into effect for approximately one
year.
The recent amendments set emission standards for sea level
conditions for carbon monoxide at 15 grains per mile (gpm) until the
model year 1979, 7.0 gpm in 1980 and 3.4 gpm, the statutory require-
ment in 1981. For hydrocarbons, the standard will be 1.5 gpm until
1980 when it changes to the statutory standard of 0.4 gpm. The NOX
standard remains at 2.0 gpm until 1981 and then becomes 1.0 gpm for
subsequent years.
The most likely course of events for future emissions appears
to be that there will be some sort of interim high altitude stand-
ard imposed for new cars, between now and 1984, and quite likely
some "fixes" may be applied to cars in use. Nonetheless, the
emissions assumptions used in the modeling effort were quite optimis-
tic no matter what interim high altitude restrictions might be im-
posed prior to 1984.
The modeling of ozone and carbon monoxide utilized meteorological
data from two summer days in 1976 and one winter day of 1974, respec-
tively. Therefore, as a result, assumed future meteorological con-
ditions are identical to those that occurred on these days. Although
it is assumed these days are representative, and to some degree
typical, of higher ozone and CO pollution episodes, meteorological
conditions will vary from year to year. For this reason, a sensi-
tivity analysis was performed for ozone to determine the variability
of results obtained to'changes in the meteorological assumptions.
164
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Lower average wind speed and shallower average mixing layers than
were originally estimated from the data were investigated. Specifi-
cally, a one-third decrease in wind speed and in mixing layer thick-
ness was assumed separately and together. The decreases were propor-
tionate in every grid point, thus all wind patterns were preserved.
Results of these model simulations showed that a one-third decrease in
wind speed increased the peak ozone concentration by only 1 pphm but
increased the total area subject to standard violations by 210 square
kilometres (80 square miles). Nearly the opposite was the case for
the one-third lowering of the mixing layer thickness, with peak ozone
concentrations increasing by 4 pphm, but the area of violations in-
creasing only by 80 square kilometres (30 square miles). Both mete-
orological parameters would change peak ozone concentrations by much
more than the sum of the individual effects. For one-third decreases
in both wind speed and mixing layer thickness, peak ozone concentra-
tion increased by 8 pphm and the area of standard violation increased
by approximately 260 square kilometres (100 square miles). It appears
that the assumed meteorological estimates would have to be in error
by a substantial amount in order to invalidate the previous ozone
results.
For the meteorological conditions evaluated, it is assumed
that there is no carry-over of pollutants from one day to the next,
nor any reentry of pollutants during a single day after they have
left the modeling area. In Denver, the afternoon mixing layer is
typically quite deep, as compared with morning conditions. This,
together with the lack of any topographic barrier on the east and
north, which are both downhill and downwind in a nighttime drain-
age flow, make carry-over of pollutants from one day to another
unlikely. This conclusion is reinforced by the observation that the
peak ozone days occurred singly in the summer monitoring program of
1976.
However, it appears that wind reversals during midday hours can
bring the pollutant cloud back to the region after it has left the
model boundary. For ozone the situation cannot be treated correctly
by the model since the concentrations change by unknown amounts
while material is outside the analysis region. Given the rapid thick-
ening of the mixing layer, dilution is likely to be far advanced when
reentry of the ozone cloud becomes an issue.
While the possibility exists that days could occur when the
characterizations involved are not valid, the situation described is,
however, consistent with maximum ozone concentrations observed in
Denver.
Since the boundaries of the Denver Air Quality Model are defined
by an 80 x 80 kilometre (30 x 30 mile) square, centered over Denver,
the potential downwind effects are not modeled. Downwind ozone and
N02 concentrations may also be a problem under certain conditions.
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The annual average particulate results are estimated with the
use of a "calibrated" model which factors the model results to more
closely resemble the observations. Also, a large fraction of the
model results are attributed to "background" particulate concentra-
tions rather than identified emissions. Therefore, particulate re-
sults are sensitive not only to the estimated particulate emissions,
but also, to the assumed "background" level and calibration constants.
In predicting future N02 concentrations in the Denver region,
uncertainty exists as to the present level of NC>2 concentration
since there is only one N0£ monitor and it may not be located so as
to pick up the peak concentrations. This is important in that the
probability of future violations of the N(>2 standard is based in
part on present measured concentrations of N02- If, in areas of the
Denver region, the N02 standard is being violated where no monitor-
ing presently exists, the likelihood of future violations of the
N(>2 standard would be increased.
Probable Effects of an Automobile Inspection and Maintenance Program
A motor vehicle inspection and maintenance program will not
eliminate the pollution problem in the Denver area, but it is a
necessary first step in attacking one of its major sources. Last
year legislation was passed mandating inspection and maintenance
beginning in 1980 for cars of 1977 and later model years. Now,
however, because of the recent current swell of public concern of
air pollution (see Volume I) the legislation is apparently going to
be strengthened. One proposal would begin the program in July of
1978 and would mandate inspection for 1974 and later model year cars.
Although the legislation is pending at this time and the outcome
is uncertain, it appears that the Inspection and Maintenance Program
passed last year will be improved.
It is proposed that the inspection and maintenance program
would work in much the same way as Colorado's safety inspection pro-
gram. It is estimated than as inspection will cost around $5.20.
The program will not only reduce air pollution, but will also re-
sult in gasoline savings through more efficient engine performance.
The exact impact on air quality of the proposed inspection
and maintenance program has not been determined. The air quality
impacts discussed in the analysis assume that an inspection and
maintenance program is not in effect. Estimates of the air quality
in Denver have been made assuming very strict compliance of auto-
mobiles with the federally mandated auto emission limitations. In
fact, strict compliance is not being achieved today and is not pro-
jected to even be approached in the future without some kind of
inspection and maintenance program. This is due to the fact that:
166
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1) manufacturers are presently not able to produce cars which meet
all of the emission limitations; 2) a certain percentage of cars
experience early failure of the catalytic converter (the principal
emissions control device) and; 3) many automobiles are not properly
maintained to meet the emission limitations and others are maladjusted.
An inspection and maintenance program will greatly reduce the latter
two problems in meeting the Federal Emission Standards.
Although not exactly the result of implementing an inspection
and maintenance program, strict compliance with Federal Emission
Standards would reduce carbon monoxide concentrations by almost 40
percent of that projected for 1985. Regionally, although not in all
"hot spot" locations, adherence to auto emission standards would
bring CO concentrations very close to the eight-hour ambient standard
in 1985. For ozone, the effects of properly controlled automobile
hydrocarbon emissions would not be as great as for CO. Peak ozone
concentrations would be reduced for 15 pphm to 13 pphm in 1985, a 13
percent reduction; and from 11 pphm to 9 pphm in 2000, an 18 percent
reduction.
Possible Effects of a Relaxation of the NO Emission Standard
In another assessment of the possible effects of changes in
vehicle emissions, an attempt was macle to evaluate the impact on
ozone and N0£ concentrations of an increase in NO emissions. This
air quality simulation assumed a relaxation of the NO emission
standard to 1 gram/mile NO emissions rather than the previous 1978
goal of 0.4 grams per mile. This simulation was performed before
the Clean Air Act Amendments of 1977 were passed, and incorporates
only one of several changes mandated by the amendments. Therefore,
the results of this simulation are of limited value in evaluating
the effect of the Clean Air Act Amendments on Denver's future air
quality. However, the simulation does provide an improved understand-
ing of the causes of air quality problems in the Denver region. Results
of this simulation for conditions otherwise the same as the 1985
probable impact results showed only slight violations of ambient
standards for ozone and no increase in peak N02 concentration. In
strict compliance with Federal Vehicle Emission Standards, as dis-
cussed above, except for the proposed relaxation in the NOX standard,
no violation of the ozone ambient standards was predicted for 1985.
The reason for the apparent improvement in air quality with
increased NO emissions is that the ratio of the two ozone precursors,
hydrocarbon and NO become unbalanced. Not enough hydrocarbon would
be present to oxidize the NO to N02 to in turn produce ozone before
atmospheric mixing and dilution lowered all concentrations. This
result is specific to Denver's bad ozone days (3 August and 28 July
1976). Regions with other emission mixes or patterns and other
dispersion climatology can expect different results. Specifically
167
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areas with more persistent inversion conditions will probably have
a worse ozone and N02 problem with the NO emissions standard relaxed.
As was previously discussed, the Clean Air Act Amendments have
been passed and the NO emission standard has in fact been set at 1
gpm beginning in 1981. However, the simulation which was conducted
for this scenario also assumed much stricter and earlier compliance
with the statutory hydrocarbon standard of .41 gpm than will be the
case under the Clean Air Act Amendments. Therefore, higher ozone
levels than the model predicted could logically be expected in the
future. Additional studies by EPA and the State of Colorado will
address this point in more detail. Therefore, this simulation does
not represent an accurate protrayal of the effects of relaxation of
NOX and hydrocarbon standards which has now taken place.
It should be noted that relaxing the NOX standard results in
a larger NO plume coming from Denver. Any downwind area releasing
hydrocarbons into this plume will experience large ozone concen-
trations because of the reaction with the N0£ originating from
Denver's NO emissions. Also, the predicted decrease in ozone con-
centrations in the Denver region would, of course, be accompanied
by increases in NO concentrations. Although there is no federal
air quality standard for NO, (only an N02 standard), it is not
probable that increased NO concentrations are desirable. NO does
oxidize to N0£ and N0£ is a regulated pollutant. Increased NO
emissions do not necessarily lead to increased N0£ concentrations
in the Denver region for reasons similar to those explaining the
ozone reduction. Increased downwind N0£ concentrations could, how-
ever, be expected, because of the longer time available for the con-
version of NO to N02- It follows from the foregoing that relaxation
of the NO standard should not, as a result of this study, be consid-
ered an ozone control strategy. Furthermore, potential downwind
effects of the standard relaxation on NO and ozone have not been
evaluated and neither have potential impacts on public health of
higher NO concentrations in Denver.
Effects on Agricultural Crops
The effects of air pollutants have been well documented. How-
ever, much is yet to be learned, and methods for forecasting dollar
loss as a function of air quality and crop type are not well developed.
Reference 908 is the only method which has been applied to obtain
national estimates. This method, termed the Factor Method, provides
a means for determining loss from a series of factors which account
for emissions, meteorology, frequency of episode days, and crop
sensitivity. Alfalfa is the only crop for which an alternative
method if available. See Reference 909. This method relates dose,
in pphm - hours exposure to ozone, to percent reduction in produc-
tivity. Using 1974 ozone data from the Welby air quality monitoring
station, dollar losses for alfalfa ranged from 16 to 24 percent.
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Using the Factor Method, a loss of 20 percent for alfalfa is fore-
cast. When the Factor Method is applied to the crops produced in
Adams, Arapahoe and Boulder Counties, generally downwind of Denver,
a total loss of over 16 percent is forecast. This amounts to about
$6,800,000.
Air quality is expected to improve insofar as ozone is con-
cerned. If the same crop mix and dollar value is assumed for the
next 25 years, and a 5 pphm threshold for crop damage is assumed,
the dollar losses for 1985 and 2000 are forecast to be about
$3,600,000 and $2,200,000, respectively. This amounts to about
$95,000,000 over the 25 year period. If the future ozone levels
were reduced by 20 percent, the loss over the 25 year period would
be reduced 21 percent to $75,000,000.
169
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WATER QUALITY
Three major alternative wastewater collection and treatment
programs for the study area, the LOCAL, REGIONAL and NO-ACTION
alternatives, were identified and discussed in Section III of this
document. Ten 201 facilities plans and their respective planning
areas, as shown on Map J, encompass the individual units of these
three major alternatives and collectively serve the majority of
the study area's stream basins, as discussed in Section II. The
status of existing and proposed wastewater facilities is given in
Table IV-P. The proposed 201 facility plans addressed in this EIS
are underlined.
The following subsections will assess the likely water quality
impacts and improvement in beneficial stream uses both for the imple-
mentation of these three major point source control alternatives
and for feasible non-point source controls.
Background
Reviewing information presented in Section III, it can be noted
that the local alternative is typified by the expansion and upgrad-
ing of existing facilities with satellite plants in the Cherry
Creek., Clear Creek and lower South Platte basins, whereas under the
regional alternative, the satellite plants would not be constructed
and excess wastewater flows above the capacity of the upgraded exist-
ing facilities would be sent to the Denver Northside/MDSDD #1 complex.
The no-action alternative is typically the same as the local one
except for various time delays in the expansion and up-grading pro-
gram. Under all the alternatives, the levels of treatment to be
provided include additional removal of BOD5 and suspended solids to
effluent levels of 20 mg/1 each, and reduction in effluent ammonia
levels to approximately 3 mg/1. In addition, residual chlorine levels
in the effluents will be reduced. The location and sizing/staging
of the various wastewater collection and treatment facilities for
the local and regional alternatives are shown in Figures III-A and
IH-B, respectively, and are discussed in greater detail in Section
III.
The Federal Water Pollution Control Act Amendments of 1972 indi-
cate that it is the national goal to meet by 1983 levels of water
quality which provide for "protection and propagation of fish,
shellfish and wildlife and provide for recreation in and on the
water". The Act also declares as a national goal "that the dis-
charge of pollutants into the navigable waters be eliminated by 1985".
The Colorado Water Quality Control Commission has classified
the majority of the streams in the Denver region by category of
beneficial uses and has established the water quality required to
achieve and/or maintain those uses in accordance with the 1983 goals.
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Table IV-P. STATUS OF EXISTING/PROPOSED WASTEWATER COLLECTION
AND TREATMENT FACILITIES UNDER THE LOCAL, REGIONAL
AND NO-ACTION ALTERNATIVES
Basin
Existing or
proposed facility
Status under
local alternative
Status under
regional alternative
Status under
no-action alternative
Bear Creek
Cherry Creek
Morrison
Glendale
Sand Creek
Aurora
(Expand plant to
2 mgd)
Fitzsimfflons
Assumed will maintain present level Same as local
of secondary treatment but will add
nutrient removal to reduce effluent
ammonia (NHj-N) to 3 mg/1
Assumed will maintain present level
of secondary treatment but will add
nutrient removal to reduce effluent
NH -N to 3 mg/1 and reiuce
residual Cl.
AWT plant to be built in 1985 only
if feasible at that time. Effluent
at secondary level when used for
reuse (industrlal/agri), tertiary
when discharged to Cherry Creek.
Flows above plant capacity sent
to Denver/Northside/Metro //I
system ^
Expanded/upgraded new facility to
meet effluent levels of 20 mg/1
each for BOD, and suspended solids
(SS) and NH.^N to 3 mg/1. Residual
chlorine (Cl) reduced to 0.05 mg/1
and fecal coliform (Fc) to 1000 UPC/
100 ml. Effluent to Quincy Reservoir
for reuse. Flows above plant capacity
to Metro HI via interceptor for
treatment
Plant abandon and flows sent to Sand
Creek Satellite (Aurora new plant)
Same as local
All flows sent to Denver/
Northside/Metro tl system
(except Glendale) via
Cherry Creek/Goldsmith
Gulch interceptor
All flows via interceptor
to Metro fll for treatment.
Aurora plant abandoned.
Same as local but
but ammonia removal
facilities would be
added at later date
Same as local
Same as regional but
construction of inter-
ceptors delayed two
years
Same as regional but
construction of inter-
ceptors delayed three
years
Plant abandoned and flows
via interceptor to Metro fl
for treatment
Same as regional but
construction of inter-
ceptor delayed three
years.
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Table IV-P.
STATUS OF EXISTING/PROPOSED WASTEWATER COLLECTION
AND TREATMENT FACILITIES UNDER THE LOCAL, REGIONAL
AND NO-ACTION ALTERNATIVES (continued)
Basin
Clear Creek
Existing or
proposed facility
Status under
local alternative
Coors
Clear Creek Satellite
(also serving North
Table Mtn., Applewood,
Golden, and Pleasant
View) (b.56m(5d)
Wheat ridge. Clear
Creek Valley, Arvada,
Crestview
Assumed to be upgraded to meet
secondary treatment levels with
nutrient removal to reduce effluent
NHj-N to 3mg/l
Assumed to construct AWT plant meet-
ing effluent levels of 20 mg/1 each
for BOD, and SS, 3 mg/1 for NHy-N,
residual Cl to 0.05 mg/1, and PC
of 1000 MPN/lOOral. Effluent levels
nay be more stringent depending upon
discharge/reuse.
Plants abandoned and flows via
interceptor to Metro SI for treatment
Status under
regional alternative
Status under
no-action alternative
Sarce aa local
Flows via interceptor to
Metro ill for treatment
Same as local
Same as local
Local alternative
delayed three years
Local/regional but
construction of inter-
ceptor delayed three
years
South Platte
South Metro
Middle
Lower
Northglenn
EnBlewopd/Llttleton
(20 mgd)
South Lakewood
Metro #1
Northglenn
(5 mgd pretreatment
prior to storage or
reuse for agricultural
exchange)
The Englewood and Littleton plant is
expanded in capacity and NH3-N and Cl
removal facilities are added. 30 mgd
in 1982, and 40 mgd in 1993- AWT ef-
fluent levels assumed at 20 mg/1 eacli
for BODj and SS, NHj-N of 3 ng/1 and
residual Cl at 0.01 mg/1
Expand/upgrade to 3 mgd AWT plant
and discharge to South Platte.
Ho additional added capacity
above 190 mgd. NH3-N removal to
various levels depending upon
effluent discharge/reuse options
All flows to new pre-treatment fa-
cility at Dull Canal Reservoir. All
effluent used on agricultural ex-
change. 5 mgd by 1982.
Existing plant upgraded
to AWT levels (as shown
in local alternative) with
flows In excess of plant
capacities sent to Denver/
Northside/Metro II system
Abandon existing plant and
transport all flows to
Metro dl interceptor/plant
Capacity expanded to
260-270 mgd with NII3-N
removal to various levels
depending upon effluent
discharge/reuse options
All flows to MDSDDiPl.
Addition of NH3-N and
Cl removal facilities
at existing plant de-
layed till 1982. Ex-
pansion to 30 mgd de-
layed to 1986.
Maintain existing
plant with effluent
sent to Metro fl for
further treatment.
Local alternative
with further expan-
sion beyond 1985 de-
layed
Same as regional al-
ternative.
-------
Table IV-P.
STATUS OF EXISTING/PROPOSED WASTEWATER COLLECTION
AND TREATMENT FACILITIES UNDER THE LOCAL, REGIONAL
AND NO-ACTION ALTERNATIVES (continued)
Basin
Existing or
proposed facility
Status under
local alternative
Status under
regional alternative
Status under
no-action alternative
South Adams County
Big Dry Creek
Coal Creek
Boulder Creek
Lower South Platte
Satellite Plant at
164th Avenue
(8.7 mgd)
Broorof lej d/Westminster
Erie, Lafayette, Louisville
1985: 0.4 mgd, 1.3 mgd,
1.3 mgd; 2000: 1 mgd, 2 mgd,
2 mgd
Boulder/White Rocks 18 mgd
Expand/upgrade existing plant to
6 mgd by 1986. Effluent at 20 mg/1
each BOD5 and SS, NHj-N at 3 mg/1
winter - 7 mg/1 summer, and FC at
6000 MPN/100 ml. Residual Cl at
0.5 mg/1. Effluent discharge to Bur-
lington Ditch.
New plant to treat flows from
Brighton; and 1st, 2nd, and 3rd
Creeks. Effluent at 20 mg/1 each
BOD3 and SS, NHy-N at 3 mg/1, FC at
1000/100 ml, and residual Cl of 0.05
mg/1. Flows from Upper Thornton and
NWSWDS to Metro #1. Flows from Lower
Thornton used by Northglenn in agri-
cultural exchange. Oiptlon to pump some
of plant flow to Big Dry Creek plant.
Big Dry/Westminster plant expanded up-
graded to 9 mgd with 20 mg/1 each BOD5
and SS, NII3-N at 1.0 mg/1, FC at 1000/
100 ml, and residual Cl at 0.02 mg/1.
Plant treats excess flows from Broom-
field and flows from Westminster and
some of Thornton. Discharge to either
Farmers High line Canal or Big Dry
Creek.
Expand/upgrade existing facilities to
20 mgd/1 each BOOc and SS, NH3-N at
3 mg/1, FC at 200/100 ml
Add tertiary treatment via biologi-
cal mechanical processes with dis-
charge to Boulder Creek.
Plant expanded to 3.75 mgd
by 1978 but abandoned by
1985 with all flows to
Metro II.
All flnws to Metro Jl ex-
cept flows from Brighton;
Isl, 2nd and 3rd Creeks to
new plant.
Maintain current capacity of
Big Dry/Westminster plant at
2.5 mgd. Maintain other
plants at existing capacity
and excess flows to Metro #1
Same as local
Same as local
Expansion to 4.25 in
1978. Final 1.75 mgd
added in 1990.
Local alternative with
construction of new
plant delayed fqur
years, and Lower Thorn-
ton flows to Big Dry
Creek plant.
Expand Big Dry/West-
minster to 5 mgd with
NH3-N removal. Main-
tain otfier plants and
excess flows to Metro
II.
Same as local but ex-
pansion/upgrading de-
layed
Same as local
-------
The DRCOG, in developing the Clean Water Plan, performed exten-
sive reviews and investigations of current state stream classifica-
tions and water quality standards. Four alternative levels of classi-
fications were established and the concomittant facilities, plans and
cost required to meet each alternative level determined. The highest
levels, Alternative Classification 1, are governed primarily by pri-
mary contact, cold or warm water biota and potable supply water uses.
From Alternative Classification 1, the alternatives descend in levels
of water quality to Alternative Classification 4 levels, which are
primarily secondary contact, agriculture and wildlife uses and which
generally represent present water quality. Through extensive review
and public participation programs, recommendations were made as to
the alternative classification level that was achievable and consis-
tent with the 1983 goals for each portion of each stream. These
recommendations were then incorporated into the Clean Water Plan.
Both the current State of Colorado stream classifications and those
recommended in the Clean Water Plan are shown in Table IV-Q.
A direct comparison between the current State of Colorado
classifications and the classifications recommended by the Clean
Water Plan is not straightforward. Generally, the headwaters of
the streams are either recommended for continued high classification
levels or upgraded. Downstream segments of the South Platte River
and Clear, Coal and Boulder Creeks are downgraded and would no longer
include maintenance of biota and, in some cases, public water supply
uses. The Clean Water Plan recommended classifications have not
been adopted by the State of Colorado as of March 1978.
Shown in Table IV-R are the current and proposed water quality
standards considered as necessary and sufficient to meet the 1983
goals within the study area. The standards proposed by the Clean
Water Plan have not been adopted by the State of Colorado as of
March 1978, but are comparable to, or for some parameters more
stringent than, the criteria proposed by the Colorado Department
of Health.
The information presented in Table II-H of Section II of this
volume, indicates that the only location within the study area that
presently consistently meets the water quality criteria established
in the Clean Water Plan to meet the 1983 goals presented in Table
IV-Q for all seasons is the upstream reach of the South Platte,
above Chatfield Reservoir. The upper portions of the remaining
basins are, for the most part, well within proposed standards except
for ammonia and phosphate during all seasons; and fecal coliforms,
during the spring at Bear Creek/Morrison and Clear Creek/Golden.
Thus, the background quality of water entering the major basins
within the study area is generally high. However, as can be seen
from the review of Table II-H, the water quality of the streams is
degraded as they pass through the lower portions of their respective
174
-------
Table IV-Q. CURRENT AND RECOMMENDED STREAM
CLASSIFICATIONS BY STREAM REACH
Stream and Reach
South Platte River
Headwaters to Dartmouth Avenue
Dartmouth Avenue to MDSDDlfl Outfall
MDSDDtfl Outfall to Weld County Line
Bear Creek
Headwaters to Mouth
Cherry Creek
Headwaters to just above Reservoir
Cherry Creek Reservoir
Cherry Creek Reservoir Outlec to Mouch
Clear Creek
Headwaters to Golden (Farmer Ts
Highline Diversion)
Golden Co Mouch
Recommended
Classification
1,2,3.4,6,7,8
2,3,8a
2,3,8
1,2,3,4,6,7,8
1,2,3,5,6,7,8
1,2,3,5,6,7,8
2,3,6,8
1,2,3,4,6,7,8
2,3,6,7,8C
Clean Water Plan
Classification
Level
1
4
4
1
1
1
3
1
3
Current State
Classification
Bl
B2
B2
Bl thru Morrison
B2 remainder
None
A2
None
Bl
B2
Sand Creek
Headwaters to Mouth
2,3,8b
Clean Water Program Classification Definitions
1 - Primary Contact, 2 - Secondary Contact, 3 - Agriculture
4 - Cold Water Biota, 5 - Warm Water Biota, 6 - Water Supply-grounduater,
7 - Water Supply - surface water, 8 - Wildlife
State of Colorado Classification Definitions
Al Suitable for all uses, including domestic water supply,
primary contact recreation (e.g., swimming), secondary
contact recreation (e.g., boating), and cold water fishery.
A2 Suitable for domestic water supply, primary contact recreation,
and warm water fishery.
Bl Suitable for domestic water supply, secondary contact
recreation, and cold water fishery.
B2 Suitable for domestic water supply, secondary contact
recreation, and warm water fishery.
Footnotes
^To consider potential water supply conflict with Brighton and
Thornton.
To consider water supply for South Adams.
Alternative 1 to be kept open as an option.
None
Big Dry Creek
Headwaters to Standley Lake (inclusive)
Standley Lake Outlet to Weld County
Line
Coal Creek
Headwaters to Highway 93
Highway 93 Co Mouth
Boulder Creek
Headwaters to 75th Street
Wastewacer Treatment Plant Outfall
Plant Outfall to Coal Creek
Coal Creek to Mouth
1,2,3,5,6,7,8
2,3,5,8
1,2,3,4,6,7,8
2,3,6,8
1,2,3,4,6,7,8
1235678
2,3,8
1
3
1
3
1
4
None
None
Bl
82
Al
A2
B2
175
-------
Table IV-R.
CURRENT AND PROPOSED WATER QUALITY STANDARDS
TO MEET 1983 GOALS
Parameter Units
Temperature C
Minimum for swimming
Maximum
Cold water biota
Warm water biota
Swimming
Dissolved Oxygen mg/1
Cold water biota
Warm water biota
Total Dissolved Solids mg/1
Fecal Collform MPN/lOOml
Primary contact
Secondary contact
Fecal Streptococcus MPN/lOOml
Primary contact
Secondary contact
Chlorine Residual rag/1
Cold water biota
Warm water biota
Ammonia (NH3-N) mg/1
Cold water biota (un-ionlzed)
Warm water biota
Phosphate mg/1
Nitrate/Nitrite mg/1
Clean Hater Plan
Recommendations
15
20
30
5(b)
7
2,000
200
200
(a)
(a)
(a)
0.02
0.02
0.1
(a)
a. No numerical standard given.
b. Concentrations of dissolved oxygen are minimums allowed.
c. A 7 mg/1 standard will be set during periods of spawning of coldwater
d. Numerical criteria will be established for specific waters to prevent
Current Colorado
Standards
(a)
20
32
(a)
5
6
(a)
200
1,000
20
(a)
(a)
(a)
(a)
(a)
(a)
(a)
fish.
degradation such as to prevent noxious
Proposed Colorado
Standards
(a)
20
30
(a)
5
6(c)
(a)
200
1,000
(a)
(a)
0.002
0.01
0.02
0,10
(d)
algal
blooms or over-eutrophicatlon.
Values are for nitrate and nitrite respectively to protect domestic raw water supply. Values for livestock water
supply are 100 and 10 mg/1 respectively.
-------
basins. For all locations, temperature criteria are met, on the
average by season, except during the winter, when the proposed
Clean Water Plan standard for swimming is exceeded. However, this
activity is unlikely to occur during the winter season. Dissolved
oxygen levels are still relatively high throughout the major basins
during all seasons, with the exception of South Platte above Little-
ton during the summer. This may in parf be due to the release of
low-level dissolved oxygen waters from Chatfield Reservoir during
the summer months, the reason for which is unknown at this time.
Levels of total dissolved solids, although below the suggested levels
for the 1983 goals in all major basins, do tend to increase substan-
tially from upstream levels in any basin. Average ammonia levels
exceed proposed state standards for current stream classifications
in Sand Creek and the lower South Platte year round, and in the
downstream reaches of the other streams during winter. High levels
of ammonia during runoff events may be caused in part by animal
grazing in the plains east of Denver and in the hills west and south
of Denver. The Clean Water Plan recommends a numerical standard for
phosphate, but the State of Colorado is proposing that numerical
criteria be based upon a case-by-case examination of "the signifi-
cance of phosphate to specifically identified water quality problems.
Under the Clean Water Plan recommended standard, phosphate presents
a problem year round in Denver region streams. Current and proposed
Fecal Coliform Standards are exceeded year round in Sand Creek and
in the lower South Platte and in all streams during runoff events.
It is within this general context that the three major waste-
water collection and treatment alternatives in this report were
developed and will be analyzed in the following subsection. Also,
their likely impacts upon water quality and the likelihood of their
meeting or approaching the 1983 water quality goals within the con-
text of the Clean Water Plan for control of non-point sources of
pollutants will be analyzed. The status of existing or proposed
wastewater collection and treatment facilities within the study
area's stream basins is indicated in Table IV-P. In addition, it
should be noted that there is the likelihood that wastewaters from
the City of Golden will be treated at an advanced waste treatment
(AWT) facility, which would-allow the City of Golden the option of
reusing the effluent in the upper portion of Clear Creek.
The Local Alternative
The upgrading of the Morrison Sewage Treatment Plant (STP) to
provide ammonia removal is expected to provide some reduction in
the point source loading to Bear Creek. However, as can be observed
in Table II-I, point sources do not account for a significant por-
tion of the ammonia loading in the basin, particularly in the upper
reaches. It appears necessary to provide a fairly high degree of
non-point source control in order to reduce loadings of all con-
stituents which are adversely affecting the Bear Creek Basin, as
can be noted in Table II-H.
177
-------
On Cherry Creek, above the reservoir, the option for an AWT
plant exists. This plant would have a very high level of treatment
when discharging to Cherry Creek and thence to the reservoir. How-
ever, this would occur only during the non-irrigation seasons. At
other times, effluent would only be treated to the levels necessary
for agricultural irrigation reuse. In theory, if additional flows
into the reservoir during winter were equalled by additional down-
stream discharges from the reservoir, the flow in Cherry Creek would
about double in 1985 and increase another 50 percent in 1995. How-
ever, any augmentation of creek flow would be limited to winter
months, this additional flow, coupled with ammonia removal at the
Glendale plant would improve water quality levels throughout lower
Cherry Creek, but phosphate may present a problem. Beneficial uses
of secondary contact recreation would be restricted to that portion
of Cherry Creek between the reservoir and Glendale, as the remainder
of the creek is channelized with access-limiting, vertical concrete
walls.
The provision of AWT facilities at the present Aurora STP site
is expected to result in a significant reduction in point source
loadings of ammonia in Sand Creek. However, by removing the efflu-
ent flows to the stream and transferring water to Quincy Reservoir,
it appears that stream flows in Sand Creek would then be too low
to provide secondary contact recreation opportunities. The question
of water rights and transfer appears to be of major importance in
this basin because it is likely that stream flows necessary for
secondary contact recreation would occur only during the spring
season, when storm runoff augments the base flows.
The provision of AWT facilities on Clear Creek (Golden and
satellite plants), along with improved treatment at Coors and the
removal of effluent flows at the STP's in the lower portion, would
vastly improve the water quality of Clear Creek. As indicated
in Section II (Existing Water Quality), this basin is significantly
impacted by point source loadings, particularly by BOD5, ammonia
and phosphate. No standard exists for phosphate although the Clean
Water Plan recommends a standard of 0.1 mg/1. If the Colorado Depart-
ment of Health finds that phosphate is contributing to water quality
problems on Clear Creek, a numerical limit may be set under proposed
state regulations. If the Clean Water Plan recommendation is adopt-
ed by the State, phosphate removal from point discharges to Clear
Creek would be necessary.
Another major problem area, the portion of the South Platte,
between Littleton and 38th Avenue, would be alleviated by the up-
grading of treatment at the Littleton and Englewood joint plant at
Englewood. As was noted in Table II-H, point source loadings in this
portion of the South Platte are significant with regard to BOD5,
ammonia and phosphate. Once again, however, the need for phosphate
removal in addition to planned reductions in BOD5 and ammonia will
depend upon findings by the Colorado Department of Health.
178
-------
Within the middle portion of the South Platte, the expansion
and upgrading of the South Lakewood STP will have a positive,
although less significant, impact upon improving water quality in
the South Platte. The removal of ammonia from the plant's effluent
would benefit the South Platte waters. This portion of the South
Platte is clearly dominated by non-point sources for all water
quality parameters (see Table II-H), and any additional expenditures
at the South Lakewood STP for secondary treatment with ammonia
removal would not be likely to prove cost-effective. Highly effec-
tive non-point source controls would be needed to achieve 1983 goals.
Within the lower South Platte, existing water quality is most
clearly dominated by point sources, and most particularly by MDSDD #1.
The upgrading of effluent quality at MDSDD #1 and South Adams County
STP's would improve water quality above Henderson, and the satellite
plant serving the Brighton area would also have a positive impact
below Henderson. However, because of the very substantial contri-
bution of loadings from MDSDD #1, particularly in total dissolved
solids, BOD5 and ammonia, it appears that diversion of a sizeable
portion of MDSDD #l's effluent to Burlington Ditch for irrigation
reuse would not only have a greater positive effect upon water quality
in the South Platte, but might also be cost-effective in terms of the
cost of higher levels of treatment.
Under the local alternative, the remaining facilities in the
Big Dry, Coal and Boulder Creek basins are to continue discharging
to their respective streams with high levels of effluent quality for
protection of stream quality. The options to discharge a portion
of the effluent from Big Dry STP to the Farmer's Highline Canal, and
all the treated wastewater flows from Northglenn to the Bull Canal
for reuse as irrigation water appear to be better uses of the
basin's water (Reference 261). Provided cost effectiveness can be
demonstrated and the necessary transfer of water rights can be
arranged, the Big Dry Creek option also appears to best protect the
water quality, however, some small stream flow reduction is likely.
From an evaluation of information presented in Table IV-P and
from the Wasteload Allocation Report (Reference 261), it appears
that the levels of point source treatment proposed in the local
alternative may provide stream water quality which would approach
the stream classification levels recommended in the Clean Water
Plan. The gap between desired and actual water quality would be
even greater if the comparison is made with current state classifi-
cation levels which are higher than those recommended in the Clean
Water Plan for the downstream reaches of most streams. This con-
clusion would be more favorable if the comparison were restricted
to average stream flows, sizeable portions of MDSDD #l's effluent
were diverted to the Burlington Ditch, and the Clear Creek and Cherry
Creek satellite plants were designed to produce effluent at quality
levels sufficient for desired stream water quality. Regardless of
179
-------
of point source treatment levels, neither current nor recommended
stream classifications pursuant to the 1983 goals can consistently
be met because of non-point pollution.
The Regional Alternative
In the Bear, Cherry, Sand and Clear Creek basins, only the
Morrison, Glendale and Coors STP's would be upgraded, while all
other wastewater would be transported for eventual treatment at
MDSDD #1. However, the resultant reductions in base stream flow in
Cherry Creek would likely reduce the potential for secondary con-
tact recreation to the spring season alone, when non-point source
control would become necessary. In the Clear Creek basin, the
reduction in streamflow might impair water rights. The overall
impact would be the basinwide reduction in Clear Creek's base flows,
resulting in a greater need for non-point source controls within
the basin than might otherwise be necessary to compensate for the
loss of dilution available with higher base flows.
With the portion of the South Platte immediately below Little-
ton, the existing Littleton and Englewood joint STP would be up-
graded and all flows in excess of the plant's capacity would be sent
to MDSDD #1. There would be reductions in point source loadings,
particularly with regard to ammonia and BOD5, and the transport of
excess flows to MDSDD #1 would further reduce the impacts of point
sources on the water quality of the South Platte in this area.
By transporting all domestic wastewaters from the middle por-
tion of the South Platte to MDSDD #1 for treatment, the impact of
point sources would be removed. However, as can be noted from
Table II-I, the major contribution of pollution in this portion of
the South Platte stems from non-point sources. Recognizing that
non-point source pollution would probably occur more frequently
during the spring, the improvement in water quality for the South
Platte in this area would likely be more noticeable during the
summer season. Loss of the discharge from South Lakewood would be
insignificant as it would contribute only 10 percent of low flow
in the South Platte. This, coupled with the provision of South
Platte stream-bank parks, would increase the opportunity for second-
ary contact recreation during the summer, particularly if upstream
water quality improved in the portion of the South Platte immediately
below Littleton.
With MDSDD #1 expanded to handle all the flows diverted from
the other basins, the lower South Platte basin would experience the
flow of a very large point source at its upper portion, with other
point sources downstream, except for Brighton, from MDSDD #1 elimi-
nated. This configuration, as compared to the local alternatives
180
-------
of three smaller point sources located along the South Platte from
Contmerce City to Brighton, might result in considerably reduced
stream water quality in a stretch of the South Platte below MDSDD #1,
although there would be some downstream recovery. The local alter-
native could provide a more uniform level of water quality than
the regional alternative. The extent and degree of reduced water
quality in this reach under the regional alternative, is unknown
at this time. It is likely, however, that under the regional alter-
native equal or greater consideration would have to be given to dis-
charging a significant portion of MDSDD #l's effluent to Burlington
Ditch. This may be necessary not only to protect water quality and
downstream water supply uses of the South Platte, but also to reduce
the sizeable expenditure of funds that may be necessary to produce
an effluent acceptable for stream discharge. This remedy could be
limited, however, because nutrient loads in Barr Lake would be
increased as a result and over eutrophication may occur.
The configurations and probable water quality impacts for Coal
Creek and Boulder Creek would be the same as for the local alter-
native, i.e., the improvement of water quality in streams, whose
base flows come principally from STP effluents. However, the option
of reusing effluent from the Big Dry Creek STP for irrigation pur-
poses in the Farmer's Highline Canal is not included in the regional
alternative, and basin flows are transferred to MDSDD #1, rather
than being utilized to maintain streamflows in Big Dry Creek. Unlike
the local alternative, there have been no definitive studies with
regard to the overall impact of the regional alternative on the study
area's water quality. The individual stream basin impacts of the
various facility plans have been discussed above and the overall
impact may be assessed in general. Under the regional alternative,
most point sources are removed from the Sand, Clear and middle
South Platte basins, thus reducing their pollution impacts upon
these streams (Table II-I). However, doing so, the basins are ren-
dered more susceptible to fluctuations in base flow and to influences
of non-point sources which, as noted in Section II, are significant
within the study area. It is therefore likely that the control of
non-point sources in these basins will become more important in the
effort to approach 1983 water quality goals. The impact of point
sources in the lower South Platte becomes more important for MDSDD #1
than in the local alternative, as discussed above. It is likely
that in order to approach 1983 water quality goals for the lower
South Platte, MDSDD #1 either would have to provide a very high level
of treatment or would have to divert a very significant portion of
its effluent to the Burlington Ditch.
181
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The No-Action Alternative
As can be noted from Table IV-R, the overall status of the no-
action alternative is to maintain the existing plant configurations
for the next several years. After this time, flows in the Sand and
Cherry Creek basins and in the lower portion of Clear Creek basin
would be sent to MDSDD #1. Satellite plants would be constructed
in the Clear Creek and lower South Platte basins and the Big Dry
Creek plant would be expanded to handle more of its basin's waste-
waters. The South Lakewood plant would send its effluent to MDSDD #1
for further treatment; the Englewood/Littleton facilities would
eventually be expanded; and the South Adams STP would be expanded
to handle more of its basin's wastewaters.
The immediate impact of this alternative is the continuing
degradation of water quality in the upstream portions of the streams
of the study area, and the maintenance of the status quo on the re-
maining portions. Following the period of upgrading, expansion and
routing of wastewater flows, as described earlier, the impact of
point sources in the basins within the study area would be reduced,
particularly in the Sand, Cherry and middle South Platte basins.
Although no rigorous assessment of the stream water quality
that will result from the implementation of this alternative is
available, it appears that the alternative does combine some of the
best features of the two previous alternatives. There is not such a
heavy reliance upon treatment of most wastewater flows at MDSDD #1;
the Big Dry Creek basin maintains its option of irrigation reuse of
its effluent; point sources are treated in the South Metro portion
of the South Platte; and the impact of point sources in the lower
South Platte is reduced and spread out rather than being concentrated
in one portion. However, point sources will still contribute to water
quality problems in the upper portion of the Clear Creek basin unless
treatment levels at the satellite plant are such that either some
form of effluent reuse can be implemented or downstream water quality
is protected. Under this alternative, non-point sources become the
influencing factor in the Sand, Cherry and middle South Platte basins.
It is likely that resultant stream water quality within the study
area under the no-action alternative will approach that of the local
alternative, but at a later time.
The principal differences between the no-action alternative and
the local alternatives are a likely delay of 3 or more years in the
implementation of point source water quality improvements with the
burden of paying for these improvements shifted to local government
and local taxpayers.
182
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Summary
Utilizing information from Section III and Reference 261, Table
IV-S indicates the anticipated 1985 non-point source loadings by
basin and the resultant point source loadings within the same basins
after implementation of each of the three major alternatives. It
should be noted that the point source loadings assume discharge to
the representative creeks. The exceptions are the Sand Creek satel-
lite plant, as mentioned previously, which will discharge its efflu-
ent to Quincy Reservoir or reuse it for urban irrigation under the
local alternative, and the Boulder STP, which is assumed will dis-
charge to percolation ponds or otherwise discharge a high quality
effluent. The levels of treatment for the wastewater facilities
were noted in Table IV-R, except for MDSDD #1, which is assumed to
discharge a secondary level effluent, i.e. BOD5 of 30 mg/1 and
ammonia of 3 mg/1. Phosphate levels in all treatment plant effluents
are assumed at 8 mg/1. The Boulder STP is assumed to have a negligi-
ble effect on Boulder Creek.
It can be seen by comparing Tables IV-S and II-I that non-point
sources of pollution are expected to increase throughout the study
area by approximately 49 percent for each of the parameters shown in
Table IV-S. This increase is a direct consequence of further urban-
ization in the Denver region. Those basins with the largest projected
non-point source loading increases are Bear Creek (200 to 220 percent),
Cherry Creek (BOD5 and phosphate 75 percent, ammonia 100 percent),
Clear Creek (60 percent), and lower South Platte (70 percent).
Pollutants from point sources would also be expected to increase as
a result of growth, but treatment by wastewater treatment plants may
negate or offset growth effects, thus pollutant loadings from point
sources may be minor compared to non-point loadings. For example,
by 1985, on Clear Creek under the local alternative, the non-point
loading for BOD^ will increase by 60 percent, whereas the point
source loading will decrease 30 percent compared to 1972. Thus,
while point sources dominate total loadings in the Clear Creek basin
in 1972, non-point loadings will dominate in 1985. This would be
true even if non-point loadings were reduced by one-third under an
effective non-point source control program.
An examination of the total basin-wide loadings in Table IV-S
indicates that the majority of 8005, ammonia, and phosphate will
originate from point sources. However, if those loadings in the
lower South Platte, principally from the Denver Northside/MDSDD #1
complex are deleted, only phosphate will still be dominated by point
sources. All other pollutants are dominated by non-point sources.
It must be remembered that, non-point sources of pollutants in most
cases only affect water quality when they enter a stream via some
runoff event such as snowmelt or precipitation. Thus, their contri-
bution is not constant as are the contributions from point sources.
183
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Table IV-S. ANTICIPATED POINT AND NON-POINT SOURCE LOADINGS IN THE
YEAR 1985, BY STREAM BASIN (pounds per day)
Basin
R«?ar Creek
Chorty Creek
Sand Creek
Clear Creek
South Matte
South Metro
Middle
Lower
Subtotal
Bip, Dry Creek
Coal Creek
Koulder Cireek
Total
Nonpoinf
source
2,900
4,300
7,200
6,600
3,900
10,000
7,200
42,100
2,800
2,000
5,500
52,400
Local
18
1,430 (430)
0
3,350
5,470
370
37,705
48,343 (47,343)
820
500
-
49,663 (48,663)
BOD 5
Point source
Regional
18
100
0
2,300
4,900
0
47,700
55,018
900
500
-
56,418
No-action
18
100
0
3,330
5,470
0
38,300
47,238
830
500
-
48,568
Nonpoint
source
246,500
268,500
578,000
554,000
324,200
851,000
548,000
3,470,200
227,000
175,300
463,500
4,336,000
TD:
Local
410
55,600
0
9«,300
132,800
12,000
944,100
1,243,210
28,600
17,500
-
1,289,310
S
Point source
Regional
410
8,900
0
60,100
113,000
0
1,160,000
1,342,410
21,000
17,500
-
1,380,910
No-action
410
8,900
0
98,300
132,800
0
960,000
1,200,410
29,200
17,500
-
1,247,110
-------
Table IV-S. ANTICIPATED POINT AND NON-POINT SOURCE LOADINGS IN THE
YEAR 1985, BY STREAM BASIN (pounds per day) (continued)
Basin
Bear Creek
Cherry Creek
Snnd Creek
Clear Creek
South Platte
South Metro
Middle
Lower
Subtotal
Big Dry Creek
I-1 Coal Creek
00
Ui
Boulder Creek
Total
Nonpoint
source
235
360
560
540
280
800
540
3,315
230
170
440
4,155
Local
2
225 (90)
0
390
575
55
3,850
5,097 (4,962)
100
75
5,272 (5,137)
NH3-N
Point Source
Regional
2
25
0
225
490
0
4,770
5,512
90
75
5,677
Mo-action
2
25
0
390
575
0
4,290
5,282
125
75
5,482
Nonpoint
source
210
320
530
490
280
750
530
3,110
200
150
410
3,870
Local
5
600 (87)
0
1,560
1,470
150
10,300
14,085 (13,572)
330
200
14,615 (14,102)
POi,
Point Source
Regional
5
70
0
1,130
],240
0
12,700
15,145
240
200
15,585
No-action
5
70
0
1,560
1,470
0
10,400
13,505
330
200
14,035
Note: Values in parenthesis for Cherry Creek - Local Alternatives are those resulting from high levels of
tertiary treatment at the Cherry Creek Satellite plant.
-------
Nevertheless, the Bear, Cherry and Sand Creek basins, as well as the
portion of the South Platte flowing through Denver proper, are domi-
nated by non-point sources of pollutants now and will continue to be
in 1985. Non-point sources would remain dominant even if a 35 per-
cent reduction of non-point loadings, as proposed in the Clean Water
Plan through nonstructural controls, were achieved in 1985. The
upstream portion of the South Platte would be dominated by point
sources, namely Littleton-Englewood, for BOD5, ammonia, phosphate
and TDS. The Clear Creek basin will become dominated by non-point
sources for BOD5 and ammonia, but will remain dominated by point
sources for phosphate and TDS. A 35 percent reduction in non-point
sources, as contemplated in the Clean Water Plan, would not change
this conclusion except that the contributions of ammonia would be
about equally balanced between point and non-point sources.
One particular point should be noted: in the local alternative,
the Cherry Creek satellite plant would appear to contribute signifi-
cant loads of BOD5, ammonia and phosphate to its basin if the efflu-
ent is to be discharged year-round. The plant's discharge levels
assumed under this alternative for these parameters were 20, 3 and
8 mg/1, respectively. Were these levels reduced to 5 mg/1 6005,
1 mg/1 ammonia and 0.3 mg/1 phosphate (tertiary treatment level 14,
as noted in Reference 262), the Cherry Creek basin point source load-
ings would be reduced to 195 kilograms (430 pounds) per day BOD5,
40 kilograms (90 pounds) per day ammonia, and 39 kilograms (87 pounds)
per day phosphate. It is therefore likely that the incorporation
of tertiary treatment at the Cherry Creek satellite plant, with the
effluent discharged only during the winter non-irrigation season,
would significantly enhance the quality and quantity of flows in
Cherry Creek.
There are two basic approaches to reducing the impact of MDSDD
#l's discharge on the lower South Platte. First is to reduce the
amount of the discharge, and second is to improve effluent quality
with higher levels of wastewater treatment. The first approach is a
limited possibility in that increased amounts of effluent may be
diverted to agricultural irrigation via the Burlington Ditch during
the irrigation season. If the amount of effluent discharge to the
South Platte were reduced to 0.66 cubic metres per second (15 million
gallons per day) under the local and no-action alternatives or 1.10
cubic metres per second (25 million gallons per day) under the re-
gional alternative, point sources for BODs and ammonia would then be
comparable to non-point sources during the irrigation season. How-
ever, point sources of phosphate, a potential contributor to water
quality problems, would still be two to three times non-point load-
ings. In addition, additional diversions to the Burlington Ditch
would increase nutrient loadings to Barr Lake and probably increase
existing eutrophication problems.
186
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The upgrading of effluent discharge quality at MDSDD #1 through
tertiary treatment to levels of 5 mg/1 BODs, 1 mg/1 ammonia, and 0.3
mg/1 phosphate, would have the following results in the lower South
Platte Basin. Under the local and no-action alternatives, BOD5 load-
ings from point sources would be comparable with non-point loadings.
Point sources for ammonia and phosphate would be two and three times
non-point loadings. Under the regional alternative, point sources
would still greatly dominate.
As mentioned previously, the implementation of any of the three
major wastewater collection and treatment alternatives is likely to
result in improved in-stream water quality enabling the use of stream
waters for secondary-contact recreation and protection of warm-water
biota most of the time. Present study area water quality levels in
downstream reaches are generally consistent with secondary-contact
and recreation uses. Clean Water Plan investigations of wastewater
treatment alternatives concluded that the improvement in the percent-
age of time that water quality sufficient to maintain a warm water
fishery in the South Platte downstream of Littleton could be main-
tained, did not justify the cost of high level secondary treatment
of wastewaters. Thus, maintenance of a warm water fishery in the
lower South Platte was not recommended as a water quality goal and
normal secondary level treatment was recommended. This difference
in treatment level is the major difference between the local alter-
native and the recommendations of the Clean Water Plan. The Clean
Water Plan generally recommends an effluent quality of 30 mg/1
suspended solids and BOD5, whereas the local alternative generally
assumes 20 mg/1 suspended solids and BOD5 with varying degrees of
ammonia removal. The effluent quality under the local alternative
is derived from facility plans which respond to current state,
rather than Clean Water Plan recommended stream water quality goals.
Regardless of treatment level, neither current or recommended stream
classifications can be met year-round by point source controls alone.
The implementation of the regional alternative is expected to
increase the percentage of time water quality criteria are met in the
Cherry, Sand and Clear Creek basins and to decrease it in the lower
South Platte (MDSDD #1 to Weld County line).
In the metropolitan area, the effect of non-point sources on
the attainment of recommended stream standards is significant. Non-
point source problems appear to be more pronounced in the Sand,
Cherry and middle South Platte basins and, to a lesser extent, in
the lower portions of the Bear and Clear Creek basins. The Clean
Water Plan has identified two major parameters, phosphate and fecal
coliform, from non-point source runoff that could constrain the
attainment of the "swimmable" criterion for Front Range streams
without some form of non-point source control. Assuming advanced
treatment of the point sources, there are fewer water quality limi-
tations to attaining the "fishing" and non-contact recreation cri-
teria, as shown in Table IV-T.
187
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Table IV-T. CONTROL REQUIREMENTS FOR POINT AND NON-POINT SOURCES
Pollutant
Principal Stream
Use Affected
Control Requirements
oo
oo
Phosphate
Ammonia
Nitrate
TDS
Fecal Coliform
Fecal Streptococci
Dissolved Oxygen
levels
(BOD, nitrification)
Body Contact
Fishery
Water Supply
Fishery
Agriculture
Water Supply
Body Contact
Fishery
Will likely require a combination
of point and non-point source
controls
Can currently only be effectively
removed from point sources.
Can be most effectively controlled
at point sources.
Can be effectively controlled
through non-point source programs.
Must be approached from both point
and non-point sources together.
Largely a function of point source
control on a sustaining basis and
of non-point source control for
storm-related events. Non-point
source control cannot make up for
a lack in point source control.
Chlorine
Fishery
Point source control.
-------
It has been noted in the Clean Water Program studies and con-
firmed in this analysis that even the most stringent control of
effluent quality from point sources will not be sufficient to meet
1983 water quality goals, and that significant non-point source
control will be necessary.
189
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GROWTH-INDUCED IMPACTS ON THE REGION'S ENVIRONMENTALLY
SENSITIVE AREAS
Wastewater collection and treatment is one of several basic
services local government provides to serve the needs of its citizens.
Planning to accommodate a future population and its need for waste-
water treatment and disposal is a prudent and responsible function
exercised by local governments. Construction and operation of these
facilities in accordance with plans to accommodate future growth
must be considered a contributing factor to the environmental conse-
quences of future growth. The same is true for other services, such
as highways, schools and water supply. On a regional basis, it is
rare that the provision or lack of a single "municipal" service
stimulates or constrains regional growth, and thus it is rare that
a single service can be considered the dominant factor in growth-
related environmental impacts. However, a single service, particu-
larly wastewater collection and treatment, can influence development
patterns. The purpose of this section is to summarize the impacts
of changes expected to occur in the region as a result of the popula-
tion increases and resultant development patterns projected for the
year 2000, for which the facility plans and the Clean Water Plan
were developed.
Climate
Construction activities randomly located throughout the region
will often be a factor in the local severities of Chinook wind
episodes by providing particulates that can be blown downwind from
construction sites to affect traffic, equipment operation, structures
and crops. The significance of this impact will range from that of
a nuisance to that of a hazard. Further development in the wind
corridors of the South Platte River and Clear Creek valleys will in-
crease the potential for wind damage in these areas. Early morning
radiation fog traffic problems, ranging from slow-downs to chain-
reaction accidents, will increase as traffic volumes continue to grow
in response to suburban growth.
Geology
Grading of undulating natural landscapes for urban development
can drastically modify landforms, change drainage patterns and alter
visual appearances. Grading impacts can be especially significant
in a local area where massive cuts and fills are made for road-build-
ing and hillside terracing, and in floodplains where protective de-
vices such as channelization, diversions and in-stream structures are
constructed. On a regional scale, these activities are likely to
have cumulative impacts on water quality. However, gross land form
characteristics will not be radically altered. Urban development
will occur near unique and significant geological structures and
190
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formations, threatening many of them with over-use and vandalism.
The region's geological hazards to development are generally local
in nature and do not pose any region-wide threats to urban expansion.
Soils
Many farmers on the Colorado plains have turned under winter
wheat crops due to low prices and drought conditions, leaving the
dry ground surface exposed to the season's high velocity winds.
Wind erosion can significantly reduce or destroy land's agricultural
production capabilities. In terms of soil loss, however, water
erosion is usually a more significant regional impact of urban ex-
pansion than wind erosion. Construction sites left exposed to pre-
cipitation and run-off experience sheet erosion, rilling and, at
times, gullying. All of these can clog drainage improvements; alter
the drainage net through additional streambank scouring, turbidity,
siltation and sedimentation; increase receiving water temperature;
and reduce chemical and biological water quality. These impacts, as
discussed in the preceeding "Water Quality" section, can have cumu-
lative long-term impacts on the region's drainage basins and water
quality.
Hydrology
Urban expansion can impact sensitive hydrologic features includ-
ing wetlands/marshes, floodplains, ground water and lakes in three
main ways. These are: (1) encroachment into or elimination of the
feature, (2) change in the amount and distribution of water flowing
to or through the feature and (3) change in the quality of water
flowing to or through the feature.
Grading and construction of buildings, roads and bridges can
encroach into or eliminate wetlands/marshes, lakes and natural flood-
plains . The proximity of development can affect both the flora and
fauna of the hydrologic element. Development can alter the extent
of the flood hazard area limits through alteration of the conveyance
capacity of the natural water course. Unwise occupation of the
floodplain can seriously increase the potential for flood damage.
Development can cause an increase in the base flow of water
reaching wetlands/marshes, lakes and floodplains, and the flora and
fauna may be affected. Lawn irrigation return flow, interception
of the ground water by storm and sanitary sewer systems, and leaky
water distribution systems may be responsible for increased flows.
Development may cause a decline in the recharge to the ground water
table through occupation of a recharge area, such as that in the
southwest portion of the region, through decreased infiltration
because of impervious cover, and through elimination of agricultural
irrigation in the area. Development tends to increase the peak rate,
191
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volume and frequency of flooding both within and outside the flood-
plain. The extent of increase tends to be larger for the more fre-
quent floods than for rarer ones. These changes can cause greater
erosion within steep floodplains and may affect the vegetation that
can be maintained.
Development is likely to produce a decline in quality in waters
reaching the hydrologic features. This can result from automobile
wastes, fertilizers, pesticides, sewage and sediment. Poor water
quality greatly speeds up the natural eutrophication process of
lakes and can affect the flora and fauna of lakes, wetlands/marshes
and floodplains.
Various hydrologic features, such as floodplains, lakes,
ground water, or marshes, can also affect development. Any flood-
plain development can be unwise, particularly along those stretches
of the upper portion of Bear Creek, Clear Creek and the upper
portion of the South Platte River, all of which experience periodic
flashflooding. The aesthetic quality of lakes may provide inter-
esting focal points around which developments are planned. However,
urban runoff is frequently the cause of eutrophication problems
in such lakes. A reliable ground water supply may be one consid-
eration in the feasibility of particular developments. Wetlands/
marshes within the study area are generally not viewed as assets,
and thus may affect development through creation of the need for
drainage projects to dry them up.
Biology
The conversion of rural lands to urban uses typically requires
flood control measures for local watercourses. Channel straighten-
ing, removal of riparian vegetation, paving of streambanks and
colonization by weeds severely reduce habitat diversity. The
soils erosion impacts, discussed earlier, affect aquatic habitats
by filling in the rough stream channel bottoms with silt which
eliminates the physical niches necessary to benthic organisms,
thus eliminating the organisms themselves. Continuing and future
aggregate mining, necessary to construction activities, is likely
to entail channel disturbances and modifications, streamside
vegetation removal, and discharges of wash water from gravel pro-
cessing operations. Construction across riparian zones severs the
continuity of this habitat, thereby disrupting wildlife movements
through it. Development around pond and marsh areas often dis-
turbs the local habitat quality. The opening of rural areas and
wildlands for residential and increased recreational uses creates
pressures on wildlife and their habitats.
192
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Development along the foothills and mesa areas may infringe
upon critical wintering areas typically used by deer and elk.
Some curtailment of deer and elk feeding range may occur in the
eastern boundary near Cherry Creek Reservoir and to the west in
Douglas County. Animal and bird migrations through the lower foot-
hills area may also be disturbed. As indicated on Map F, several
areas have been recognized as ecologically significant due to
unique geologic formations, soil types, plant and animal communities,
and other factors. Development and recreation pressures on these
areas may not only degrade the habitats or affect the surrounding
environments, but may also reduce cumulatively the overall environ-
mental quality of the region. Areas of particular concern, due to
urban expansion, as noted by comparisons of the Projected Land
Use Map (Map I) and the Biologically Sensitive Areas Map (Map F),
are: (1) the Nature Conservancy in northwest Denver, (2) the Ken
Caryl-Johns Manville Ranch, (3) the Marshall Mesa and (4) the
White Rocks area near Boulder.
Human activities greatly increase the wildfire potential, par-
ticularly on slopes of 30 percent or greater where the fire hazard
is critical. Construction and maintenance activities on steep
slopes and the resultant slash, felled trees and other inflammable
litter significantly increase this potential.
Energy
The 1975 population of the Denver region constituted about 57
percent of the population of the State of Colorado. By 1985 it
will constitute perhaps 60 percent, and by 2000 about 54 percent
of the state population. The Denver region's share of statewide
energy consumption is estimated to be on the order of 64 to 68 per-
cent at the present time. Natural gas shortfalls, amounting to
15 to 20 percent within five years, are expected to begin in the
Denver region during 1978-79. The demand for natural gas by the
Denver region may adversely affect the rural areas of Colorado, as
rural areas are dependent on liquid propane which is manufactured
from natural gas. There will be an increased reliance on and demand
for electric power. After 1980, if scheduled power plants are de-
layed significantly, some brown-outs or load reduction and shedding
will occur.
The increased demand for electrical power will probably be
met with coal-fired power plants, which will increase Colorado's
coal production. Between 1977 and 1985, the Public Service Company
of Colorado plans to build or participate in building coal-fueled
generators in Fort Morgan, Southeastern Colorado and Craig. The
Craig plant is scheduled to burn Colorado coal, while Wyoming coal
is to be used in the other generating facilities. Consequently,
beginning in the 1980's, conflicts may arise over available water
193
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supplies between municipal and agricultural water users in the
Denver region, due to increased demand for water for energy,
statewide. (Reference 970)
Regional demand for petroleum-based fuels will increase with
increased population. This increased demand will be limited to
some degree by increased vehicle fuel economy and higher fuel
prices. Although there will still be a net increase in consumption,
petroleum-based fuels will be smaller part of overall basic fuel use.
Aesthetics
Growth in the Denver region could lead to a degradiation of many
qualities which have created Denver's attractiveness and desirability.
Some of the qualities that could probably be adversely affected in-
clude: (1) open spaces, wetlands and other natural areas, (2) wild-
life, (3) scenic views through high-rise construction and air quality
related visibility obstructions, (4) air quality, (5) noise levels,
and (6) relaxed lifestyle.
Outdoor Recreation Sites
Regional growth will require development and recreation sites
beyond those acquired to date. The growing needs of the populace
will not be met as the land area per capita for parks will decrease
36 percent from 6 hectares (15.2 acres) per 1,000 persons in 1970
to 4 hectares (9.9 acres) per 1,000 persons in 2000. Park overuse
and facility vandalism will continue and intensify throughout the
region particularly in those areas having a high percentage of
children and young people. This will be especially true in new sub-
urban areas where there is a general predominance of young families.
As these suburban areas age, the populations should begin to mature
and the incidences of vandalism should somewhat decrease.
Land Waste Treatment Sites and Wastewater Reuse
Until a decision is made on the West Adams County sludge dis-
posal site, the Lowry Bombing Range sludge disposal activities will
continue, and existing problems could worsen due to high sludge
application rates. However, the anaerobic digesters now under con-
struction at MDSDD #1 will reduce the short-term possibility of a
worsening situation. If the West Adams County site is not approved
due to unforeseen environmental or legal problems, some new disposal
scheme for the Lowry site might be adopted which could continue
the present controversy. This controversy has resulted from a basic
conflict between the established disposal use and the adjacent and
growing residential uses.
194
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As was indicated in an earlier discussion, development of new
land application systems for wastewater treatment under the owner-
ship and operational control of Denver area sanitation districts is
considered difficult. Monetary costs of land acquisition and water
rights problems have made these systems appear unfavorable by com-
parison to conventional treatment. In some cases the wastewater
operating agencies, such as MDSDD #1, do not have ownership of the
waters they are treating. Therefore, implementation of a MDSDD //I
operated land application system presents innumerable institutional
difficulties.
Development of new lands for irrigation also runs afoul of
existing water rights. For a municipality owning tributary water,
a land application system that consumed additional South Platte
water would require the purchase of additional water by the muni-
cipality to "make up" the lost consumed water. Cities that own
West Slope non-tributary water do generally have the right to reuse
the water.
From EPA's perspective, water quality benefits are paramount,
especially where potential construction grant funding is involved.
From the point of view of the municipalities, the most financially
beneficial use of these waters and development of new domestic water
supplies may be the most important criteria. From the perspective
of downstream irrigation, water supplies should be neither diminished
in quality or quantity. Additionally, state water quality priorities
have favored protection of high-quality mountain streams (most of
which are on the Western Slope) over plains streams that vary widely
in seasonal flow and have been heavily contaminated by municipal
and agricultural use. Thus, defining water quality and supply
"benefits and impacts" is no easy task.
A number of important interrelated considerations must be kept
in mind in discussing reuse potential in the water-short Front Range
area:
• The region is still growing rapidly in population. Consid-
erations of new municipal water supplies for growth is
necessary.
• All of the water now in the South Platte basin is being used;
in fact, successive use in the rule downstream to the Neb-
raska border.
• New supplies of water can come from the West Slope only
through trans-basin diversions. Municipal water supply for
new growth can come either from this source or by condem-
nation or first use of agricultural rights.
195
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• Stream quality in the Front Range is degraded from municipal,
industrial point source, and non-point source runoff from
urban areas and agriculture. Reuse schemes must be viewed
in the context of both instream water quality and quantity.
Section III identified four possible reuse systems. A sub-
set of the recycling system would involve reuse of water by indus-
try or for urban irrigation (e.g. golf courses). -An evaluation of
the environmental merits of four potential reuse systems is given
in the list below. For comparison purposes, all four systems
assume a doubling of population and water use in the region. All
comparisons are from a base case of the present situation with lim-
ited reuse.
System No'. 1; No Reuse —
• Increase in the environmental effects of West Slope diversions
and/or condemnation of South Platte rights.
• AWT needed to meet standards or the total load of ammonia
and nutrients to the streams will increase.
* Flow downstream will be augmented.
* IDS concentrations downstream decreased; total load increased.
System No.' 2; Agricultural Successive Use —
* Increased effect of West Slope diversions and/or condemnation
of South Platte rights.
• Stream quality below outfalls improved (IDS and nutrients
decreased) during irrigation season.
• Ammonia nutrient benefits to agriculture.
* Smaller AWT plant may be required.
* Potential public health effects and soil damage.
System No. 3: Water Exchange - "First Use" by Municipalities —
* No additional effect on West Slope streams or from irrigation
water rights condemnation.
* Stream flow between water supply diversion and wastewater
treatment plants reduced.
* Nutrient benefits to agriculture.
196
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• Offstream storage may be required.
* Higher TDS and lowered flow downstream.
Potential public health effects and soil damage.
System No. 4; Increase by Recycling —
• No additional effect on West Slope streams or from irriga-
tion water rights condemnation.
• Higher TDS in city drinking water.
• Possible other contaminates in drinking water.
* AWT plant for reuse and discharge required.
Higher TDS and lowered flow downstream.
It is apparent in this analysis that no one system has an abso-
lute advantage over another. Total costs have not been evaluated
for such alternatives. There will be environmental benefits and
impacts with any system.
/•
System No. 1 has the advantage of providing more flow downstream
to the agricultural community. In such a system, however, the own-
ers of the imported water would have to receive compensation from
potential downstream users for added water. West Slope streams
would suffer the environmental impact of stream depletion.
System No. 2 has similar benefits and costs to System 1 except
that stream quality in the vicinity of the municipality and immed-
iate downstream would be somewhat improved.
System No. 3 has the advantage of no additional importation or
condemnation of water rights. Nutrients are diverted from the stream
in favor of farms. TDS values in the stream may increase, however,
and stream flows within the vicinity of the municipality may be de-
pleted.
System No. 4 involves no new or condemned water, but adds TDS
and possibly other contaminates to the municipal drinking water.
Alternatives to this are more expensive advanced wastewater treat-
ments. Downstream flows would also be depleted and TDS would be
increased.
Complications of real life situations can confuse this idealized
analysis. In many cases, the depletions, nutrient removals and TDS
incremental changes are small in comparison to the total water
quality problem. Such systems may only marginally change water qua-
lity.
197
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Exchanges can be complicated if some other higher use is made
of canal waters (e.g. Barr Lake — an irrigation storage reservoir
contemplated as a recreation area).
West Slope diversions are generally not made on an incremental
basis. Reuse schemes like 3 or 4 may be made in conjunction with
large, capital-intensive West Slope diversions (e.g. Foothills and
reuse projects of the Denver Water Board).
Protection of agricultural uses near the metropolitan area may
not necessarily be safeguarded by "first use contracts". The de-
cision to retain farmland in agricultural use near a metropolitan
area is basically economically constrained. If the price of farm-
land conversion to urban uses is high enough, or if costs of opera-
tion (e.g. taxes and distance from marketing areas) of farms gets
too high, farmland will still be converted. Given the same amount
of water available for agricultural uses, new farms or expanded
farms farther away from the metropolitan area may compensate for
farmland lost around the metropolitan area.
Advanced waste treatment to remove ammonia, chlorine and phos-
phates is not now practiced in the Denver Metropolitan Area to meet
the 1983 goals. A commitment to removal of these substances will
be an expensive proposition. The value of any of the reuse schemes
must be related to the most cost effective method of achieving these
results. Although the State of Colorado has classified most Front
Range streams as B-2 (warm water fishing, secondary contact recre-
ation) , funding has not heretofore been available for advanced
waste treatment. Should the State determine that future funds will
be used to remove ammonia, chlorine and possibly nutrients, reuse
schemes could prove to be a cost-effective method of attaining
water quality goals. However, adequacy of flows and stream habitat
do limit the fishery potential in many streams in the Denver region.
With certain reuse schemes which may improve water quality, stream
flows may be further depleted. Therefore, both water quality and
quantity must be considered in determining impacts of reuse on
proposed stream uses.
Traffic
Impacts related to dependence on the automobile, such as low
density or sprawl development, congestion and high noise levels
in the central business district (CBD), will continue to worsen as
the region grows. The situation of the commute-hour traffic over-
load on the region's highway system will continue and in some areas,
such as the CBD and suburbs near the CBD, it will become worse.
New highway construction to alleviate existing traffic problems
will compound the situation by providing additional highway capa-
city which can accommodate more growth and its traffic. Further
suburban growth would absorb the new capacity in a relatively
198
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short period of time. The Federal Urban Mass Transit Administration's
denial of funds for a regional transit system eliminates the possi-
bility of a fixed rail system for the present time. Any regional
transit system proposed by the Regional Transit District (RTD) to
compete with the automobile will have to rely on RTD's fleet of busses.
DIRECT ENVIRONMENTAL IMPACTS
Climate
Construction activities are generally restricted during Chinook
events, which are temporary in nature and occur primarily in the
winter when little heavy construction is done, thus minimizing ef-
fects upon construction. Wastewater treatment processes involving
spraying, such as trickling filters and irrigation of effluent may
produce local aerosols containing microorganisms and dissolved
solids. During Chinooks, these aerosols could be carried long dis-
tances. Blowing particulate matter from spray operations and sludge
disposal sites may impair vision and impede transportation. Some
damages to physical property suffered during highwind occurrences
would result in temporary, higher energy and cost requirements as
repairs are made.
All land application methods, including percolation ponds, will
affect the local microclimate. Volatilization of water molecules
may lead to a local fog formation during certain cold temperature
periods and produce a nuisance effect. Such an effect could take
place at the proposed sludge land application site for Metro Denver,
which is located close to the proposed Adams County general aviation
airport causing costly delays in terms of time and manpower (Refer-
ence 126) .
Low-temperature conditions can limit biological processes and
thus curtail certain treatment processes such as aerobic digestion,
trickling filter systems, and mechanical aeration.
The Littleton/Englewood, South Lakewood, South Adams, Aurora
and MDSDD #1 plants have the highest potentials for odor problems on
still days. The proposed satellite plant on Cherry Creek may have
odor problems if future residential development occurs nearby.
Hydrology
The construction and operation of wastewater treatment plants
can have important impacts related to the drainage network in the
study area. Plant siting can affect the water supplies in downstream
reaches by defining the point of return flow for the municipal water
systems. Since both irrigation and municipal water systems use the
drainage network for most of their supply, the point of return flow
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of domestic water can be critical. Plant construction and plant
operation and maintenance will affect water quality in the drain-
age networks as discussed previously in "Water Quality".
Siting of those projects to be undertaken within floodplains
requires special consideration. They must be designed so as not to
increase the potential for flood damage either upstream or down-
stream. Since facility damage may result in direct release of un-
treated or partially treated sewage, the facilities must also be
capable of withstanding the flood depths and stream flow velocities
to be expected. Several interceptors such as Sand Creek, as well as
the central plant expansion of MDSDD //I and the lower South Platte
and Cherry Creek satellite plants will be sited in floodplains.
Interceptors that will be aligned through wetlands/marshes,
such as the proposed Sand Creek interceptor, may cause adverse
effects. The trench excavation and the pumping to keep it dry dur-
ing construction will lower the ground water table and may temporarily
dry up the marsh. If gravel is used to backfill part of the trench,
it could act as a drain to lower the ground water table permanently.
On the other hand, any leakage of sewage from the interceptor might
adversely affect the quality of the water in the marsh.
Geology
No significant direct alteration of land forms is anticipated
through implementation of any of the alternatives. No significant
direct impacts of geologic hazards, or on unique geological for-
mations or structures are anticipated for any alternative.
Soils
Soil-related direct environmental impacts result almost exclu-
sively from construction activities. These impacts consist of run-
off erosion from construction sites and commensurate temporary sur-
face water quality degradation. Wind erosion of exposed soils
results in windborne dust and particulates. These effects are gen-
erally temporary. The local and no-action alternatives would cause
the greatest number of erosion impacts and the regional alternative
the least. No alternative would cause significant long term adverse
impacts.
Biology
Direct Impacts of Local Alternative —
The identified alternatives would not significantly reduce flora
or fauna in the Denver Metropolitan Area. In general, the treatment
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plant sites and the interceptor corridors do not support native
plant communities. Rather, each of the sites proposed for waste-
water treatment facilities is typified by introduced vegetation and
wildlife species tolerant of human presence. All of the facilities
are situated either in urban areas or areas traditionally supporting
agriculture and grazing activities. Three types of potential im-
pacts upon biotic communities have been identified. The first two
relate to construction activities while the last one concerns facil-
ities operations.
Disturbance or Loss of Vegetation and Wildlife Habitats — New
treatment plant facilities and interceptors would be constructed
for the following service areas: South Adams, Englewood/Littleton
Cherry Creek/Goldsmith Gulch, Lower South Platte, Clear Creek/Sand
Creek, Northglenn and Broomfield/Westminster. Site construction
would entail the removal of ground cover and reduction of habitat
for some small animals. Principal plant cover in adjacent areas
would remain relatively unaffected. No losses would be anticipated
for highly productive habitat, or endangered or threatened plant or
animal species. The main differentiation regarding impacts on vege-
tation and wildlife, which can be made between the various facilities
plans, is related to the size of the facilities and subsequently the
amount of flora and fauna that would be removed.
Disturbance of Aquatic Habitat During Construction — Treatment
plant construction adjacent to watercourses could cause short-term
disturbances to the aquatic environment. Facility sites with poten-
tial effects on aquatic systems are Big Dry Creek, Lower South Platte
and Clear Creek and Englewood/Littleton. Other facilities will
probably use existing outfalls or convey effluents to a regional
facility. Removal of riparian vegetation could increase erosion and
adversely affect water quality and aquatic habitat. Increased tur-
bidity and sedimentation will disrupt bottom habitat, kill inverte-
brates and degrade water quality. These effects on the aquatic en-
vironment would be a short-term adverse impact many hundreds of
metres downstream of the facility. Physical stream conditions would
be restored by the natural scouring and restoration effects of spring
flows or seasonal upstream releases.
Effects Upon Aquatic Environment During Facilities Operations —
All of the proposed facilities would improve local water quality
within the Denver area. The South Platte River would benefit from
higher quality effluent discharged by the Englewood/Littleton, South
Adams and MDSDD #1 facilities. Big Dry Creek would receive surplus
flows from the Broomfield/Westminster facility.
This improvement in water quality would enhance productivity of
the aquatic environment and, through the food chain, would also en-
hance productivity of the terrestrial environment. The resulting
greater carrying capacity of these ecosystems could likely increase
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the number of individuals supported in the area. The potential for
establishing species not presently supported in these reaches of
Sand Creek, Clear Creek, Big Dry Creek and the South Platte River
is likely to have both beneficial and detrimental ramifications.
Overall, the multiple discharges provided in the local alternative
offer the opportunity to increase habitat areas and promote a diver-
sity of plant and animal species in the aquatic environment.
Direct Impacts of Regional Alternative —
The regional alternative, in general, would have fewer direct
impacts than the local alternative due to the limited number of
facilities. Potential impacts can be divided into the terrestrial
environment of the facilities sites and the aquatic environment
affected by the treatment facilities.
Disturbance or Loss of Vegetation and Wildlife Habitats — Con-
stuction of new facilities will be limited to the Englewood/Little-
Ton, South Adams County and MDSDD #1 treatment plant sites and a
new plant for the Brighton area. Interceptor routes that will be
constructed through vegetated areas include portions of the lower
South Platte drainage course. Other interceptor routes will follow
established roadways, xmpacts of biotic communities would be simi-
lar to those discussed under the local alternative.
Effects Upon Aquatic Environment — The regional alternative
consolidates all wastewater flows, except Englewood/Littleton, Brigh-
ton and Westrainster/Bloomfield, to the Denver Northside and MDSDD #1
plants. With the abandonment of local treatment plants, stream
areas will benefit from the termination of local discharges high in
BOD, suspended solids, ammonia-nitrogen, chlorine and other pollu-
tants. On the other hand, diversion of effluent discharges would
reduce local stream flows by 0.09 to 0.44 cubic metres per second
(2 to 10 million gallons per day). This would have a noticeable
effect on smaller watercourses such as Sand Creek and Big Dry Creek,
where diminished flows reduce the amount of aquatic habitat. In
comparison with the local alternative, the greatest number of dis-
charges (including reuse) would have the greatest benefit to the
natural environment through enhancement of the water regime.
Direct Impacts of the No-Action Alternative —
The no-action alternative embodies the same facilities as the
local alternative. Impacts relating to the disturbance or loss of
vegetation and wildlife habitats and the disturbance of aquatic
habitats during construction are similar to those discussed in the
local alternative section. The main impacts of this alternative are
the effects caused by delays in project implementation.
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Effects Upon Aquatic Environment — One to three year delays in
project implementation will require the continued use of local treat-
ment plants and discharges to local streams, but eventually the bene-
ficial impacts will approach, but not equal those expected under the
local alternative. The perpetuation of water quality problems pre-
sently experienced in some stream segments will be a short-term im-
pact lasting an additional one to five years. Ammonia-nitrogen and
chlorine residual, which in excess concentrations are toxic to aquatic
life, are the parameters of significant concern to the South Platte
River from the South Adams and Englewood/Littleton facilities, and
to Sand Creek near the Aurora facility.
Energy
Estimates of the energy consumed in the construction of facilities
described for each alternative are not available. However, a limited
comparison between alternatives is possible. Three factors can be
considered. These are the total length of installed interceptors,
the number of plant expansions and/or upgradings in treatment levels,
and the number of new plants constructed under each of the three
alternatives during the next five years. Assuming one unit of energy
per mile of interceptor, one unit per million gallons per day of
plant expansion, and one-and-one half units per million gallons per
day of new plant capacity, a comparison of construction energy de-
mands indicates that the local and regional alternatives are essen-
tially the same. Because the no-action alternative includes delays in
construction beyond the five-year period considered in this comparison,
not all the reduction in energy demand would be realized.
Energy use during operation of the facilities will be dominated
by the wastewater treatment plants themselves. First order estimates
of the increase in natural gas and electrical power yearly demands
of the alternatives five years hence are:
Local Regional No-Action
Natural gas, million cubic feet 40 30 8
Electric power, million kilowatt- 11 9 3
hours
In this instance, the local alternative will result in the highest
increase in energy demand. The significant quantities of natural
gas that would be demanded for the local and regional alternatives
are of particular concern as shortfalls in natural gas supplies for
the Denver region are expected as early as the 1978-79 heating season.
As wastewater treatment plants should be considered as interruptable
consumers of natural gas, loss of process heat is a real possibility.
Plant effectiveness would be degraded with consequent deterioration
of effluent quality during stream low-flow periods. Stream or re-
ceiving water's water quality could therefore be significantly
affected.
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Transportation
Direct impacts are construction-related and thus of a temporary
nature. These impacts relate to disruptions of traffic flow near
construction sites, and are likely to be greatest for the local al-
ternative, somewhat less for the no-action alternative, and least for
the regional alternative. No significant adverse impacts are antici-
pated.
Historical Features
Although no individual wastewater treatment plant would cause
the removal or destruction of a designated historical landmark, some
of the sites are near designated landmarks or in historical areas.
The South Platte River Valley, downtown Denver and Cherry Creek
vicinity are areas of great historical interest; new interceptor
lines will pass through these areas and the other creek basins as
well under the regional alternative. Although historic sites having
potential for official recognition, as well as currently designated
ones, are not directly threatened by construction activities, they
could be damaged structurally by such construction techniques as
blasting and trenching. Hauling of construction material past his-
torically significant points during the construction phase of one to
two years duration could cause accumulative vibrational effects, but
only in a very localized corridor along construction routes. Vibra-
tional effects of hauling are of much smaller effect than actual
pipeline excavation. Depending on the depth to bedrock or impervious
layer and other factors, carving or blasting may be required along
limited segments of the interceptor routes. Facility planning in the
current planning stage has not determined the exact alignments. As
excavation impacts are generally localized within approximately 3
metres (ten feet) on each side of the trench, it would not be appro-
priate, and perhaps misleading, to project impacts over large areas
until such information becomes available. The effects of dust and
dirt raised by construction activities upon historic sites would also
be minimal and difficult to predict at this time.
Outdoor Recreation Sites
Very few current recreation sites will be directly affected by
construction of the proposed wastewater treatment facilities under
any alternative, as few new plants are planned. More new facilities
are incorporated in the local alternative than in the regional alter-
native, thus potential impacts of the local alternative are greater.
Water-based recreation plays a major role in Denver. Many recreation
sites are located adjacent to or surround streams, lakes and reser-
voirs. As wastewater treatment facilities are to be located at
points along these streams and several interceptor routes have been
planned to lie adjacent to stream beds, some conflicts in siting may
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arise. The Bureau of Outdoor Recreation (BOR) has identified some
possible areas of conflict along Sand Creek, Clear Creek and the
lower South Platte drainages, and has recommended that multiple use
of land be a planning goal. A recreation plan is being developed
for the Sand Creek-Tollgate Stream corridor as a segment of the Corps
of Engineers' Denver Metro Study. The proposed interceptor right of
way would be a good location for hiker-biker trails to connect with
those of the South Platte River Greenway. The proposed Clear Creek
treatment plant location could be a potential recreation site.
Either alternative could incorporate a trail system similar to that
of Sand Creek. For the lower South Platte, the BOR has identified
in the Denver Metro Study that a new wastewater treatment plant at
164th Avenue may conflict with a potential recreation site (Reference
126) .
Stream flow may be augmented through treated discharge at many
points in the local, new plants alternative, rather than at a few
plants in the regional and no-action alternatives. The BOR has iden-
tified four areas of recreational benefit and potential resulting from
new plant operation:
• Return of a steady water flow to Sand Creek, which could
increase recreation benefits for hiking, bicycling and
nature study. This flow would not occur under the re-
gional alternative.
* Return of water flow to the proposed Corps of Engineers
reservoir to help maintain a conservation pool.
* The use of additional open space area for certain kinds
of recreation around the plant site.
* Underground construction of certain components of the
plant and utilization of the surface area for park and
recreation purposes.
In addition, discharges of a relatively higher quality water
than the current stream flow will enhance fishery potential in areas
not radically modified by channel improvements (see Map F), provid-
ing that flows are high enough and water quality is sufficient to
sustain a fishery. Increased flows will also enhance other recrea-
tional activities such as boating and general stream aesthetics, thus
serving to enhance the quality of recreation experience obtainable
at downstream sites. The more specific impacts on water quality and
flow augmentation are addressed in the "Water Quality" section.
Two factors considered in the biological direct impact section
have effects upon outdoor recreation: (1) the disturbance or loss
of vegetation and wildlife habitats; and (2) the disturbance of the
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aquatic environment. In the local and no-action alternatives, four
and one new treatment plants respectively and six and four plant
expansions respectively will permanently remove ground cover and re-
duce small animal habitats, thereby reducing potential recreational
opportunities in these areas. Although water quality will be en-
hanced by the addition of high quality effluent, the construction
disturbances, such as erosion of banks and siltation of streams,
may extend many hundreds of metres downstream and last one to two
years, thus impairing downstream recreational experiences. Those
alternatives with the greatest number of discharges, including reuse,
would have the greatest benefit to the natural environment and
recreational experiences through enhancement of the water regime.
Land Waste Treatment
None of the proposed alternatives contemplate land percolation
or infiltration as a wastewater treatment method. However, signifi-
cant reuse is planned where effluent would be used for urban or agri-
cultural irrigation, either directly or through exchange agreements.
Another motive for reuse, particularly through exchange agreements,
is to secure additional water supplies for domestic or industrial
use. Irrigation reuse is also attractive, as discharges to streams
are reduced with usually beneficial effects on stream water quality,
and nutrients and organic material are beneficially recycled into the
ecosystem.
Crop irrigation with wastewater effluent of the quality expected
from proposed facilities is generally restricted in the United States,
although it is more common in Europe. Use for irrigation of crops
for direct human consumption is generally prohitibed. The reasons
are based on unknown risks of contamination by pathogens (bacteria
and virus), mutagens and carcinogens. Other concerns are buildup of
salts in soils reducing productivity, buildup of heavy metals and
chlorinated hydrocarbons in soils, and subsequent uptake by plants
and eventual contamination of ground waters. Thus reuse for agri-
cultural irrigation presents both risks and benefits.
Aesthetics
Direct impacts on the visual and aesthetic environment can be
divided into construction effects lasting only a short-term and
operation effects which entail both short- and long-term impacts.
Similar types of effects occur within the local, regional and no-
action alternatives. Differentiation between alternatives basically
relates to the amount of area disturbed by the individual facility
sites.
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Construction Effects —
Adverse effects on local aesthetics during construction are
generally related to nuisance factors. Pipeline excavation and
treatment plant site preparation entail earth-moving, grading,
and in some cases, dewatering. Depending upon seasonal and topo-
graphic conditions, the generation of suspended particulate matter
is unavoidable. Construction noise, engine emissions from heavy
equipment and vibrations are other nuisance effects. Traffic re-
routing, temporary stockpiling of materials along roads, and
increased truck traffic during construction periods constitute
temporary inconveniences which will require residents to make short-
term adjustments.
Operation Effects —
The local alternative with multiple treatment facilities would
tend to have greater odor, noise and visual impacts than the regional
alternative. The construction and operation of a treatment plant
would certainly be intrusive and would tend to alter the character
of the surrounding area. The structural facilities can be located
away from areas of high visibility and designed to be visually and
aesthetically compatible with the environs. However, plant opera-
tions will entail equipment noise, processing odors, incidental
lighting and traffic from maintenance vehicles to some degree.
Facility sites creating the greatest disturbance would be those
closest to residential or commercial developments. Thus, expansion
of the Aurora plant, the proposed Clear Creek plant, and the South
Lakewood plant may cause some conflicts.
Facility plans which incorporate some system of treatment or
disposal by land application would be more land-intensive than
structural treatment systems. Land application probably would not
be noticeable as a distinct and separate land use within an agricul-
tural community. However, potential odor problems during adverse
conditions may affect a larger area than that of a small physical
plant.
In an overall evaluation, the improvement of wastewater treat-
ment in the planning area strives toward obtaining and enriching
cultural goals such as recreation, ecological viability and aesthetic
enjoyment. These are presently fulfilled in the mountain parks and
streams west of Denver. For the plains streams, however, improvement
in water quality alone will not fulfill those goals. Hendricks and
Bluestein (Reference 982), in their study of the South Platte River
concluded that:
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"Their achievement is essentially precluded by the
modifications brought about by intense human uses
of the stream and associated lands and by the
natural characteristics of the plains streams.
Thus, improvement of water quality in the plains
South Platte to 1983 levels (as specified by
PL 92-500) will result in few benefits and at very
high costs. However, to permit deterioration of
the mountainous South Platte will result in
irrevocable societal losses. From all of this, it
would seem that the most cost effective investment
policy would be to protect the mountainous South
Platte from deterioration and to maintain the
plains South Platte to permit continuance of existing
human activities".
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V. Comments and
Responses
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SECTION V
PUBLIC COMMENTS
Written comments on the Draft EIS were received from federal,
state, regional and local agencies, and from special interest groups
and private citizens. The review of these comments disclosed that
most of them fell into two groups. One group consisted of technical
comments concerned with errors, corrections, or clarifications of
technical information. The other group of comments addressed sub-
stantive issues which had been raised in the Draft EIS or during
public review and discussion. EPA has decided that the most effective
way to deal with this latter group of comments is by a consolidated
response, incorporating a discussion of each issue and the actions,
if any, EPA will take. These issue discussions and EPA actions are
presented in Volume 1, Sections III and IV.
Of the remaining comments, a number were of a nature which
requires no response, while the rest addressed the scope of the EIS
and the detail to which various environmental aspects were addressed.
Some comments were received which took the position that the Draft
EIS was too broad in scope, and reached too far in including growth
related impacts as a consequence of EPA funding of wastewater treat-
ment facilities. EPA does not maintain that all or part of the
growth related impacts are due solely to EPA's funding of wastewater
facilities. EPA does maintain that its role in funding wastewater
facilities which accommodate future growth means it must share some of
the responsibility for the environmental consequences of that growth.
One of the more immediate concerns to EPA is that the obligation of
its available funds under the Clean Water Act is not in conflict with
EPA's responsibilities under the Clean Air Act. Other comments
received commended EPA for the breadth of the scope of the EIS, but
expressed a desire for more detail. These comments generally took
the position that the scope of the EIS was necessary and appropriate
and represented a valuable first step toward dealing with a federal
agency's role in regional environmental issues. The question of
detail is always difficult to deal with in an EIS of this scope. Much
additional information has been developed since the Draft EIS was sent
out for public review, and has been incorporated into this Final EIS
particularly as it relates to EPA's actions and policies adopted as a
consequence of this EIS.
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The EIS explores in varying degree the impacts of growth on the
demand for public services. The depth to which an impact on a public
service is explored is related to the degree of responsibility, au-
thority, and direct or indirect EPA involvement. For example, sewer
service and wastewater treatment is a public service explored in
detail, while schools are briefly addressed.
Both the U.S. Department of Housing and Urban Development and
the Governor of State of Colorado commented on this uneven treatment
of public service impacts.
The original impetus for this regional EIS was to provide a
mechanism for addressing region-wide secondary impacts which were
very difficult to address in individual project EIS's, and to
respond to citizen and other agency calls for an overview environ-
mental assessment which would assist in assessing proposed EPA,
HUD and BLM projects affecting the Denver region as well as other
subsequent federal actions. EPA.and HUD together explored and
promoted the concept of a joint EPA-HUD-BLM assessment effort, but
procedural, planning, and budget difficulties could not be surmounted.
Consequently, EPA initiated its regional EIS which would stress areas
of primary EPA concern, and at the same time coordinate with and
recognize the work BLM was engaged in on the Foothills EIS and HUD's
work on its "areawide" EIS. This was done with the expectation that
the BLM and HUD EIS's would explore certain categories of impacts in
greater detail.
The EPA has no extant options regarding this issue as current
federal policies mandate cooperation between agencies of the federal
government. The EPA has reviewed the "Environmental Statement -
Proposed Foothills Project" by BLM and the "Denver Metropolitan Region
Environmental Assessment" by the Denver Regional Council of Govern-
ments for HUD, and although not necessarily agreeing with all the
findings of those documents, finds they contain relevant environmental
information, and hereby incorporates them by reference into the "Den-
ver Regional EIS for Wastewater Facilities and the Clean Water Program.1
This additional information has been used and considered by EPA in for-
mulating its decisions and policies.
All written comments that were received are included in this
Section, and EPA's responses, where appropriate, are given imme-
diately following each comment letter. Public input received as a
result of the newspaper supplement and meeting brochures has been
consolidated and analyzed in the publication "Attitudes of Denver
Region Residents on Environmental Issues." See Reference 130, which
is available at EPA's regional office at 1860 Lincoln, Denver, Colo-
rado.
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UNITED STATES DEPARTMENT OF AGRICULTURE
FOREST SERVICE
11177 West 8th Avenue
P.O. Box 25127
Lakewood, Colorado 80225 July 11, 1977
8400
Mr. John A. Green
Regional Administrator, Region VIII
Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80202
Dear Mr. Green:
Following are our comments on the "Denver Regional Environmental
Impact Statement for Wastewater Facilities and the Clean Water Program."
1. The title of the ES should be changed to be more closely
related to the subject matter which is more an assessment
of environmental effects resulting from further growth of
the Denver metropolitan area than a study of wastewater
treatment alternatives. As an example, on page VI-2 (3)
a shortage of natural gas by 1978-1979 is listed as an
unavoidable adverse impact. Obviously, this is not related
to the environmental effects of the wastewater treatment
alternatives.
2. Minor changes which we believe would improve the statement
include:
(a) p. II-32-there is no cold-water fishery in Big Dry
Creek above Standley Reservoir;
(b) p. II-43-"rare and endangered" is obsolete terminology.
Should be "endangered and threatened;"
(c) p. II-44-there are no black-tailed deer - must be (T
either white-tailed or mule deer;
(d) p. II-44-otter records in Weld County date back to (£
1906. This record could hardly describe the existing
environment.
S. H. HANKS
Deputy Regional Forester, Resources
211
6200-11 (1/69)
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RESPONSES TO COMMENTS BY
U.S. DEPARTMENT OF AGRICULTURE, FOREST SERVICE
11 July 1977
1. Please see the introduction to Section V, Volume 2.
2. Table II-F of Section 2, Volume 2, has been amended to note
this comment (p. 43).
3. All references to "rare and endangered" species in the draft
EIS have been changed to "endangered and threatened" species in
the final EIS.
4. All previous references to "black-tailed deer" have been
changed to white-tailed and mule deer in Volume 2 (p.57).
5. Additional information regarding the presence of otters in
the region has been added in Section II, Volume 2 (p. 57).
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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE _^ ^
P. 0. Box 17107, Denver, Colorado 80217
July 8, 1977
Mr. John A. Green
Regional Administrator
U. S. Environmental Protection Agency
1860 Lincoln St.
Denver, Colorado 80203
Dear Mr. Green:
Thank you for sending us a draft copy of the Denver Regional Environmental
Impact Statement for Wastewater Facilities and the Clean Water Program.
We have the following comments to offer:
Page 11-64 - We believe a further distinction should be made between prime
lands as defined by the Soil Conservation Service versus the prime agri-
culture soils as identified by the Denver Regional Council of Governments
(DRCOG). The DRCOG used our criteria in identifying prime lands; however,
they went beyond our definition and included additional lands of regional
importance (map D). We do not object to this; however, we suggest that
the report acknowledge this difference or explain that a combination of
map D (prime agriculture soils) and map H (land use) will identify the prime
lands as defined by SCS, since only the irrigated soils in Colorado that fit
our criteria can be considered prime lands. The difference in acreage bet-
ween the two categories of prime lands is significant; consequently, the degree
of impacts related to urbanization would also be significant.
Page IV-32 - Causes of Agriculture Land Consversion
We would like to suggest a couple of additional reasons why farmers continue
farming.
Increased land values have enabled some farmers to borrow money against
increased equity in their land which allows them to continue operating.
In addition, farmers are not always motivated by economic reasons when deciding
what to do with their lands. They continue farming because they enjoy living
and working on the land, even though they may suffer financially.
Page V-21 - Water Erosion
We are developing an erosion control guide for urban areas which will be
helpful to planners and developers in controlling erosion for construction
related activities.
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-2-
Thank you for the opportunity to review and comment on this proposal. We
compliment you on your discussion of prime lands and related impacts. If
you have any questions concerning prime lands, please contact us.
Sincerely,
Robert G. Halstead
State Conservationist
cc: R. M. Davis, Administrator, SCS, Washington, D.C.
Office of the Coordinator of Environmental Quality Activities
Office of the Secretary, USDA, Washington, D.C.
Council on Environmental Quality (5 copies)
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RESPONSES TO COMMENTS BY
U.S. DEPARTMENT OF AGRICULTURE, SOIL CONSERVATION SERVICE
8 July 1977
1. Please see discussion on prime agricultural soils and lands
in Volume II, page 72.
2. This comment has been added to the test of "Causes of Agri-
culture Land Conversion," Section IV, Volume 2 (pp. 140 and
142).
3. No response required.
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United States Department of the Interior
OFFICE OF THE SECRETARY
MISSOURI BASIN REGION
IN REPLY REFER TO: BUILDING 67, DENVER FEDERAL CENTER
]JR 77/564 DENVER, COLORADO 80225
August 1, 1977
Mr. John A. Green
Regional Administrator
Environmental Protection Agency
Region VIII
1860 Lincoln Street, Suite 900
Denver, Colorado 80203
Dear Mr. Green:
Personnel of the Department of the Interior reviewed your Draft
Environmental Statement for the Denver Regional Wastewater Facilities
and Clean Water Program and have the following comments to offer.
General
1. The environmental statement should identify a recommended plan
and evaluate the associated environmental impacts with and without
this plan. Furthermore, the alternatives to the recommended plan
and the resulting impacts should also be identified.
2. The EPA has explained the factors that induced it to include so
much information concerning the impact on air quality of wastewater
treatment-aided growth in the Denver region. Nevertheless, the amount
of material on air quality standards, forecasts, and potential abate-
ment strategies seems disproportionately large. As a result, overall
document focus and intelligibility seem to have suffered.
3. The final EIS should indicate continuing consultation with the
State Historic Preservation Officer and his professional staff,
consistent with the letter and spirit of the National Historic
Preservation Act of 1966, the National Environmental Policy Act of
1969, and Executive Order 11593. Moreover, the final environmental
impact statement should further reflect procedures to be followed
should previously unknown archeological resources be encountered
during project development. In short, all actions taken to guide
project development should be in compliance with the Advisory Council
on Historic Preservation "Procedures for the Protection of Historic
and Cultural Properties" (36 CFR, Part 800).
216
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Mr. John A. Green, Denver, Colorado
We further suggest that in order to protect any archeological sites
identified that specific site location information not be included
in the final environmental statement. However, this document should
include a copy of all project related correspondence to facilitate
and expedite the review process.
4. The draft environmental statement thoroughly analyzes the water
quality needs of the Denver Metropolitan Area and the alternative of
regional versus local treatment of wastewater. However, the statement
does not "develop a preliminary design for the project" as was intended
under "Step I" of the water quality planning process described on
page 2 of the Summary. Without this preliminary design and its
concomitant site-specific description of proposed facilities, we
cannot determine the impact of the project on local outdoor recreation
resources. More detailed information on the location of any proposed
waste treatment facilities and an analysis of their environmental
impacts is needed, either by means of a more specific final statement
or a separate environmental statement for each facility.
5. The EPA should be aware that there are numerous recreation areas
within the study region which have received matching assistance monies
from the Land and Water Conservation Fund (L&WCF). Encroachments on
properties that have received L&WCF assistance would constitute a
conversion of recreation use under Section 6(f) of the Land and Water
Conservation Fund Act, as amended. Section 6(f) requires that any
change from recreational land use be approved by the Secretary of
the Interior and also requires the substitution of other properties
of at least equal fair market value and reasonably equivalent
usefulness and location for the recreation lands to be taken. There
is no provision under this section for acceptance of cash in payment
for recreation lands converted to other uses.
6. There are also several properties within the study area which have
been transferred from Federal ownership to local agencies for park
and recreation purposes. Conveyance has been accomplished under the
provisions of the Surplus Property Act of 1944 (58 Stat. 770), as
amended, and the Federal Property and Administrative Services Act of
1949 C63 Stat. 377), as amended. The provisions of the Instrument
of Transfer specify that the property shall not be sold, leased, or
otherwise disposed of except with the consent of the Secretary of
the Interior. Substitution of properties of at least equal fair
market value and reasonably equivalent usefulness and location for
the recreational lands to be taken would be required.
7. Any temporary or permanent disruption of recreation resources,
including those having received Federal assistance, and appropriate
mitigation, should be addressed in the final environmental statement.
In addition, we suggest that direct, positive recreational benefits
217
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Mr. John A. Green, Denver, Colorado
could be incorporated into the project. It would be possible, for
example, to qualify for L&WCF monies for acquisition and/or development
of lands adjacent to proposed construction sites which could serve
both as buffers and as recreational resources in their own right.
Another possibility would be to incorporate bikeways or trails on the
rights-of-way of sewer trunk line construction. These factors should
be discussed in the final document.
Specific Comments
1. In the Summary Sheets under Item 3, Environmental Impacts, most
of these items should be grouped under "growth induced environmental
impacts." These are Nos. 1, 2, 3, 5, 6, 8, 9, 10, 12, 13, 14, 15, 16,
17, 18, 19, 20, 21, 22, 23, 24. The remainder of impacts identified
should be attributed to the construction of the wastewater facilities
and the implementation of the clean water plan. The document describes
the multitude of impacts associated with the growth of the Denver
Metropolitan Area and does not identify the specific impacts which
would result by the implementation of the clean water plan or
construction of wastewater facilities.
2. On page 1-12 there is reference to other environmental impact
statements which are in process and about to be released. This is
misleading and gives the reader the impression that other EIS's must
be reviewed in order to get the total picture about the conditions
associated with this Federal action.
3. On page 11-39, it is stated that the Coal Creek was degraded in
19.72 by, among other things, "the extraction of coals." This should
be modified to indicate that the degradation arose (as indicated on
page A-31) from the former mining of coal. According to all records,
no coal has been mined in the Coal Creek drainage for many years.
4. Table headings are missing on Table IV-A. Irrigated land
descriptions shown on map H does not appear consistent with the
amount of irrigated land shown in tabulations II-Q and II-P. This
omission and inconsistency should be clarified in the final EIS.
5. One finding of the Corps of Engineers' Denver Metro Study
mentioned on page IV-93, is that the South Platte River has potential
for further development as an urban riverway. The construction of
additional waste treatment facilities in the South Platte River flood
plain may jeopardize this proposal and conflict with proposed park
areas in the vicinity of the river. We recommend that the final
document provide information concerning the approximate location of
proposed facilities and fully evaluate the relationship of these
facilities to the urban riverway concept.
218
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Mr. John A. Green, Denver, Colorado
6. It should also be noted that while park vandalism and misuse in
the Denver area (page A-58, Appendix, et al.) have been problems in
the past and will undoubtedly continue to be problems in the future,
it is our conclusion that they are neither most significant nor unique
to the area. The Corps' Metro Study, for instance, determined that
the lack of funds for operation and maintenance of existing park areas
was the most pressing recreational problem. The potential overuse of
these resources (page 19, Summary) due to increasing population
pressures will probably require as a solution acquisition of more
areas or limiting of use of the existing areas.
7. In addition, we suggest that the final document reference the
source of the many recreation statistics presented in the draft
statement since it is unclear what guidelines were used to compile them.
Park density figures, for example, are dependent on a combination of
many variables—political or social boundaries, population projections,
type of park acreage, standards used, etc. (we presume that park
density acres per capita, page 13 of the Summary, et al., was meant
to be acres per 1,000 population). Two ongoing recreation studies
of the Denver area, the Corps of Engineers' Metro Study and the
Bureau of Outdoor Recreation/National Park Service Urban Study, may
be helpful sources of additional recreation data. The Bureau of
Outdoor Recreation, Mid-Continent Region, P.O. Box 25387, Denver
Federal Center, Denver, Colorado 80225, would be pleased to furnish
copies of these studied when published or, upon request, offer any
other assistance and information.
8. The statement asserts that strata of the Denver Basin dip slightly
toward the east (page A-7). However, the Denver Basin is a structural
as well as a physiographic or topographic feature. The configuration
of some of the basin up through the Fox Hills-Laramie Formations and
at least the basal beds of the intertongued Arapahoe and Dawson
Formations dip toward the axis of the basin. Dips are generally very
steeply eastward at outcrops on the west side of the basin, but more •
gently northward in the southern portion of the basin and westward on
the east side (Finley, E. A., Dobbin, C. E., and Richardson, E. E.,
19.55, Preliminary structure contour map of the Colorado Plains: U.S.
Geological Survey Oil and Gas Investigations Map OM 176). As would
be expected from the configuration of the basin mentioned above, some
recharge to the deeper aquifers also occurs in the eastern and southern
portions of the basin (page 11-24, paragraph 2).
9. One reiterated statement of some concern is a projection of
future conflict in the Denver region between demands for water by the
electric power industry and agriculture. These include:
219
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Mr. John A. Green, Denver, Colorado
a. Pages 17-18 (of Draft Summary). "After 1980, if the scheduled
development of power plants are delayed significantly, some brown-outs
or load reduction will occur. The increased demand for electrical
power will probably be met with coal-fired power plants which will
necessarily increase Colorado's coal production. Consequently,
beginning in the 1980's conflicts may arise between municipal and
agricultural water users in the Denver region, and energy industries
over available water supplies."
b. Page 11-44. "Projected shortfalls in supplies of natural gas
will pose a constraint on growth after 1980. In the long term, increased
reliance on coal-based electrical generation will force increased
competition for available supplies of water which are necessary for
coal mining and processing and air pollution abatement."
c. Page IV-81. "The increased demand for electrical power will
probably be met with coal-fired power plants which will necessarily
increase Colorado's coal production. Consequently, beginning in the
1980*s, conflicts will arise between municipal and agricultural water
users in the Denver region, and energy industries over available water
supplies."
d. Page VI-2. "9. Increased dependence on coal for electrical
power generation will create new water allocation and quality problems."
Although not always specifically stated, all of the above statements
apparently refer to: (1) the Denver region as defined for the study,
and (2) the 1980*s. According to the best available information, no
new powerplants or powerplant expansions, coal-fired or fueled
otherwise, are planned for the Denver region for the next 10 years.
Given the long lead times involved in planning and constructing
coal-based powerplants, it is rather unlikely any new facilities
would be built until at least the 1990's. Moreover, it seems unlikely
that any power facility with even a slight air pollution potential,
such as a coal-fired powerplant, will be built in the Denver region
during the present century. We believe the above statements should
be modified to indicate there is only a slight possibility of conflict
over water supplies between coal-based electric power generating
facilities and agriculture and other users within the Denver region
within the time span of the study.
10. We also wish to call attention to the assertion in the above
statements that increases in Colorado coal production would "necessarily"(
result from an increase in coal-based powerplants serving the Denver
region. Between 1917 and 1985 the Public Service Company of Colorado
plans to build or participate in building coal-based generators in
Fort Morgan, Southeastern Colorado, and Craig. Although the Craig
plant is scheduled to burn Colorado coal, Wyoming coal is to be used
in the other generating facilities.
220
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Mr. John A. Green, Denver, Colorado
11. In addition to a strong possibility that as yet unidentified,
archeological sites are located in the project area, Appendix A, pages
59-67, and Appendix B, page 8, both establish the presence of many
historical sites in the Denver area. The final environmental impact
statement should establish which cultural resource sites are located
in the project development area, which of them are on the National
Register of Historic Places, and which cultural resource sites are
believed to be eligible for such listing. If any of these sites will
be affected, the final environmental impact statement should state
in what manner, and how any adverse effects noted will be mitigated.
Thank you for the opportunity to review and comment on your draft
environmental statement and project. We hope these comments will be
helpful in your preparation of the final statement.
Sincerely yours,
'J
OHN E. RAYBOU
Regional Environmental Officer
221
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RESPONSES TO COMMENTS BY
U.S. DEPARTMENT OF THE INTERIOR
1 August 1977
1. Please see discussion in Section III, Volume 2 and the Introduction
to Section V, Volume 2. EPA's proposed action are continued in Volume I.
2. Please see discussions in Volume 1, subsections III-l and IV-1,
and the Introduction to Section V, Volume 2.
3. Please see Volume I, subsection IV-9.
4. Please see discussions in Volume 1, subsections III—10 and IV-10.
5. The Summary has been revised, see Volume 1.
6. Please see discussions in Volume 1.
7. Section I of Volume 2 has been amended to prevent any misleading
impressions regarding a reader's need to review other EIS's
(p. 12).
8. The word "former" has been added, as recommended, to Section II,
Volume 2 (p. 52).
9. Column headings have been added to Table IV-A (p. 109).
10. The irrigated land shown on map H is that that has been mapped by
the U.S. Geological Survey. The sources for other data used in
the text to delineate agricultural land areas are mentioned, see
page 72, Volume 2.
11. No response required.
12. The recreational statistics cited in the EIS are from present and
future estimates of land uses made by DRC06.
13. Recognizing that Denver competes for western slope water, the text
of the final EIS (Volume 2) has been changed according to your
comments.
222
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FEDERAL ENERGY .• OMiNISTRATION
REGION VIII
1075 South Yukon
P.O. Box 26247, Belmar Branch
Lakewood, Colorado 80226
June 27, 1977
Mr. John A. Green
Regional Administrator
Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
Dear Jack:
We have reviewed the draft environmental impact statement on the
Denver Regional Wastewater Facilities and the Clean Water Program
and feel this regional draft is adequate as written. It details
the general environmental considerations of the greater Denver
Metro area quite well.
We assume the site specific wastewater treatment facilities in the
metropolitan area being funded under the 201 program will now only
need brief environmental analyses, eliminating the need for draft
and final EIS's as a result of this regional EIS. Is this reasoning
correct?
Thank you for the opportunity to comment on this draft EIS.
Sincerely,
Dudley E./Faver
Regiona/ Administrator
223
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RESPONSE TO COMMENT BY
FEDERAL ENERGY ADMINISTRATION
27 JUNE 1977
1. It is expected that this EIS will eliminate the need for
further, lengthy environmental review for the projects
being considered.
224
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DEPARTMENT OF HEALTH. EDUCATION. AND WELFARE
REGION VIII
FEDERAL OFFICE BUILDING
I9TH AND STOUT STREETS
DENVER. COLORADO 80294
July 14, 1977
OFFICE OF THE REGIONAL DIRECTOR
Mr. John A. Green
Regional Administrator
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
Dear John:
Thank you for the opportunity to review the draft environmental impact
statement for the Denver Regional Wastewater Facilities and Clean Water
Program.
It appears that the impacts expected to result from this proposed pro-
ject and reasonable alternatives thereto have been adequately addressed.
Sincerely yours,
in R. LaPedisi
cting Regional Director
cc:
Office of Environmental Affairs
HEW, Washington, D.C.
Council of Environmental Quality
Washington, D.C. (2 copies)
225
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RESPONSES TO COMMENTS BY
U.S. DEPARTMENT OF HEALTH, EDUCATION AND WELFARE, REGION VIII
14 JULY 1977
1. No response required.
226
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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
REGIONAL OFFICE
EXECUTIVE TOWER - 1405 CURTIS STREET
DENVER, COLORADO 80202
REGION VIM July 18, 1977 IN REPLY REFER TO:
8DE
Mr. John A. Green
Regional Administrator
Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
Dear Mr. Green:
This is in response to the Environmental Protection Agency (EPA) Draft Denver
Regional Environmental Impact Statement (EIS) for Waste Water Facilities and
the Clean Water Program dated June 1977.
We agree with the statement in your Draft Summary EIS that the provision of
waste water facilities to accommodate future growth must be considered a contri-
buting factor to the environmental consequences of that growth. We appreciate
the fact that EPA must decide what role, if any, it should play in supporting
future growth along with the related environmental effects. It is this under-
standing that forms the basis of our following comments:
1. The Draft EIS discusses in great detail the problem that agri-
cultural land is being converted to urban use. The statement
points out that the Council on Environmental Quality (CEQ) has
recognized this problem and has required special consideration
by Federal agencies whose actions affect the conversion of
"prime" or "unique" farmland to other uses. We feel that the
Draft EIS misrepresents the impact of converting "prime"
farmland to other uses in both Table IV-L and Map D, Prime
Agricultural Soils. The responsibility to define "prime"
and "unique" farmland has been given to the Department of
Agriculture, Soil Conservation Service (SCS). According to
the SCS definition of "prime" farmland, the land must be
capable of producing a viable crop seven (7) out of ten (10)
years. In the Denver area, such production can only be
obtained from irrigated lands. The areas delineated on
Map D are properly labeled as "Prime Agricultural Soi Is."
227
Insuring Offices
Casper, Wyoming • Denver, Colorado-Fargo, North Dakota • Helena, Montana • Salt Lake City, Utah-Sioux Falls, South Dakota
-------
Many of these areas do not meet the SCS definition of "prime"
farmland because they are not irrigated and lack sufficient
moisture to produce at the required rate. We suspect that
the data that appears in Table IV-L was obtained from Map D
and therefore, would misrepresent the impact on "prime"
farmland. We also feel that this data was used in the
narrative portion of the Draft EIS and may represent an
inaccurate conclusion. We feel that a map properly deline-
ating "prime" farmland should be included in your Final EIS.
Such a map with supporting data has been prepared for use in
HUD's forthcoming environmental assessment of this area and
is available for your use if requested. You will find that this
new information will indicate an uneven distribution of "prime"
farmlands within your Waste Water Facilities Planning Areas.
As you indicated in your Draft EIS, page IV-30, "Growth will
go where facilities are available to serve it,..." It would
seem appropriate for you to determine the amount of "prime"
farmland that would be converted to urban use within each
service area and then take this adverse impact into account
in your decision on each of your waste water facilities.
We feel that such a discussion should be included in the
Final EIS.
You have indicated in your Draft EIS that the forecasted growth
will cause an increased demand on community services and facilities;
however, it does not appear that equal consideration was given
to all services and facilities. For example, individual
assessments are included for transportation and recreation,
but not for such services and facilities as public safety
(fire and police), schools, solid waste, etc. It has been
our experience that schools are consistently impacted by
growth, and that over crowding occurs in certain parts of
the Denver area. We feel that the Final EIS should discuss
these impacts equally and that the impacts should be quanti-
fied by your Waste Water Facilities Planning Areas. This
would enable EPA to weigh these impacts in deciding on the
best course of action for each waste water facility.
228
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3. We question the discussion on Outdoor Recreation Sites in
several areas. On page IV-82, you indicate that land areas
for parks will decrease "from 15.2 acres per capita in 1970
to 9.9 acres per capita in 2000." We assume the unit of
measure was intended to be acres per 1,000 population instead
of per capita. The Draft EIS does not indicate the statis-
tical basis for this statement which is in conflict with
another statement on page V-25 which implies that munici-
palities have kept pace in developing parks as populations
have increased and that such a trend will continue. Also
on page V-25 you suggest that local governments require
that developers provide neighborhood recreation facilities
as a part of their development proposals. We assume you
mean that developers should pay for the development of
such facilities since under the current practice, developers
do donate land for recreational use. Your suggestion
would be an "ideal" solution; however, could not be imple-
mented, as would be the provision of classrooms, solid
waste disposal facilities, sewage treatment plants and
other service facilities. Your suggestion is very theo-
retical and proposes attractive but not realistic solutions.
A similar theoretical solution could be proposed for the
Denver air quality problem in that governmental controls
should dictate that only non-polluting,vehicles be permitted
in the Denver area. This also illustrates an "ideal" but
impossible solution to a problem. If there are no solutions
that can be implemented to correct this impact, then that
should be stated in the Final EIS and taken into account
in your decision-making process.
As you mentioned in your Draft EIS, HUD is preparing an environmental analysis
of the impacts of growth in the Denver Metropolitan Area. This analysis should
be complete by September of this year and should be published as an EIS this
winter. We would be happy to provide you with any portion of our assessment that
might aid you in your decision-making process as soon as it is available.
In addition to our comments on your Draft EIS, we are enclosing the comments of our
Headquarters office in the form of a memorandum from James F. Miller dated
July 8, 1977.
Thank you for the opportunity to provide these comments.
Sincerely,
Robert J. Matuschek
Assistant Regional Administrator
Community Planning and Development
Enclosure
229
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RESPONSES TO COMMENTS BY
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
18 July 1977
1. Please see discussion on prime agricultural soils and lands in
Volume II, starting on page 72 and in Volume I, subsection III-9
and IV-9.
2. Please see the Introduction to Section V, Volume 2.
3. The correction suggested to page IV-82 of the draft EIS has been
made in Volume 2, page 194. Regarding the issue of developing
new parks, we believe that a developer should be required, at a
minimum, to provide land for parks, where needed. In many areas
land, as well as more elaborate provisions for parks, recreation,
and open space are met by developers and therefore, it does not
appear to be an "ideal but impossible solution."
4. The assessment report as provided by DRCOG to HUD was reviewed and
utilized in finalizing this EIS.
230
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HUO-B6 (7.79) PREVIOUS EDITION MAY BE USED y - DEPARTMENT OF
HOUSING AND URBAN DEVELOPMENT
TO :Walter Kelm, Director, Environmental DATE: JUL 8 1977
Quality Division, Region VIII
IN REPLY REFER TO:
CSP
FROM :James F. Miller, Environmental Planning Division, CSP
SUBJECT: EPA Regional Environmental Impact Statement for Wastewater
Facilities and the Clean Air Program
This is in response to the memorandum to Richard H. Broun on this
subject. Our major comment is that the EIS really does not address
the issue of alternative urban growth patterns and their implica-
tion, in terms of various environmental factors, that could result
from alternative wastewater treatment and air pollution control
strategies.
Impact analysis is based on the present growth trend, continued
urban sprawl and the decline of the City of Denver. It considers
physical impacts under this assumption, with some exceptions
(biologically sensitive areas affected by development (Map F), but
is weak on the long term socio-economic impacts. There is little
discussion of the implications of this growth pattern for low and
moderate income housing and employment opportunities.
There is no attempt, in any holistic way, to identify areas not
suitable for development due to commination of air and water
quality and other environmental constraints. One mitigation
measure discussed was to reduce growth in the north and northeast
Denver region based purely on prime agricultural land considera-
tions. There was no attempt to base this recommendation on a
total picture of environmental constraints. The secondary socio-
economic impacts of this recommendation were also ignored; for an
example, there is no comprehensive trade-off analysis of alternate
frowth strategies and the potential physical and socio-economic
enefits and costs of each. Without this, the third objective of
the EIS cannot be met, i.e., stimulating public discussion about
desirable environmental goals for the Denver metropolitan region.
HUD is concerned about regional strategies for promoting low and
moderate income housing. There is also no direct consideration of
the relationship of EPA's construction grant program with other
Federal programs, part of this same objective.
231
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There is a significant amount of discussion of governmental and
fiscal mitigation measures over which EPA has limited control,
yet, there was no discussion of alternative regional growth
strategies which have even more significance. There is also a
weak discussion of the impacts of alternative transportation
control measures in terms of how they could be affected by
alternative growth patterns. Reduction of traffic volumes, which
the report states is necessary for control of particulates, CO and
ozone can be accomplished by directed growth patterns. There is
strangely no mention in the summary report of DMTA's decision not
to fund mass transit which bears directly on the issue.
Other impact interrelationships are omitted. For example, the
connection between improvement of recreational uses in various
riparian areas and the impact that alternative wastewater flow
decisions can have on these is not made in the summary report,
although the importance of recreational development as a potential
adverse impact is made. There is also little discussion of the
connection between energy conservation and alternative land use
patterns.
232
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RESPONSES TO COMMENTS BY
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
8 July 1977
1. The objective of the EIS is not to evaluate alternative growth
patterns but to assess the impacts of the growth plan being
utilized in developing the facilities plans and Clean Water Plan.
Mitigation measures for significant adverse impacts which are
identified and can be acted upon by EPA are addressed in Volume
I.
2. Please see the Introduction to Section V, Volume 2.
233
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THE COLORADO COLLEGE
COLORADO SPRINGS, COLORADO 80903
19 July 1977
Mr. John A. Green
Regional Administrator
U.S. Environmental Protection Agency
1860 Lincoln
Denver, CO
Dear Mr. Green:
The following are personal comments that I would like to pass on
with respect to the 208 Clean Water Plan for the Denver Metro
region. First, from an air quality point of view, I strongly
support your conclusion (page 1-6) that it is necessary to look
at projected population growth in terms of growth and in terms
of distribution, with the intent being (page V-4) to examine
what strategies and/or plan changes may be most effective in
reducing Denver's air pollution. This broad philosophy and
plan is however severly limited by the following very restrictive
assumption which seems to underlie most of the analysis in the
EIS (page V-4): "...we can be reasonably confident that there is
a linear relationship between additional population increase
and increase in vehicle miles travelled (VMT)." Further work
must be done to understand the implications of challenging this
assumption.
I would like to call attention to the following critical conclusions
from the EIS:
1. (page V-6) It is not fruitful to utilize restrictive local
land use controls which might promote development
elsewhere, in order to relieve regional air pollution.
2. (page V-7) A 30 % reduction in 1976 emissions resulted in
a 15% reduction in peak ozone.
3. (page V-10) Reductions in traffic volumes may present the
most effective method of reducing the particulate
air quality problem.
4. (page V-ll) After around 1995, any subsequent growth in traffic
will cause deterioration of Denver's air quality.
5. (page IV-49)Using the Denver Air Quality Model projections and
conclusion (2) above, it follows that ozone violations
would not be projected if there was a 23% reduction
from projected 1985 emission rates and a 14%
reduction from projected 2000 emission rates.
I believe that these conclusions imply the need to extend the Denver
208 EIS to evaluate how reductions comparable to those listed in (5)
above might be dependent on^wastewater planning.
234
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-2-
With respect to the details of the air quality modelling, I
would like to know the answers to the following questions:
1. The 1976 model results are based on emission factors from
AP-42/5. We know that these emissions are too low by as
much as a factor of two in some cases. How can the model
start from "wrong" data and get "right" answers in terms
of agreement with measured ozone levels? It suggests that
the model has been tuned in some ways to get agreement with
the observations. A list should be provided of all parameters
which were assumed and/or adjusted and the sensitivity of the
model results to these parameters should be detailed, (e.g.
how critical is the eddy diffusivity parameterization on
affecting levels and distributions?)
2. Why was meterology which produces ozone in the north-east
not considered and why was the meterology which was used
not included in the appendices? The model should have been
tuned up for one set of data and then verified on an independent
set of emissions and meterology inputs.
3. Why was the region chosen to be so small? A 30x30 mile area
is by no means large enough to characterize the regional
nature of the ozone problem resulting from Denver's automobile
emissions. Measurements as far as Ft. Morgan have found ozone
in excess of 80 ppb. A visual examination of the brown cloud
reveals that it extends well out of the modelling region to the
north on essentially every calm morning both in winter and summer.
4. Why was the estimated impact of air pollution on agriculture
limited to Adams, Arapahoe, and Boulder counties when it is
known that ozone produced by emissions from the Denver Metro
area is impacting the intensively farmed areas to the north
and east?
5. Why was no attempt made to model the air quality which might
result from serious efforts to reduce the future automobile
dependence of Denverites? Society usually makes choises based
on historic trends unless two conditions hold:(l) a serious
problem which warrents public action has been identified
and (2) believable alternatives to the historic trends are
available. This Environmental Impact Statement, as have
many other studies, details the problem and gives it considerable
weight. However, the EIS does very little to shed light on
alternatives which would challenge the assumption that more
people means more VMT. The conflicts with the existing
population projections, land use plans, and adopted transportation
are now clear. Before final decisions are made on future
wastewater facilities we must define, study, and evaluate
techniques to reduce our automobile dependence.
Thank You Very Much,
Chairman: Colorado Air Pollution Control
Commission
Val R. Veirs Assistant Professor of Physics
235
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RESPONSE TO COMMENTS BY
VAL R. VEIRS, CHAIRMAN OF THE COLORADO
AIR POLLUTION CONTROL COMMISSION
19 July 1977
1. Please see discussions in Volume 1, subsections III-l and IV-1.
2. This quote cannot be found and any context in which such an
approach was taken cannot be recalled.
3. This is an interesting observation. One should be careful to
note, however, that the 15 for 30% relationship was derived from
1976 emissions. Whether or not it would hold for other cases such
as year 2000 HC/NO emissions is not established.
4. Please see Volume I, subsection III-l and IV-1.
5, We are not aware of such deficiencies of AP-42/5. Such errors
should be minimal for the 1976 vehicle fleet which was studied
for validation exercise. 1985 and 2000 estimates did not use
AP-42/5 as discussed on p. 154. In all cases proper altitude
effect compensations were made.
The model was not tuned. A full disclosure of model development
is given in Appendix A, Reference 998. The sensitivity studies
described in this Reference covered wind speed and mixing depth which
were judged to be the most significant meteorological parameters.
The references given (Liu et al., 1976b and Lamb et al., 1975)
describe the diffusivity parameterization in some detail.
6. Simulations were carried out for all days for which data were
available. On 28 July 1976, peak concentrations were to the north
of Denver. The highest observed ozone on that day was at Northglenn
and Welby. Perhaps the meteorological data should have been in-
cluded in the report. All data for the validation study were
independent data since none was used for tuning since no tuning
was done.
7. The region was the largest region for which data were available.
The existence of impacts which we had no way of analyzing does
not invalidate the analysis of impacts for which data were avail-
able.
8. These are the areas within the study area with the majority of
regional agriculture and generally downwind of Denver.
9. A 30% reduction in future emissions was modeled and reported.
Reductions larger than this would appear difficult to bring
about without massive redevelopment of living and working fa-
cilities.
236
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RICHARD D. LAMM
Governor
EXECUTIVE CHAMBERS
DEBTVKR
August 1, 1977
John A. Green, Regional Administrator
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, CO 80203
Dear Mr. Green:
I am transmitting the comments from the various divisions and departments
of the State of Colorado on the Draft Denver Regional Environmental
Impact Statement for Wastewater Facilities and the Clean Water Program.
Additionally, I have taken the opportunity to synthesize what we believe to
be some of the more pressing issues raised by the State agencies.
The Environmental Protection Agency should be commended for addressing a
range of issues beyond the explicit jurisdiction of the agency. Your
initiative conforms to the spirit of the National Environmental Policy
Act and should serve as an example for other federal agencies to recognize
that the programs of any one entity are rarely independent of other
programs and policies at various levels of government.
Generally speaking, the Draft neglects a significant amount of the Denver
Metro region which in a few short years will have been developed and
expanded in a manner similar to today's near-suburban area. Specifically
excluded was northern Douglas County. We feel that the area analyzed
in the Draft should be expanded to include all surrounding county portions
in close proximity to Denver that are likely to be impacted.
We are very disappointed that other federal agencies did not participate
in the environmental impact statement. The statement itself makes a
strong case for policy coordination between governmental programs. But
without the involvement of other federal agencies in the EIS development,
it appears likely that the document will become just another academic
exercise that effects little real progress toward solving the problems
enumerated. We are particularly disappointed in view of the clear
direction for interagency coordinated statements set forth in the Guidelines
of the Council on Environmental Quality, Section 1500.7(b).
While it is well recognized that no one controlling measure—such as the
number, location, capacity, and type of wastewater plants—will alone
stop or answer the problems which unplanned population growth brings, the
inability of this Draft to present and analyze the strategies EPA and
other Federal funding agencies have to address these problems is glaring.
237
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Mr. John A. Green
August 1, 1977
Page 2
The three strategies outlined for attacking the wastewater problem—
local, regional, or status quo—are a step in the right direction, but
at some point in time these strategies must relate and be tied to other
federal programs, such as those listed in the attached letter of the
Division of Planning.
In setting aside a portion of the document for the anticipated socio-
economic impacts, the document lacks the information that the develop-
ment of greater wastewater treatment capacity will have on the parallel
development of human service needs, i.e. health care demands for the
poor, the elderly and the handicapped, social service demands, leisure
time demands, and, in general, human settlement patterns and related
problems common to all large metropolises.
Finally, the Draft fails to adequately consider recent trends concerning
the slowing of the "white flight" to suburbia. Some cursory indicators
point to a movement of white families back to the city center. Also,
with the relative progress of Urban Renewal, a revitalization in the
downtown area is slowly reoccurring. Further, the Draft has not mean-
ingfully addressed the possibilities of a substantial decline in per
capita clean water usage and the related reaction this phenomenon may
have on the eight metro treatment plants. It would also have been
helpful to have included samples of draft legislation where additional
state mitigation measures were conceived to be advantagious, e.g.
legislation on land development through use of tax disincentives.
I appreciate the opportunity to offer our comments on the proposed
Draft. Please feel free to contact my office for any needed assistance
in clarifying these or related points. Please find attached the more
specific agency comments relating to this environmental impact statement.
Sincerely,
Ri
238
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RESPONSE TO COMMENTS BY THE
GOVERNOR OF THE STATE OF COLORADO
1 August 1977
1. Please see discussions in Volume 1, subsections III-ll and
IV-11.
2. We agree that the intergovernmental coordination and policy
development are important aspects to adequately improving
Denver's environment. Please see proposed actions in Volume 1.
3. Please see discussions in Volume I.
4. Please see the Introduction to Section V, Volume 2.
5. It has been noted under "Population" in Section II, Volume 2,
that some cursory indicators point a slowing of the "white
flight" to suburbia, with white families moving back to the
city center (p. 69).
6. Please see discussions in Volume 1, subsections III-7 and IV-7.
239
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COLORADO DEPARTMENT OF HEALTH MR POLLOTION CONTROL
Division jjxxftexKtafl of
INTER-OFFICE COMMUNICATION
T0 . Robert D. Siek DATE . July 25, 1977
FROM- William M. Auberle SUBJECT: Wastewater Facilities and
Clean Water Program EIS
An analysis of air quality was performed for this EIS for the purpose of
predicting the effect of land use and population forecasts used in planning the
eight proposed Wastewater Treatment Facility Plans (201) and Clean Water Plan
(208) on future Denver air quality. This analysis was performed by Systems
Applications Incorporated (SAI) under contract to EPA and is listed in the EIS
bibliography as Ref. 998. Reference 998 is an extensive (460 page) document
entitled "Air Quality in the Denver Metropolitan Region 1974-2000." It opens
with a "Summary of Results" wherein 14 conclusions concerning the study inputs
and Denver's present and future air quality are set forth.
Our comments are directed to these conclusions, first as they relate to
the Wastewater Treatment Facility Plans and Clean Water Plan; and, second, but
more important, as they may be used by other agencies in decisions affecting
land use and transportation planning.
First, while we do not agree with a. major analysis conclusion that the
distribution or redistribution of population as could be affected by the size
and location of wastewater treatment facilities would have little effect on
reductions in air pollution concentrations across the region, we do believe
that EPA's funding of the capacity for wastewater treatment and intercept sewer
lines necessary to accommodate current growth projections and allocations for
the year 2000 will not in itself result in foreclosure on the options available
to provide clean air in the Denver Metropolitan Region.
We must, however, carefully examine the assumptions and qualifications
upon which this and the several conclusions set forth in the study are based.
Without such an examination the conclusions may be misleading and allow an
observer to believe that if there does exist an air pollution problem there
may be nothing we can do about it.
The analysis performed by SAI provides the following conclusion with res-
pect to population redistribution: If total regional emissions are unchanged,
reduction of HC and NO emissions by 25 percent in any given suburb or cluster^2
of suburbs would have negligible effect on local or regional ozone concentra-
tions. From this the inference is drawn in the study "that land use controls
that would reduce an area's population by as much as 25 percent without changing
the regional population would be ineffective in terms of reducing ozone concen-
trations." The conclusion should be expected since their simulated redistribu-
tion of population was, in effect, a redistribution of emissions which accounted
for no more than seven percent (7%) of the emissions on a regionwide basis with
total regional emissions remaining constant. Also, this simulation related to
ozone only and did not address carbon monoxide and particulates.
Continued
AD BUS-29 (10-29-100)
Signature
240
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Robert D. Siek
July 25, 1977
2
Redistribution of emissions is not equivalent to redistribution of popu-
lation. The major source of air pollution, either directly or indirectly, with
respect to all pollutants studied, is the automobile. Therefore, an appropriate
simulated redistribution of population would input an alternative transportation
plan to serve that population. This was not included as a part of SAI's simula-
tion. Population distribution or redistribution can not then be excluded as
an air pollution mitigating measure to the extent that it could result in a
reduction in emissions from the automobile by reducing or eliminating its use.
Carbon monoxide and N02 conclusions can be misleading with respect to the
impact of these pollutants and the selection of mitigating measures. The study
states that "Carbon monoxide concentrations averaged over two-mile square grid
cells do not now exceed standards. Standards are violated at smaller 'hot spots'
CO concentrations should be much lower in the future and the number of hot spot
violations should decrease." There is no indication in this conclusion of the
number of hot spots that might be found in a 2 mile x 2 mile grid; that there
may be a dozen or more and a high number of people exposed is not revealed.
Averaging CO over a four square mile area results in the masking of the highest
CO concentrations. Also, summertime mixing depths were inappropriately assumed
for wintertime conditions. Eddies and turbulence caused by high rise construc-
tion in the central business district was the rationale given for use of summer-
time mixing depths. This must be considered conjecture since there is no
evidence to support this for the Denver CBD. Mixing depths in the winter are
lower and increase CO.
Further, the Air Pollution Control Division's CO monitoring, coupled with
traffic count data, contradicts the study conclusions related to the regional
nature of CO.
During the SAI study base year, 1974, the Division recorded violations of
the 8-hour CO standard at all of its six monitoring stations ranging from 10%
of the days at the remote Welby station to a high of 35% of the days at the
CBD CAMP station. The average CO levels at all six stations were within 50% of
each other. The wide variation of traffic volumes at the stations would suggest
a much wider variation in CO levels if CO had only locally determined character-
istics. Levels measured at the NJH station were similar to those at CAMP. The
residential CARIH station had high levels of carbon monoxide which could not
be explained by traffic activity alone. This would indicate that CO not only
has a local character, but a regional character as well. SAI's analysis must
be considered perfunctory with respect to CO.
The study indicates that the Denver region is probably now in compliance
with NO standards;that future NO2 concentrations cannot be confidently pre-
dicted; that conflicting results were obtained with two types of analyses, and
that their (SAI's) best estimate is that NO., concentrations will not rise mark-
241
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Robert D. Side
July 25, 1977
3
edly over the next three decades if Federal vehicle emissions standards are
net. The study, however, also concludes that a relaxation of the 1985 Federal
Vehicle Emission factor from 0.4 grams of NO per mile to about 1 gram per
mile would eliminate violations of the Federal oxidant standard. We cannot
accept their best estimate that N02 will not markedly increase nor the implied
strategy that by permitting higher NOX levels from auto ozone will decrease.
Air quality maintenance analysis work performed by the Division indicates that
we will have a maintenance problem in the Denver Region with respect to NO2.
Implicit in the relaxation of NOX standards is the philosophy to improve air
quality in the metropolitan area at the expense of the rural agricultural areas.
This we cannot accept.
Finally, we agree that the air quality analysis of the Denver Region was
carried out using an improved version of SAI's Air Pollution Simulation Program
(APSP) and EPA's Climatological Dispersion Model (CDM), which models had been
previously utilized by this Division in its Denver Metro Air Quality Maintenance
Analysis (AQMA). The new version of APSP incorporates current atmospheric
chemistry concepts through use of SAI's Carbon-Bond chemistry model. The signi-
ficant input into this model was traffic data. A major assumption was compliance
with the Federal vehicle emissions standards by use of Federal automotive emis-
sion factors published in AP-42, Supplement 5, but adjusted for this altitude.
The use of such factors is by no means a fault of the analysis given the inputs
available at the time. However, it must be emphasized that AP-42, Supplement
5, has been recognized as underestimating automotive emissions for the Denver
Region since its publication. As a result, new vehicle emission factors have
been developed and recently published as AP-42, Supplement 8. The point to
be made is that an analysis which can have significant influence on land use
and transportation decisions would serve better by using current concepts in
the emission inputs.
William M. Auberle, Director
Air Pollution Control Division
JVS:pm
242
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RESPONSES TO COMMENTS BY
COLORADO DEPARTMENT OF HEALTH, DIVISION OF AIR POLLUTION CONTROL
25 July 1977
1. The discussion of air quality impacts has been revised
and Volume 2, Section IV should be reviewed. The discussions under
Subsections III-l and IV-1 of Volume 1 are also pertinent.
Many of the comments from the Colorado Department of Health
address the report by Systems Applications, Inc., reference 998,
which formed the basis for the air quality discussions in this
EIS. Following are responses relevant to comments pertaining
to reference 998.
2. The motivation in carrying out the land use sensitivity study was
to determine the effect on predicted pollution peaks and patterns
of changing forecasts of urban growth. This was accomplished by
changing the emissions data used by the computer model. The
criteria for these changes were:
That they be simple so as to most clearly display their
effect. Since model input is emissions, not population
6r traffic, we changed emissions without specifying how
emissions might be so changed. In application to some-
one's forecasts, emissions changes could represent popu-
lation changes, transportation system changes, changes in
other emission sources and/or interdependent changes in
some or all of these factors.
That the emission changes studied represent patterns
rather than overall emissions since the effect of an
overall emission changes of 30% was studied in a sepa-
rate exercise (p. 167, Reference 998).
That the emission changes studied by sufficiently large
as to represent maximum expected effects obtainable by
circumstances or by policy decisions. A 25% change in
pattern (i.e., at the expense of one Imited area rela-
tive to its neighbors) seemed rather severe—certainly
as much as a realizable policy might generate. The Air
Pollution Control Division correctly notes an important
aspect of urban distribution problems. It is difficult
to make pattern readjustments sufficiently large as to
make a marked impact on regionwide emissions or ozone.
A final comment is that the land use sensitivity study actually
addressed NOo and particulates as well as ozone (p. 142, Reference
998).
243
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The conclusion which cited that "Carbon monoxide concentrations
averaged over two-mile square grid cells do not now exceed standards "
was in error. Co standards were found to be violated on this basis.
The observation that the number of CO hot spots in a 2 mile x
2 mile grid is not revealed is certainly correct. It would not
have been revealed in a 1 mile x 1 mile analysis either, nor,
indeed, on any grid scale for which data were available. Our
comment on page 31, Reference 998, that ",.. violation of the
NAAQS can surely be found in any major urban area at particularly
critical spots such as industrial, shopping center, or stadium
parking lots or at busy intersections," together with our grid
model result of a 15 ppm 8-hour maximum (56% above NAAQS over 4
square miles) certainly do not mislead the reader as to the
magnitude of the problem.
The comment about the conjectural nature of the winter mixing
depth has certainly a measure of validity also. Inasmuch as any
value of mixing depth would be to some degree conjectural, it was
important to use the most objective estimate. Alternative esti-
mates that occurred to the investigators were:
a) Zero (±.e., a ground based inversion) based on morning tempera-
ture profiles at Stapleton airport
b) 300 meters, based on Holzworth^s mean winter morning estimate
c) 20 meters based on stability category, Turner's tables and
estimated characteristic length
d) 4 meters, based on estimates of traffic wake dimensions used
in several line source models (e.g. California Air Resources
Board)
e) 50 meters, based on building wake dimensions.
Alternatives a and b conjecture that the atmospheric boundary layer
at Stapleton is characteristic of downtown, or that the atmospheric
stability is predominantly thermal; mechanical effects are absent.
Alternative c conjectures that downtown is an open meadow, and that
mechanical turbulence is determined by atmospheric shear rather
than obstacles. Alternative d conjectures that the highest concen-
trations will occur on open, exposed roadways rather than on park-
ing lots or street canyons. Alternative e conjectures that build-
ing wakes will extend throughout the space between buildings in
the downtown high rise area. We chose the last conjecture as the
least misleading for revealing grid-average concentrations in the
region of greatest grid cell emissions.
The final comment on CO, that monitoring data contradicts
results, does not seem to be justified. No conflict is seen.
Some points to note are:
The base year emissions were those for 1976. Only
meteorology was obtained from 1974, as an example case.
No grid cell average monitoring was obtained (or is pos-
sible) .
244
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The average monitoring results should not be compared
with peak concentrations from a single modeled day.
Distribution of exceedances from a period of monitoring
should not be compared with the exceedances noted on a
single modeled day.
It should be emphasized that even on a 4 square mile average basis,
peak concentrations well beyond NAAQS were computed and it was
stated that actual, local peaks would 'be much higher and more
widely distributed.
4. It is the investigators' understanding that EPA-RTP recognizes the
shortcomings of present NO^ evaluation techniques including the
only technique (rollback) that they previously recommended. It is
our belief that there is a general consensus that photochemical ef-
fects cannot be ignored, but that no satisfactory treatment is now
available.
If these understandings are valid, then revealing the ambigui-
ties of analyses and the reasons for them seems the least mislead-
ing course of action. Similarly, with regard to the effect of NOX
emissions on ozone, it was felt it would be misleading to not
reveal this result, that objection to the result should rest on
defects in the model, and that sufficient warnings to the reader
of the disadvantages of high N0? concentrations should be included
so that others can develop informed strategies.
The comments recognize the attempts to meet the concern for
valid modeling in the statement "... we agree that the air quality
analysis of the Denver Region was carried out using an improved
version [of the model] ..." The concern for revealing strategy
implications may be found on pp. 36 and 177, of Reference 998.
5. The comments express concern that AP-42 Supplement 5 emissions
estimates were, "... by no ... fault of the analysis, ... the
inputs available at the time —" (thus apparently they were
"current concepts") whereas Supplement 8 emissions are now avail-
able and judged more accurate. Supplement 8 was not available
at the time the investigations were conducted, but investigators
became aware of work on Supplement 8 during the project. To
meet the concern for using the best possible inputs, EPA Region VIII
provided emission factors that did embody the major findings of
studies that led to Supplement 8 and are at least comparable to
Supplement 8 factors. These factors were used and reported as
"Set 2" factors on p. 160, Reference 998. At the time it was too
late to reflect these studies adequately in the report but "Set 2"
factor simulations were used and identified as base case predic-
tions in the EIS.
245
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COLORADO DEPARTMENT OF HEALTH
Radiation and Hazardous Materials Control
INTER-OFFICE COMMUNICATIONS-
TO : Ron Simsick
DATE : July 18, 1977
FROM : Orville F. Stoddard
SUBJECT: Denver Regional Environmental Impact Statement for Wastewater Facilities
and Clean Water Program.
Potential surface and ground water pollution and gas generation problems can
result from open dumps located in alluvial deposits or mined out gravel pits
in natural drainage areas. The impact of the disposal of solid waste in these
areas was not adequately considered.
The disposal of solid wastes in sanitary landfills to reclaim marginal land is
acceptable. This potential resource was not mentioned in the portion of the
report pertinent to agricultural or recreational lands.
The recovery of materials and energy from solid wastes and sludge was not men-
tLoned in the portion of the report pertinent to energy.
The generation, transportation, and ultimate processing and disposal of hazard-
ous wastes was not addressed in this document.
These topics must be given thorough consideration as they have a significance
impact.
OFS/pj
Enclosure (s)
246
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RESPONSES TO COMMENTS BY THE
COLORADO DEPARTMENT OF HEALTH
DIVISION OF RADIATION AND HAZARDOUS MATERIALS CONTROL
18 July 1977
1. Please see the Introduction to Section V, Volume 2.
2. Please see discussions under Volume 1, subsections III-8 and IV-8.
247
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COLORADO DEPARTMENT OF HEALTH
Division or Section of «"*• and Haz"
• Coatro1
TO : Ron Simsick
FROM: Albert J. Hazle
INTER-OFFICE COMMUNICATION
DATE : July 20, 1977
SUBJECT- DENVER METRO DRINKING WATER
AND WASTE WATER EIS - RADIOLOGICAL
HEALTH.
Two matters in radiation need to be addressed:
One is the radioactive material content of the discharge of waste water
treatment plants and the radioactive material content of waste treatment
sludge. The Colorado Health Department is currently investigating the
situation.
The second item is the impact of uranium mine effluent on the Denver Water
Board's water supply source is not addressed in the EIS.
The above items are my comments which are provided without a thorough
review of the document.
AJHrbjw
Signatur^
-------
RESPONSES TO COMMENTS BY THE
COLORADO DEPARTMENT OF HEALTH
DIVISION OF RADIATION AND HAZARDOUS MATERIALS CONTROL
20 JULY 1977
1. Additional information has been added to the Plutonium
Contamination and Radiation Hazard Section of Section II,
Volume 2 (p. 62).
249
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Department of Local Affairs
Colorado Division of Planning
Philip H. Schmuck, Director
Richard D. Lamm, Governor
July 11, 1977
Mr. Ron Slmsick
Office of Health Protection
Colorado Department of Health
4210 East llth Avenue
Denver, Colorado
Subject: Denver Regional EIS for Wastewater
Facilities and the Clean Water Program
Dear Ron:
Because of the breadth of issues raised and the complexity of alternative
solutions, we are unable to offer more than general comments on the above-
referenced EIS, within the time frame that has been provided for review.
However, we feel strongly that these issues should be pursued in more
depth, and that the EIS should be considered a starting point in moving
toward long term solutions for the environmental problems of the Denver
region. The developmental patterns and impacts in this area constitute
the State's foremost land use problems, and we should seize the opportunity
to address them and attempt a coordinated solution involving local, state,
and federal entities.
The Environmental Protection Agency should be commended for realistically
projecting the environmental consequences of our present development policies
and displaying a range of alternative strategies even though most of them
are beyond the control of EPA. Too often we have seen environmental state-
ments which were never able to extend beyond the myopia of one particular
agency's jurisdiction. That has not happened in this instance. In fact,
the most obvious weakness of this EIS is the failure to relate clearly the
specific actions contemplated (the eight wastewater treatment facilities
considered for funding) to the larger issues of long term development
trends. (For example, it is clear how the wastewater facilities Impact
immediate stream quality, but not how they drive or detract from future
sprawl.)
The specific treatment facilities considered are needed urgently and it
does not appear wise or feasible to delay them until solutions can be
found for the larger problems. Resolution of the long-term problems will
likely require several years of effort. As the EIS points out, the future
of water quality in the Denver area is not truly dependent upon the alternative
technologies available for point discharges. It is more dependent upon non-
point discharge. There is even less relation between the specific waste-
water facilities and the issues of air quality and energy conservation.
250
520 State Centennial Building, 1313 Sherman Street, Denver, Colorado 80203 (303) 892-2351
-------
Mr. Ron Simsick
July 11, 1977
Page 2
Therefore, it would seem reasonable to move first toward a decision con-
cerning the sewage plants, separating that urgent step from resolution
of the long-range problems.
From the EIS, several policies emerge which would appear to favorably
mitigate future adverse environmental impacts in the metropolitan area.
Those policies are:
1. Reduction of dependence upon the individual automobile.
2. Consolidation of local, state, and federal jurisdictional
divisions in the area.
3. Encouragement of less-consumptive alternatives to the prevalent
single-family subdivision.
4. Promotion of water conservation and re-use.
5. Elimination of "leap-frog" development patterns.
Further discussion between the affected entities could undoubtedly add other C]
policies to this list, but these stand out most clearly upon initial review. The
EIS does not refine any of these potential policies to the point where imple-
mentation strategies could be discussed specifically. EPA has discussed only
its own limited implementation tools while freely admitting their impotence
to solve the overriding problems. In fact:, this limitation is a serious
deficiency in the EIS.
Guidelines issued by the Council on Environmental Quality ,#1500.7(b) state:
"Where more than one agency...is involved in a group of actions directly
related to each other because of their functional interdependence and
geographical proximity, consideration should be given to preparing one
statement for all the Federal actions involved. Agencies in such cases
should consider the possibility of joint preparation of a statement by
all agencies concerned, or designation of a single lead agency to assume
supervisory responsibility for preparation of the statement... In either
case, the statement should contain an environmental assessment of the full
range of Federal actions involved, should reflect the views of all parti-
cipating agencies, and should be prepared before major or irreversible
actions have been taken by any of the participating agencies." Many other
federal programs impact the issues raised in this EIS. The list would
include:
FHA/VA home financing
HUD community development grants
Reclamation/BLM/Forest Service water policies
FHwA highway plans
FAA airport improvement grants
UMTA mass transit programs
BOR recreation grants
Small Business Administration programs
251
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Mr. Ron Simsick
July 11, 1977
Page 3
I am forced to concur with EPA's conclusion that they cannot affect
metropolitan growth problems merely through manipulation of wastewater
treatment facilities. However, I am not at all certain that a coordinated
program supported and enforced by policies of all of the above-listed
agencies would not have a significant effect. And if that program were
further supported by the State and key local entities, I am optimistic
that meaningful environmental gains could result. Therefore, if we
wish to seriously address these problems, I feel it is imperative that we
make every effort to force the kind of joint EIS that is envisioned by
the CEQ Guidelines. To do so, it appears inevitable that we must somehow
divorce this EIS from the eight specific wastewater facilities that
cannot await the time that such a massive, coordinated effort would require.
I hope that these general comments prove helpful to you in assembling a
State position on this matter. I would be happy to work with you further.
Very truly yours,
Charles G.'Jordan
Senior Planner
CGJ/btm
Reviewed:
Philip H. Schmuck
Director
252
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RESPONSES TO COMMENTS BY
DEPARTMENT OF LOCAL AFFAIRS
DIVISION OF PLANNING
11 JULY 1977
1. Please see discussions in Volume 1, subsections III-l and IV-1.
2. EPA is in complete agreement with your statement. With the pro-
posed actions EPA plans to take, which are described in Volume 1
of this EIS, it is hoped that the environmental consequences of
the projects and 208 Plan will be largely positive, including
secondary growth impacts. Although EPA actions are being taken
without the level of governmental coordination suggested, our actions
may foster similar action by other Federal, State and local
agencies.
253
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STATE OF COLORADO
Richard 0. Lamm, Governor
DEPARTMENT OF NATURAL RESOURCES
DIVISION OF WILDUFE
Jack R. erlab, Director
6O6O Broadway
Denver, Colorado 8O216 (825-1192)
July 5, 1977
Mr. Robert Siek
Associate Director for
Environmental Health
Colorado Department of Health
4210 East llth Avenue
Denver, CO 80220
Dear Mr. Siek:.
It is vitally important to the wildlife of Colorado that waste treatment
facilities be designed to prevent any further degradation of Colorado's
lakes and streams.
All possible measures should be implemented to upgrade Colorado's
water quality at the earliest possible time in order to preserve and
improve the existing human and wildlife environments.
Growth can occur without further degradation of Colorado's waterways
and Denver should take the leadership role in accomplishing this goal.
Growth control must be actively and accurately studied to prevent over-
committment of Colorado's finite water resources.
Thank you for the opportunity to comment.
Sincerely yours,
Jack R. Grieb
Director
P. T. Barrows, Chief
Environmental Resources
PTB:cs
cc: Clearinghouse
R. Evans
DEPARTMENT OF NATURAL RESOURCES, Harris Sherman, Executive Director • WILDLIFE COMMISSION, Thomas Farley, Chairman
Sam Caudill, Vice Chairman • Roger Clark, Secretary • Jean K. Tool, Member • Vernon C. Williams, Member
Jay K. Childress, Member • Eric Kelly, Jr., Member • Wilbur Redden, Member
254
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RESPONSES TO COMMENTS BY
THE COLORADO DIVISION OF WILDLIFE
5 JULY 1977
1. Please see discussions in Volume 1, subsections III-3 and IV-3.
2. Please see discussions in Volume 1, subsections III-2 and IV-2.
3. Please see discussions in Volume 1, subsections 111-5,6,7 and
IV-5,6,7.
255
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RICHARD D. LAMM
Governor
C.J. KUIPER
State Engineer
DIVISION OF WATER RESOURCES
Department of Natural Resources
1313 Sherman Street - Room 818
Denver, Colorado 80203
Administration (303) 892-3581
Ground Water (303) 892-3587
July 20, 1977
MEMORANDUM
TO: ROBERT SIEK, ASSOCIATE DIRECTOR FOR ENVIRONMENTAL HEALTH
FROM: DR. JERIS A. DANIELSON, DEPUTY STATE ENGINEER
SUBJECT: DRAFT ENVIRONMENTAL IMPACT STATEMENT - DENVER REGIONAL
WASTEWATER FACILITIES AND CLEAN WATER PROGRAM
This is to acknowledge receipt of the above referenced Draft Environmental
Impact Statement for the Denver region. We have reviewed this report, and
basically, have only one comment concerning the impact of the regional
wastewater program upon the water resources of the South Platte River and
its tributaries. This comment is in regard to the emphasis being placed
upon the reuse and/or exchange of effluent with agricultural ditch companies
involving waters tributary to the South Platte River basin. We urge the
Environmental Protection Agency to require Water Court approval of the plan
prior to providing funds to the local agencies proposing the reuse plan.
Without the opportunity for other water users to have the ability to protect
their water rights through this established process, these water users could
be detrimentally affected. Furthermore, a subsequent lawsuit by injured
parties could prevent the reuse program from operating and result in a con-
siderable loss of funds expended on a particular plan.
JAD/HDS:mvf
cc: Colorado Clearinghouse
. /Wu^Wtf•^->
eris A. Daniels on
256
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RESPONSE TO COMMENT BY
THE COLORADO DIVISION OF WATER RESOURCES
20 JULY 1977
1. Please see discussions in Volume 1, subsections III-6 and IV-6.
257
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OFFICE OF THE STATE ARCHAEOLOGIST
1300 Broadway
Denver, CO 80203
303-892-3391,2,3
Mr. Philip H. Schmuck
Department of Local Affairs
Colorado Division of Planning
520 State Centennial Building
1313 Sherman Street
Denver, CO 80203
RE: DEIS Denver Regional Wastewater (EPA}
resources
Dear Mr. Schmuck:
July 21, 1977
RECEIVED
JUL 2 6 1977
archaeological
The Office of the State Archaeologist of Colorado has re-
ceived and reviewed the Environmental Protection Agency's Denver
Regional Environmental Impact Statement for Wastewater Facilities
and the Clean Water Program.
While we agree that a regional approach is efficient (cf. p.
1-5, 1-8) and we applaud EPA's commitment to adhere to "The State
and Federal procedures for the preservation of historic and arch-
aeologic [resources]..." (p. V-29), we must conclude that
archaeological resources are not adequately addressed in this
statement.
The area's CD rich prehistory is not discussed (cf. p. 11-45),
and (2) the possible unavoidable adverse impacts upon archaeological
resources of both the prehistoric and historic periods are not
mentioned (cf. p. VI-1-3, B-8-9). EDA states that "Site reports
have been obtained from the Colorado State Archaeologist and are in
the process of being mapped for inclusion in the final EIS" (p. IV-
92). We have two comments regarding this statement:
First, when the "site reports" were released from the Colorado
Archaeological Survey Site Inventory (the state-wide archaeological
data repository we maintain), it was with precise instructions to
use the data for planning purposes only and not to include specific
site locations in any public document, etc. As part of the State
Historic Preservation Officer's inventory of the State's cultural
resources (those eligible and potentially eligible to the National
Register of Historic Places), such data is expressedly waived from
the Freedom of Information Act (PL89-665 Title 1 Section 101(a)4).
In theinterest of the preservation of these fragile, non—renewable
resources, we forbid the inclusion of such a map in the final EIS.
258
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Mr. Philip H. Schmuck
Page 2
July 21, 1977
Second, the mere listing of the few recorded archaeological
resources in the region does not constitute compliance with the
various federal mandates involved—NEPA and the CEQ Guidelines,
the National Historic Preservation Act of 1966, Executive Order
11593, and 36 CFR 800.
Additionally, the statement does not reveal how EPA will
identify previously unrecorded archaeological resources, what pro-
visions will be made for the evaluation of archaeological sites
in terms of the National Register of Historic Places eligibility
criteria, or how plans for the avoidance or mitigation of adverse
impacts upon eligible archaeological resources will be accomplished
Considering (1) the regional scope of this EIS, and (2) the
disturbed ground surface in most of the region, we recommend the
following approach; the formulation of general historic
and prehistoric overviews, the delineation (based upon rigorous
research) of areas expected to contain important archaeological
resources, and on-site monitoring .by a competent archaeologist of
all ground disturbance within those "sensitive" areas. This ap-
proach will most efficiently accomplish the identification and
evaluation of the covert (i.e. subsurface) archaeological resources
most likely to be encountered.
We have had some experience with EPA procedures in the Platte-II
Sewer Project and while we recognize some of the planning problems of
the agency, we believe EPA should more rigorously study their
Cultural Resources Management obligations. If we can be of continued
assistance, please call upon Staff Archaeologist David R. Stuart
at (303) 892-3391. (The State Historical Society's Department of
Historic Preservation will independently comment upon architectural/
historical resources.)
For the_St;aJ:e_ Historic
Leer
Bruce
State Archaeolf
u, Ph.D.
st Colorado
BER(DRS) :ng
cc: Hart, SHPO
Wall, Advisory Council on Historic Preservation
Klein, Council on Environmental Quality
Rudy, NFS Interagency Archaeological Services
259
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RESPONSE TO COMMENTS BY
THE OFFICE OF THE STATE ARCHAEOLOGIST
21 JULY 1977
Please see the Introduction to Section V, Volume 2, and dis-
cussions in Volume 1, subsections III-9 and IV-9. EPA will
not publish the archaeological sensitivity map and its support-
ing information. These materials will be maintained by EPA
for use in the review of wastewater facility plans and other
similar projects.
260
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RICHARD O. LAMM
Governor
EXECUTIVE CHAMBERS
DENVER
MEMORANDUM
July 8, 1977
TO: Ron Simsick, Colorado Health Department
FROM: Gary Broetzman, State 208 Coordinator
SUBJECT: Response to EPA Draft Denver Regional EIS
The draft EIS seems to evaluate the air and water quality aspects
of the ongoing growth and development patterns of the Denver Metropolitan
region. As such, it does provide a valuable discussion document on the com-
plexity of the issues involved,both technically and institutionally.
The document seems to fall short in fully identifying possible
actions that EPA could take within its air and water program authorities in
trying to curtail some of the more obvious impacts. For example, the document
discusses issues associated with urban sprawl, point source system configura-
tion, nonpoint sources, water conservation, fragmented institutional arrange-
ments, and lack of water quality and land use linkages in decision-making.
Virtually no possible EPA actions are identified, however, for mitigating
these problems with respect to the eight wastewater projects involved.
Let me offer a few primary issues:
1. Various options for system configuration were discussed
ranging from a more centralized system with a large treat-
ment facility downstream from the MDSDD plant to a more
decentralized system. It seems that some resolution of
these options is needed in order to decide whether to pro-
ceed with several or all of these eight projects. This did
not seem to be done.
2. Orban sprawl continues in part because the fragmented num-
ber and nature of governmental entities involved in waste-
water management. The region suffers from this in two
respects. First of all, the numerous entities involved
make effective program integration and coordination extreme-
ly difficult. Secondly, the proliferation of special pur-
pose sanitation districts limits the ability to bring to-
gether decision-making of growth and development with air
and water quality control. The DRCOG 208 program is moving
towards consolidation of the number of these agencies, but
261
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Ron Simsick -2- July 8, 1977
from our perspective is placing far too much importance on
the special purpose districts as the management agencies.
Although EPA may have no choice but to work with the exist-
ing management structure with regard to the eight projects
involved, it should go on record as favoring the use of
local general purpose governments as future management
agencies.
3. During the last week in June, EPA recommended to Congress a
need to tie water conservation requirements with the award
of construction grants for municipal wastewater facilities.
Although that could be awkward to implement, there seems to
be no question that a much greater emphasis is needed towards
water conservation within the Denver region and the State.
Such an emphasis would have financial benefits in terms of
reducing investments in both water supply and wastewater
facilities as well as benefits in terms of reducing our
demands upon a limited water resource. EPA could very well
take the posture of setting forth a lead time during which
a regional water conservation program is implemented prior
to proposing any constraints on construction grants for the
region. Concurrently, EPA could evaluate in more detail the
present and future per capita flow rates incorporated into
the designs of the eight projects.
4. The draft-did not highlight a need for broader integration
of water quality and total water management. The DRCOG 208
plan includes considerable decentralization of wastewater
facilities. Such a configuration will add opportunities
for reuse and successive use of treated wastewater to satisfy
a variety of municipal, industrial, and agricultural water
supply needs. The effects of such total water management em-
phasis should be assessed in terms of reducing transmountain
diversions and/or conversion of agricultural waters for ur-
ban needs as well as the effects of reductions in downstream
flows.
5. The emphasis given to nonpoint sources in the draft is diffi-
cult to comment upon. Although the DRCOG plan report did
provide gross estimates of nonpoint pollutant loadings into
the receiving waters, the report did not assess specific im-
pacts on beneficial uses. Without the latter, the pertinent
impacts of nonpoint sources are difficult to ascertain..
Ron, these are the major comments that I can offer. I would suggest
that you use them as appropriate in developing a unified State response.
262
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RESPONSES TO COMMENTS BY
THE STATE 208 COORDINATOR
8 JULY 1977
1. Please see discussions in Volume 1, subsections III-3 and IV-3.
2. Please see discussions in Volume 1, subsections III-4 and IV-4.
3. Please see discussions in Volume 1, subsections III-7 and IV-7.
4. Please see discussions in Volume 1, subsections III-3&6 and IV-3&6.
5. Please see discussions in Volume 1, subsections III-5 and IV-5.
263
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STATE DEPARTMENT OF HIGH
JACK K1NSTLINGER
DIVISION OF HIGHWAYS
E. N. HAASE
CHIEF ENGINEER
EXECUTIVE DIRE
4201 EAST ARKANSAS AVENUE • DENVER. COLORADO 8O222 • <3O3) 757-9O11
July 21, 1977
Dr. Anthony Robbins
Executive Director
Colorado Department of Health
4210 East llth Avenue
Denver, Colorado 80220
Dear Dr. Robbins:
The Colorado Department of Highways has completed its review of EPA's
Draft Denver Regional Environmental Impact Statement for Wastewater Facilities
and the Clean Water Program issued in June, 1977. We applaud EPA's recognition
that the eight wastewater treatment facilities and the provisions of the DRCOG
Clean Water Plan are irrevocably related warranting the development of the
subject EIS.
The Department of Highways takes strong exception with the conclusions
reached in the "Implementation of Air Quality Mitigation Measures" section
(p. v-11). We believe that EPA has critically errored in concluding that
"... population growth is not in itself the problem, but rather, the air
quality problem is more related to transportation." The total population and
its distribution in the Denver region largely determines the transportation
system and therefore the resultant air pollution emissions. For example, if
population growth in the Denver region continues to occur in low density sprawl
a high dependence on the automobile is unavoidable. With sprawling land use
patterns a financially feasible transit system cannot achieve significant
patronage. (Note the UMTA denial of funds for RTD's first usable segment.)
Therefore, the appropriate question to be addressed in the EIS is: How
can EPA's decisions relative to funding wastewater treatment facilities and
interceptor sewer lines be used to manage population growth and promote develop-
ment patterns that can be feasibly served by public transportation, bicycling,
and walking thereby reducing automobile use, VMT, air pollution emissions, and
energy consumption? The EIS must be considered to be substantially deficient
unless this question is addressed in depth.
The Department must also take issue with the inference that since the
federal government has very limited authority in local land use EPA can do
little to improve air quality (p. v-11). Although the federal government has
limited authority over local land use, federal assistance and regulatory programs
have major impacts on local level use. The EIS incorrectly states that the
264
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Dr. Anthony Robbins
Executive Director
Colorado Department of Health
July 21, 1977
Page Two
federal government has very limited authority in transportation planning
decision making (p. v-11). In Colorado, approximately 30% of the transpor-
tation investment is federally financed. Further, the region's highway and
public transportation plans as well as nearly all individual projects require
federal concurrence.
Additional comments on the draft environmental impact statement are
attached. Please do not hesitate to contact me if the Department of Highways
can be of any additional assistance.
Very truly yours,
Jack Kinstlinger
Executive Director
AP/sks
ATTACH.
265
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COLORADO DEPARTMENT OF HIGHWAYS
COMMENTS ON THE DRAFT REGIONAL ENVIRONMENTAL IMPACT STATEMENT
FOR WASTEWATER FACILITIES AND THE CLEAR WATER PROGRAM
Listed below are comments and suggestions for further analyses developed by the
Staff of the Colorado Department of Highways on the subject DEIS.
• The carbon monoxide (CO) analysis in the "Air Quality Impacts" section
(IV-42) is seriously flawed by the averaging of concentrations over a
four square mile grid cell. This results in the masking of the high-
est CO concentrations (p. IV-47).
• Although the Department of Highways has used the COM to simulate par-
ticulate emissions, the Department questions the validity of model's
basic assumption that particulate emissions are directly proportional
to VMT. Further, work is needed to determine if this assumption is
correct for the Denver situation and therefore which strategies would
be effective (p. iv-49).
• The draft statement is deficient for excluding Douglas and Weld counties
in the impact analysis. Obviously, relevant information was not easily
accessible for the counties since they are not members of the Denver
Regional Council of Governments (DRCOG); however, difficulty in obtaining
information is no excuse for such a serious error. The boundaries of
analysis should have been determined by including all the surrounding
county portions which are in close proximity to Denver and therefore are
most likely to be impacted - not by informational and modelling conveni-
ence. The seriousness of this omission was especially apparent in
northernDouglas County were rapid development of urban sprawl is already
occurring. In addition, much of northern Douglas County is within the
service area boundaries of the proposed Littleton-Englewood waste-
treatment plan and the Cherry Creek/Goldsmith Gulch 201 area. (Refer to
wastetreatment map).
• The draft, in its analysis of the projects' relationships to plans and
policies did not examine the proposed regional growth and development
policies developed by DRCOG. These proposed policies should be examined
because they will be used as a guide for future development in the region.
• There is little consistency between the map of wastewater treatment
facility boundaries and the map of urban service areas developed by
DRCOG. If the urban service area concept is to be adhered to these two
sets of boundaries need to be consistent.
• The maps accompanying the draft do not show where major interceptors or
collection lines will be laid. Therefore it is virtually impossible to
tell precisely where within each identified 201 study area severed growth
may occur. Without this information we must assume that the study areas
are to be completely developed. It is doubtful whether such development
would be economically feasible or desirable.
266
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The vehicle miles of travel (VMT) on Page A-71 is too low for the population
estimate. This was the result of using the RTD/SMC model which may under
predict the actual year 2000 VMT. The population figure being used is about
2,000,000, rather than the 1,800,000 as shown in A-10. The RTD/SMC model
was not formally adopted by the MPO, and therefore, the results of model
should not be used.
Any reference to I 470 should be changed to SH 470 as a result of the I 470
study.
Colfax Avenue runs east-west and cannot be described as going from the CBD
to Englewood (See Page A-71). It should read Broadway from the CBD to
Englewood.
On Page IV-86 under traffic, the dependence on the RTD bus fleet for the
long term should be expanded to include preferential treatment of high
occupancy vehicles, such as exclusive lanes, ramp bypasses at freeways.
On Page 1-70, the statement is made that as population increases, people
will live at greater distances from the CBD and other activity centers;
and absolute and per capita VMT will likely increase. This statement is
somewhat in error. The existing land use plan does not contain fully
developed activity centers. This limits the number of opportunities for
completing trips with minimum amount of travel. However, once all activity
centers are fully developed, the opportunity to make shorter trips will be
increased due to the number of increased businesses closer to the home
and thereby may result in a lower VMT per capita. It is agreed that the
absolute VMT will increase, but this cannot be eliminated as long as the
population increases.
The draft report did not mention the fact that the transportation planning
process, consisting of DRCOG, RTD, and CDH, is in the process of developing
a transportation systems management plan that will make better use of the
existing transportation system. Such things as ramp metering, preferential
treatment of HOVs are only a few of the areas being investigated. These
strategies are designed to conserve energy and improve air quality.
A major flaw of the analysis would be the fact that only one land use plan
was assumed with each alternative treatment concept presented. It would
have been more appropriate to examine alternative land use plans in conjunc-
tion with each set of alternative treatment concepts. These alternatives
could be tested to determine the cost of attaining the specified goals and
objectives as they relate to meeting water quality standards.
It would be helpful to include the population figures for each analysis year
by urban service area. This would allow for a better determination of con-
sistency with the land use data used in the transportation and other planning
processes.
The document contends that the construction or improvement of facilities in
the metropolitan area will result in further urban sprawl. It can be demon-
strated that the do-nothing alternative for controlling urban development
will not work. In fact, this is the worst alternative as it relates to energy
consumption for improving air quality. The transportation system is a servant
of the land use plan.
267
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The statement does not contain an analysis of how many new residents/ or
sewer connections each service area will have to attract on an annual
basis in order to pay off their annual debt service. An analysis of this
sort would give an indication of where and at what rate growth would have
to occur for the provision of sewer services to remain economically feasi-
ble.
On page III-l the statement is made that "the Clean Water Plan is concerned
primarily with non-point sources of water pollution, and secondarily with
point sources." Based on our previous review of DRCOG's Clean Water Plan
and the official state comments made by the Water Quality Control Commission
we feel that this statement is incorrect and should be deleted. The absence
of specific control measures and management techniques and implementing
agencies in the Clean Water Plan supports this opinion.
In the discussion of mitigation measures the suggestion is made that the
number of special districts should be reduced. The Department of Highways
agrees with this opinion and urges EPA to evaluate the consistency of this
recommendation with the structure of the point source management agencies.
To mitigate the impacts associated with the conversion of agricultural lands
EPA suggests the adoption of strong tax. disincentives to be imposed on trans-
actions involving agricultural lands. Experience in other states suggest
that these disincentives need to be extremely severe or that development
rights for agricultural lands need to be acquired (fee simple or easements)
by governmental jurisdictions. The Draft should have included draft legisla-
tion to implement this mitigation measure.
Page 1-11, Table I-A: If the decision option of Treatment Plant capacity and
timing will affect agricultural land turnover, it must certainly have a socio-
economic impact. Should have marked this column.
Page II-4, Paragraph 1: In an inversion temperature increases with height,
not "decreases". This error should be corrected.
Page 11-63, Table II-P: Douglas and Weld County should not be included in
this table if no information was gathered on them. The inclusion of zeroes
for this failure to gather information is misleading. Either reliable data
should be placed on the table or these two counties should be left out of
this particular table. We strongly suggest the former.
Page 11-64,. Paragraph 1: Because some of the counties near Denver are not
members of DRCOG and are not covered by the empiric model does not exclude
them from development pressures. This has been empirically disproved in
northern Douglas County. This is a total error.
Page III-2, Top: Local control of waste treatment plants may have an
unfavorable effect on water quality. This is because smaller jursidictions
with the commensurate smaller financial bases are more cost conscious. Con-
sequently, sophisticated treatment methods may be passed up. Also, a regional
treatment plant would facilitate unification of objectives so that the occur-
rence of discharing effluents overflows and thus water quality problems
down the stream" would be minimized. Finally, the presence of increasing
268
ii
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returns to scale would make a regional treatment plant favorable to water
quality. Smaller treatment plants, with smaller user demand, would be
less likely to fully utilize the expensive capital investments necessary
for sophisticated treatment methods. Because of this, local jurisdiction
with smaller plants would be reluctant to make these investments. However,
a large regional plant would have a large demand and thus could more fully
utilize the capacity of such investments, making them economically sound.
• Page III-2, Paragraph 2: By stating that the controlling of non-point
sources to the extent of meeting 1983 goals is a minor improvement in
water quality, it is inferred that either water quality, from a non-point
source perspective, is not a problem in Denver, or that the 1983 goals are
too modest to be effective. This statement should be clarified.
• Page 111-18, Paragraph 1: Water rights agreements which are clearly
archaic and lead to inefficient water use should be changed. This should
be discussed.
• Page IV-4, Paragraph 1: The fact that cities are noisy and congested is
a real problem. Actual empirical observations can be made everyday. The
blatantness of these problems is illustrated by the creation of federal,
state and local government bodies to deal with such problems.
• Page IV-4, Paragraph 1: Marginal economic analysis is presently and is
expected to be in the future, a very limited foundation for basing
conclusions. Certainly basing conclusions on economic value versus city
size with one study, plus on a marginal analysis, is grossly inadequate.
The validity of the study is doubtful since it could not have accurately
incorporated, with specific values, all the externalities which city growth
produces. Also, it may be argued that many of our largest cities are now
suffering economically because of their size. The analyst is advised to
observe the economic situation of New York City in which size has
contributed to increasing probability of mismanagement, large capital in-
vestments with long return periods, the allowance for the development of
powerful unions which increase the deficit between revenues and costs, and
the adverse effect of size on noise and air pollution and congestion which
tends to lower the desirability of the city for both residing and working
purposes. We need cities, but the idea that economies of scale are always
present with an increase in size or don't become exhausted until the city
is a megalopolis is absurd. If marginal benefit were clearly above
marginal costs then the flight of the higher income groups arid businesses
would not be occurring.
• Page IV-4, Paragraph 3: Economic growth is frequently favorable in the
shortrun, however, in the longrun, unrestrained rate of growth in the
economy can be devastating to an urban area. Denver's present growth
is primarily due to its naturally beautiful surroundings and the poten-
tial energy development. The attractive location has drawn a large
inflow of highly skilled labor which has resulted in a very attractive
location for high skill demanding industries. If economic, and there-
fore, population growth continues unrestrained, however, the attraction
to skilled labor of a "beautiful area" will be eliminated consequently,
not only will the inflow of skilled labor be reduced, but an actual
outmigration of this labor force would be probable. This result will
make it less attractive for businesses to locate here and could cause
an outmigration of existing Denver based businesses.
• Please change the spelling of Governor "Lamb" to "Lamm" throughout the
draft.
269
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RESPONSE TO COMMENTS BY
THE STATE DEPARTMENT OF HIGHWAYS
21 JULY 1977
1. Please see discussions in Volume 1, subsections III-l and IV-1.
2. Please see discussions in Volume 1, subsections III-1&4 and IV-1&4.
3. The grid cell analysis certainly does mask the highest CO concen-
trations, as the SAI report stated on pp. 31, 71, and 93. This
finding is supplemented by discussions of the nature of the ef-
fects that produce the highest concentrations. Since the highest
concentrations cannot be confidently modelled and occur too
commonly for all to be observed by practical monitoring systems,
the citizen is probably best served by noting and explaining the
existence of the maxima. See also response to Colorado Department
of Health, comment #3.
4. Agreed the approach used vas the best available, but has short-
comings as we noted on page 33, reference 998. It seems unlikely
that more adequate analyses would change any results qualitatively
and thus have any significant policy implications.
5. Please see discussions in Volume 1, subsections III-11 and IV-11.
Regarding air quality, the reader is warned in several passages of
extraregional Impacts.
6. Please see discussions in Volume 1, subsections III-9 and IV-9
and Volume 2, page 78.
7. Agreed, except Map J boundaries are of facility planning areas and
not necessarily areas to be served by a particular facility. Also
see discussion in Volume 1, subsection IV-1.
8. See figures III-A, III-B, and IV-B, of Volume 2.
9. This correction and note are hereby incorporated into the draft
EIS1 Appendix document by reference. The material noted was in-
cluded in error in the EIS. The air quality analysis used popu-
lation and traffic levels developed by CDH and DRCOG.
10. Correction incorporated.
11. Correction incorporated.
12. This recommendation has been included in the Traffic section of
Section IV, Volume 2.
13. Correction incorporated.
270
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14. This information has. been incorporated into the Traffic section
of Section II, Volume 2 (p. 62),
15. DRCOG's forecasts of land use and population were used throughout
the EIS as the only common and accepted regional projections. Varia-
tions in land use and population were explored in the Mitigating
Measures section of the Draft EIS and were used in developing the
actions EPA proposes as explained in Volume 1 of this final EIS.
16. See Table IV-H of Volume 2.
17. Continuation of urban sprawl is forecast, and wastewater treat-
ment facilities, as is the transportation system, are designed to
accommodate growth. The no-action alternative must be examined in
all EIS's, and was not intended as a growth-controlling mechanism.
18. See revised socio-economic impacts sub-section of Section IV, Vol-
ume 2.
19. Correction made. See discussions in Subsections III-5 and IV-5 of
Volume 1.
20. gee discussions in Volume 1, subsection III-4 and IV-4.
21. See discussions in subsections III-9 and IV-9 of Volume 1.
22. This Table has been deleted in the final EIS.
23. Correction made in Section III, Volume 2, pg. 17.
24. The error in Table II-P has been corrected by deleting the zeroes
and entering the note "no available data." Lines for Douglas and
Weld Counties remain on the Table to note a lack of potentially
useful data (p. 74).
25. This paragraph has been amended in Section II of Volume 2 to
correct the error (p. 75, paragraph 1).
26. Comment noted. There are a number of complex issues revolving
around local vs. regional approaches. See discussions under
Subsections III-3&4 and IV-3&4 of Volume 1.
27. Water quality impacts discussion of Section IV, Volume 2 clarified.
28. Please see discussions in Volume 1, Subsections III-6 and IV-6.
29. No response required.
30 and 31. Clarifying amendments appear in Chapter IV of Volume 2 in
response to these comments.
32. This error has been corrected in the Final EIS.
271
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THE STATE HISTORICAL SOCIETY OF COLORADO
Colorado State Museum, 1300 Broadway, Denver, Colorado 80203
August 5, 1977
Mr. Robert Siek
Associated Director for Environmental Health
Colorado Department of Health
4210 East Eleventh Avenue
Denver, Colorado 80220
RE: Denver Regional Environmental Impact Statement
for Wastewater Facilities and the Clean Water
Program
Dear Mr. Siek:
This office shall comment concerning only architectural and
historical properties that may be located within the poten-
tial environmental impact area of this project; the office
of the State Archaeologist will respond separately concern-
ing archaeological properties.
It is our understanding /based upon 40 CFR Part 1500.9(2)7
that compliance with the environmental requirements of
Section 102 (2)(C) of the National Environmental Policy Act
should include compliance with Section 106 of the National
Historic Preservation Act of 1966, as amended, and with Ex-
ecutive Order 11593. Toward that end, we note that the
Environmental Protection Agency (EPA) has identified the
major designated properties of architectural and historical
value within the Denver Metropolitan area.
The statement also contains a discussion of the potential
effects that the construction of wastewater facilities may
have upon these properties. The potential effect identified
by EPA is that of vibration caused by execavation and re-
moval of materials for conduits and facilities. It appears
that the EPA has overlooked several other, potentially more
harmful, effects of construction of wastewater facilities.
272
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Mr. Robert Siek
Page 2
First is the direct effect caused by excavation upon ar-
chaeological and historical archaeological material.
Conduits, if located in areas that hold remains of In-
dian and Euro-American activities, can destroy much
valuable historical information. To avoid this adverse
effect, we recommend that the EPA undertake an identifi-
cation program to pinpoint those areas that are most
likely to contain archaeological remains. This would
establish full compliance with the National Historic
Preservation Act of 1966 and permit efficient construc-
tion of the wastewater conduits and facilities. Certain-
ly provisions should be established to watch for and pro-
tect any cultural remains unearthed during ground disturb-
ing activities.
Secondly is the indirect effect upon cultural properties
caused by the pressures of growth that increased sewage
capacities would permit. As additional subdivisions and
developments are made possible, historical structures and
archaeological remains may be endangered. While the ef-
fects of growth may be unavoidable, certainly contingen-
cies to deal with these effects could be addressed.
A discussion of these effects and potential mitigation
could appropriately be included in the discussion of the
impacts upon cultural properties within the Denver metro-
politan area. Further exploration of these effects and
feasible mitigation could be contained within the site
specific environmental impact statements.
We look forward to working with the EPA to establish full
compliance with federal preservation law. Please contact
Michael Quinn of this office at 892-3394 or at the above
address if we may be of assistance.
FOR THE STATE HISTORIC PRESERVATION OFFICER
Sincerely,
James Edward Hartmann
Curator, Historic Preservation
cc: John Green (EPA)^
Advisory Council
Council on Environmental Quality
273
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RESPONSE TO COMMENTS BY
THE STATE HISTORICAL SOCIETY OF COLORADO
5 AUGUST 1977
1. Please see the Introduction to Section V, Volume. 2, and discussions
in Volume 1, subsections III-9 and IV-9. EPA will not publish the
archaeological sensitivity map and its supporting information.
These materials will be maintained by EPA for use in the review
of wastewater facility plans and other similar projects.
274
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MEMORANDUM
TO: Ron Simsick
FROM: Water Quality Control Division
DATE: June 28, 1977
SUBJECT: Denver Regional EIS for Wastewater Facilities/Clean Water
Program
the above mentioned project
The Division has received and reviewed
and has the following comments:
Improved Wastewater Treatment (Summary Report, page 25): The state-
ments made in this discussion were apparently based on DRCOG's
predictive modeling. Although, in general, they may be true, the
non-point source assessment that DRCOG conducted on non-point runoff
was not comprehensive or definitive enough to assign numerical
values to levels of treatment better than secondary. The Division
does not believe that it is accurate to state that "All other pollu-
tants are dominated by non-point sources contributing to water
pollution upstream of the Metro discharge." The reoccurrence
interval of rainfall and snowmelt events should be checked to see
how many days of the year this statement could be true.
In the same section, the Division can see no reason to go to
better than secondary treatment and lower BOD, S.S., P04, NH-, and
N03 if the effluent is to be used for irrigation. This section shoul
be rewritten with a little less positiveness and raise the questions
of non-point source controls as issues to be resolved by additional
monitoring. Otherwise, we will buying status quo with very little
chance of improving water quality through the Metro area.
Major Unavoidable Adverse Impacts (Summary, page 35): The Division
has a policy of secondary treatment and disinfection prior to dis-
charge for effluent used for irrigation purposes. We also under-
stand the Governor's Scientific Committee is also making this
recommendation after studying land application criteria for the
past several months.
275
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RESPONSES TO COMMENTS BY
THE STATE WATER QUALITY CONTROL DIVISION
28 JUNE 1977
1. Please see discussions in Volume 1, subsections III-5 and IV-5.
2. Please see discussions in Volume 1, subsections III-3 and IV-3.
276
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Senate Chamber COMMITTEES
7540 Kline Drive Cfotp pjf PolOTPrln Vice Chairman of:
Arvada, Colorado 80005 CMcUC UI ^OiOradO Rflane,
Denver Membero,
Local Government
State Affairs
July 25, 1977
Tns Environmental Protection Agancy
1860 Lincoln Strsat
Oanvar CO 80295
In re: 208 Watar Quality - Denver Rsgicn
Gsntlaman:
I am the elactsd Stata Senator from Senata District 16. Tnat
District includes all of North Jefferson County, portions of tha southern
part of Bouldar County and all of GUpin County. Includsd within this
District ara most of tha City of Arvada, portions of Uestminstar, Broom-
fiald and Bouldar and all of Cantral City and Black Hawk. All in all,
thera ara approximately 60,000 adults and a good many thousands of
young parsons and children. I would estimate that I rsprssant 80,000
to 90,000 parsons.
Tha 208 Watar Quality program for tha Danvar ragion is of upmost
importanca to tha psopla whom I represent.
You have befora you two plans with rafsranca to watsr quality
for tha Danver region. Ona involves no federal funding and the othar
involves significant contributions on tha part of tha Federal Government.
Watar quality is of coursa vital to tha Osnvar region and to
tha citizans whom I raprasant. The axpsnditurss involved in thesa plans
would ba substantial. Quita claarly, tha communities thsmsalvss cannot
undertake thesa projects with thair own financial rasourcas. They simply
do not hava the money.
I urga you to adopt the VJatsr Quality Plan which will involve
substantial assistance from the Fadaral Government. Thesa funds ara
available and the people whom I represent sra entitled to have this aid.
Should you adopt tha plan which involves no Fadsral funding, it would ba
a calamity. It appears that next year alone thera should be scma four
million dollars available in Fadsral funds to assist in this watar quality
277
&-. :
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July 25, 1977
Tha Environmental Protsction Agsncy
Paga Two
project. Quita claarly, your agency should authorize this.
For myself and on behalf of those whom I represent, I urge
you to adopt the federally funded plan and to authorize the expenditure
of at least, this four million dollars during the ensuing year.
Yours very truly,
Al Maiklsjohn
Stata Senator
District 16
AJMJr:pad
278
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RESPONSE TO COMMENTS BY
STATE SENATOR AL MEIKLEJOHN
25 JULY 1977
1. Please see Section III, Volume 2 and all of Volume 1.
279
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city oFarvada
B1O1 RALSTON ROAD
ARVADA. COLORADO BOOQS
PHONE 3O3-«421-255O
July 18, 1977
Environmental Protection Agency
i860 Lincoln Street
Denver, CO 80295
Attn: Bob Doyle
RE: EIS for Wastewater Facilities
and the Clean Water Program
The Statement, contrary to its title, dwells too much, on all consequences of growth
and not enough on the specific questions concerning impact from construction of
wastewater facilities. The Statement also leads the reader to the conclusion that
the only proper thing to do is to stop growth and suggests that one way to do it is
by not financing wastewater facilities. Such a suggestion flys in the face of the
national goal to clean up our water.
Specifically, the City of Arvada believes that more attention should be focused on
the impact from action proposed in the 208 Clean Water Plan and 201 Plan Alternatives
for Clear Creek. The proposed plans for Clear Creek recommends transportation of
wastewater from the basin to the Metro District Plant for treatment and then discharge
to the South Platte River. In the long run, such action will result in lower flows
in Clear Creek as compared to a treatment plant located in the basin which discharges
back into Clear Creek. Lower flows in Clear Creek obviously will affect the efforts
to achieve fishable, swimable waters.
The City of Arvada concurs with comments submitted by the Metropolitan Sewer District.
Sincerely,
Donald F. Allard
Deputy City Manager
DFA/sc
280
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RESPONSE TO COMMENTS BY
THE CITY OF ARVADA
18 JULY 1977
Please see the Introduction to Section V, Volume 2.
EPA will fund additional municipal wastewater treatment
facilities under terms and conditions described in Volume 1
of this final EIS. EPA will not support at this time the
Clean Water Plan recommendations for the Clear Creek planning
area. See discussions in Volume 1 subsections III-3, 6; and
IV-3, 6.
281
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CITY AND COUNTY OF DENVER
W. a McNICHOLS, JR.
Mayor
DEPARTMENT OF PARKS - RECREATION
1805 BRYANT STREET
DENVER, COLORADO 80204
June 21, 1977
Mr. John A. Green
Regional Administrator
U.S. Environmental Protection Agency
Region VIII
1860 Lincoln Street
Denver, CO 80203
Dear Mr. Green:
I have reviewed the Draft Environmental Impact Statement for the Denver
Regional Wastewater Facilities and Clean Water Program. I can not find
anything wrong with this as it relates to Parks and Recreation.
We know that we need to accelerate development of parks and acquire more
land for park, open space and recreational use. However, it boils down
to just one thing, available money - of which there seems to be very little.
Just to bring you up to date with the existing population of Denver alone
all of the land and facilities we would need just to keep pace would be
close to $35 million.
I agree with the regional tax base sharing plan. Denver foots the bill
for many of the facilities while the surrounding counties use' those
facilities, most of the time for free. Yet we get stuck with all of the
problems and welfare loads which cuts into our development, operation and
maintenance.
One thing that is mentioned is that growth should be discouraged in the
North and Northeastern portions. Denver annexed a great deal of land
out in that area for development but with shortages of water and natural
gas taps for awhile, development will be delayed for many years.. In this
area we had some larger park areas along with neighborhood park sites set
aside by the developers. We were also to receive two large land areas
for development of 2-18 hole golf courses which were going to be built
soon according to annexation agreements. Since no development has taken
place in these areas, we assume these may not be valid. In one case,
the larger developers are now bankrupt, and the development status is
up in the air.
282
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Mr. John A. Green
June 21, 1977
Page 2
A great deal of existing park development exists along Cherry Creek and
Goldsmith Gulch in Denver. We plan on doing a great deal more. It is
assumed that extensions of any sewer lines in these areas will not affect
this development.
If you have any further questions or need additional information, please
call me on 297-3155.
Sin
5hn E. Dillavou
Assistant Director
Parks Planning and Engineering
JED:kr
283
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RESPONSES TO COMMENTS BY
THE DEPARTMENT OF PARKS - RECREATION
THE CITY AND COUNTY OF DENVER
21 JUNE 1977
1. Please see discussions in Volume 1, subsections III-9 and IV-9.
2. Please see discussions in Volume 1, subsections III-4 and IV-4.
3. Please see discussions in Volume 1, subsections 111-10 and IV-10.
284
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CITY AND COUNTY OF DENVER
W. H. McNICHOLS. JR.
Mayor
DEPARTMENT OF PUBLIC WORKS
July 19, 1977
WASTEWATER MANAGEMENT DIV.
5055 WASHINGTON STREET
DENVER, COLORADO 80216
Mr. John A. Green
Regional Administrator
U.S. Environmental Protection Agency
Region VIII
1860 Lincoln Street
Denver, Colorado 80203
Dear Mr. Green:
Re: Draft Environmental Impact Statement for the Denver Regional Wastewater
Facilities and Clean Water Program
Pursuant to your notice of June 3, 1977, requesting a review and comment on the
draft Environmental Impact Statement (EIS) for the Denver Regional Wastewater
Facilities and Clean Water Program, the following comments are offered for your
consideration:
The draft EIS covers the many inter-related environmental issues surrounding
growth in the Denver Metropolitan Region; however, it is difficult to determine
from the text of material whether the "purpose" of the statement has been prop-
erly addressed and what EPA's position will be regarding financial participation
in the implementation of current and future projects and the 208 plan. The
question of controlling growth because of its impact on existing environmental
problems appears to be the main issue of this statement. It is the contention
of the City that continued growth is not only essential for the maintenance of
a viable urban setting, but continued growth is and always has been our goal.
To this extent the City and County of Denver has conscientiously worked toward
the preservation of environmentally sensitive areas and has continually attempted
to achieve a reasonable balance in its development between different land uses
and activities. Therefore, the City cannot permit repression of its development
activities and responsibilities to provide the services and quality of life its
citizenry expect and warrant because of unrealisticly imposed environmental re-
quirements. In addition, it is our considered opinion that this Statement, while
comprehensive in scope, is generally inadequate from the following perspectives:
(1) It unduly concentrates on the apparent negative environmental effects of the
proposed Facility Plans and Clean Water Plan; it has not fairly presented the
positive factors associated with these planning efforts; and (2) While being suf-
ficient for those individuals specifically involved and technically attuned to
the environmental process, the Statement is very difficult for the layman to under-
stand and effectively comment on.
285
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Mr. John A. Green
Page 2
July 19, 1977
Contrary to the statement on page X-l, first paragraph, which states "the water
quality goals will not be met by the 208 Clean Water Program," the City and
County of Denver takes this opportunity to voice its unequivocable support of
the 208 Program. This Program's provisions are realistic and are directed
toward the achievement of the national water quality goals in a reasonable time
framework. This Program was achieved through the mutual cooperation of all
parties involved. The Program recognizes that the multi-jurisdictional compo-
sition of the Denver metropolitan area will present problems in the implementa-
tion of its provisions; however, the Program has made significant strides to im-
prove upon this given system by the proposed establishment of basin-wide wastewater
management agencies. This multi-jurisdictional composition has functioned most
effectively to this time and has not prevented the achievement of many notable
regional accomplishments, such as the creation of the Metropolitan Denver Sewage
Disposal District No. 1, the Urban Drainage and Flood Control District, as well
as the Denver Regional Council of Governments. The City and County of Denver
strongly suggests that the EPA re-evaluate this region's initiatives in the areas
of environment, regional services, etc., and its locally implemented accomplish-
ments; the results of such an investigation should provide the assurances that
were evidently not apparent to the EPA consultant in the initial work leading to
the draft statement.
The Draft Statement continually stresses that water quality goals in this region
will not be met because of the pollutional loading from non-point source discharges.
A statement on page V-14, third paragraph, states that "future structural controls
are likely to be limited to commercial and industrial areas of the region as there
is significant evidence that the majority of a number of non-point sources of
pollution originates from these areas." The 208 Clean Water Plan recognized the
lack of data in this area and,proposed an extensive non-point source sampling
and monitoring program to provide the basis for determining the type, extent, and
appropriate control measures, either structural or non-structural with which to
address the non-point source pollutional problem. Furthermore, the 208 Plan rec-
ognized the limitations in improving water quality because of the lack of non-
point source management agencies but was quick to point out that, through its
continuing planning process, this issue will not only be addressed but also resolved.
The draft repeatedly makes the point that it will not be possible to meet the re-
quirements of PL 92-500 for Denver region's water bodies to comply with the 1983
goals for a quality suitable for swimming and fishing because of the pollutional
loadings from non-point discharges. The draft also points out the financial dif-
ficulties that cities would have in attempting to achieve these national goals.
If the EPA recognizes these deficiencies on a national scale, it would seem appro-
priate that the EPA initiate appropriate action to modify the law to establish
realistic requirements, dates, and provide necessary funds to local governments.
This would then permit initiation and implementation of reasonable programs to
address the non-point pollutional problem. The financial burden, which would
otherwise be placed on local governments to comply with the mandates of the public
law, given the other equally demanding urban problems, would be devastating. It
286
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Mr. John A. Green
Page 3
July 19, 1977
serves no purpose to establish national goals as zero discharge of pollutants
and swimable-fishable waters, to establish deadlines, permit limits of allowable
pollutants, or impose penalties, if it is known that time restraints are im-
possible to meet and the costs are of such a magnitude that they are simply
out of reach.
No one should contest the desirability of a pure environment. However, the facts
of life dictate otherwise; and it is recognized that the need to clean up our
environment is essential. However, it cannot be done in a "great leap forward"
and must proceed on a common-sense basis. Essential needs must first be deter-
mined and then receive priority consideration. As an example, in the field of
wastewater management, it is of no avail to expend vast sums to establish warm
water biota and bodily contact stream classifications if the subsurface collection
systems, sewers if you will, are old, leaking, and in various stages of extreme
deterioration. It is believed that this is a general condition throughout the
United States, if not the world. Recognizing this, it is difficult to reconcile
the fact that under the implementation of Public Law 92-500, the major emphasis
was for funding of treatment plants. If wastes cannot be transported properly
to these plants, they cannot be properly treated. The result is pollutants which
are distributed throughout the trace of the various collection systems and even-
tually find their way into the natural drainage features.
The draft EIS does not address the potential impact on the environment based on
the non-implementation of the projects covered in this document and the continu-
ation of growth in the region. A comparison of the probable impacts on the en-
vironment with and without the implementation of the proposed project and the
208 plan should be included in the EIS to provide necessary information on the
relative impacts of growth on the region's environment. The contemplated projects
are planned to mitigate existing problems as well as prevent their recurrence by
making allowances for moderate growth; therefore, it is recommended EPA support
their implementation and provide to local entities the necessary funding to improve
and protect the region's environment.
The following comments are intended to correct, clarify, and modify a number of
inaccuracies within the draft text.
1. Page 11-61, Table II-O, the entries for the City and County of Denver User
Charges should be corrected as follows:
Third column - 101 percent of water rate in effect as of
December 31, 1973; water rate equals $.49/1000; fifth
column - 150 percent of water rate plus a surcharge;
columns seven and eight, both commercial and industrial
tap fees are set—per rate schedule as developed by the
Manager of Public Works.
The reference for the above information is Article 167 of
the Revised Municipal Code of the City and County of Denver.
287
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Mr. John A. Green
Page 4
July 19, 1977
2. Page III-8, fourth paragraph, states the Cherry Creek and Goldsmith
Gulch service area is*"within the jurisdiction of Metropolitan Denver
Sewage Disposal District No. 1." The word "jurisdiction" without the
proper qualifiers, is incorrectly used in this paragraph. The only
jurisdictional authority possessed by the Metropolitan Denver Sewage
Disposal District No. 1 is planning as it affects their plant expansion.
The area is, however, within the complete jurisdictional authority of
the City and County of Denver.
3. Page III-9, fourth paragraph, states that "the five Sand Creek sub-
basins are administered by the Metropolitan Denver Sewage Disposal
District No. 1." This statement is misleading. The City and County
of Denver administers that sub-basin which is totally within its
boundaries (Westerly Creek); the flows within this area are trans-
ported to a Metropolitan Denver Sewage Disposal District No. 1 inter-
ceptor and plant for primary and secondary treatment.
4. Page V-10, fourth paragraph, the need to determine the effectiveness
of "street cleaning" as a control measure for improving both air and
water quality through the use of "demonstration studies" is essential.
However, it is suggested that these studies be extended in scope to
include all other similar control measures, such as catch basin cleaning,
street salting, etc.
I trust these comments will be helpful in revision of this draft statement. If there
are any questions concerning the comments contained within this report, please feel
free to contact this office at your convenience. The opportunity to participate
in this review process is appreciated.
Very truly yours,
P.E.
Di rector
JZ:clj
288
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RESPONSES TO COMMENTS BY
THE DEPARTMENT OF PUBLIC WORKS OF THE
CITY AND COUNTY OF DENVER
19 JULY 1977
1. EPA believes the scope of the draft and final EIS is appropriate
to its larger responsibility of protecting the environment.
The EPA has no mission to control growth per se. The draft EIS
was to aid EPA in reaching a position which is explained in
Volume 1 of this final EIS. For additional material responsive
to these comments, please see the Introduction to Section V,
Volume 2.
2. The Clean Water Plan recommended by DRCOG, has been significantly
altered by the conditions imposed by Governor Lamm. These con-
ditions plus others proposed by EPA specifically address water
quality goals and stream classifications. See discussions in
Volume 1, subsections III-2, 4 and 5; and IV-2, 4 and 5.
3. Please see discussions in Volume 1, subsections III-5 and IV-5.
4. These corrections have been incorporated into Section II, Volume 2
(p. 73).
5. These distinctions have been made by amending the referenced
paragraphs in Section III, Volume 2 (pp. 93 and 94).
289
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RICHARD P, LJUNDAHL
DIRECTOR OF PUBLIC 'i
ClTY OF MORTHGLENN^ COLORADO
TESTIMONY AT EPA PUBLIC HEARING
DENVER .REGION EIS
JULY IS, 1977
MR, CHAIRMAN, LADIES AND GENTLEMEN:
THE CITY OF NORTHGLENN SHARES THE CONCERN OF ERA AND OTHERS REGARDING
A PIECEMEAL APPROACH TO ENVIRONMENTAL PLANNING, !'fe SUPPORT THE CONCEPT
OF A REGIONAL ENVIRONMENTAL IMPACT STATEMENT FOR WASTEWATER FACILITIES
TO BE CONSTRUCTED OR EXPANDED IN THE DENVER AREA,
Vfe ARE CONCERNED, HOWEVER, THAT THE OVERVIEW EIS TALKED IN NEGATIVE
TERMS WITH RESPECT TO LAND APPLICATION AS A METHOD OF SEWAGE TREATMENT,
FOR EXAMPLE, THE ADVERTISING SUPPLEMENT IN THE LOCAL PAPERS NOTED "PUBLIC
HEALTH AND SOIL DAMAGE MAY RESULT FROM AGRICULTURAL IRRIGATION WITH WASTEWATER
TREATMENT PLANT DISCHARGE UNLESS BETTER TREATMENT QUALITY IS ATTAINED,"
THERE ARE OTHER NEGATIVE STATEMENTS IN THE MAIN REPORT ON PAGE IV-94, PAGE V-
M, V-15 AND PAGE VI-1.
SPECIFIC GUIDELINES FOR WASTEWATER QUALITY TO BE USED FOR AGRICULTURAL
IRRIGATION ARE SO STRINGENT THAT ADVANCED WASTEWATER TREATMENT (A'\T)
WOULD BE REQUIRED PRIOR TO LAND APPLICATION, PAGE 25 OF THE SUMMARY EIS AND
PAGE V-1A OF THE MAIN REPORT INDICATE, AMONG OTHER THINGS, THAT TOTAL
NITROGEN SHOULD NOT EXCEED 5 MG/L AND AMMONIA SHOULD NOT EXCEED 3 MS/L,
IF THESE GUIDELINES ARE ALLOWED TO STAND, THE WHOLE IDEA OF LAND APPLICATION
AS A METHOD OF WASTEWATER TREATMENT WOULD BE DEALT A SEVERE BLOW,
ffc, THOMAS C, JORLING, ASSISTANT EPA ADMINISTRATOR, HAS SAID THAT
"MUNICIPAL WASTE is COMPRISED OF, AMONG OTHER THINGS, PHOSPHOROUS, POTASSIUM
290
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-2-
AND NITROGEN, THE STANDARD NUTRIENTS OF COMMERCIAL FERTILIZER, THESE
MATERIALS SHOULD HAVE BEEN INCORPORATED INTO A NEW ECOLOGICAL DEFINITION OF
SECONDARY TREATMENT, YET THIS WAS NOT DONE AND HAS NOT BEEN DONE,"
IN A JULY 1, 1977 PRESS RELEASE MR, JORLING FURTHER NOTED THAT MUNICIPAL
TREATMENT TECHNOLOGIES HAVE BECOME "HIDEBOUND" AND EPA IS HAVING DIFFICULTY
PROMOTING RECYCLING OF SEWAGE WATER FOR IRRIGATION PURPOSES BECAUSE OF
INTERNAL "INERTIA" AND RESISTANCE TO CHANGING FROM CONVENTIONAL SEWAGE
TREATMENT TO LAND APPLICATION METHODS,
WE AGREE WITH ffc, JORLING THAT NUTRIENTS IN SEWAGE MUST BE PUT TO
BENEFICIAL USE, Vfe AGREE WITH THE EIS THAT STANDARDS MUST BE ESTABLISHED
FOR AGRICULTURAL REUSE OF SEWAGE EFFLUENT, HOWEVER, THESE STANDARDS MUST
BE CONSISTANT WITH THE NATIONAL STATE-OF-THE-ART OF LAND APPLICATION AND
MUST RETAIN THE NUTRIENTS VALUABLE TO THE FARMER AND TO HIS LAND,
ANOTHER SPECIFIC COMMENT, THE ENERGY IMPACTS ANALYSIS is TOO GENERALIZED.^
IT SHOULD CONSIDER CONSTRUCTION AND OPERATION OF THE PLANT, INCLUDING ENERGY
IMPACTS OF THE MANUFACTURE OF CHEMICALS AND TRANSPORTATION OF CHEMICALS AND
SLLinccS, THE ENERGY SAVED BY APPLYING NUTRIENTS IN THE SEWAGE DIRECTLY
TO THE LAND RATHER THAN MANUFACTURING AND DELIVERING PETROLEUM-BASED
FERTILIZER IN LIKE QUANTITY SHOULD BE CONSIDERED, ALSO, SPECIFIC OPERATIONAL
COMPARISONS BETWEEN CONVENTIONAL TREATMENT PLANTS AND LESS INTENSIVE ALTERNATIVES
SUCH AS LAND TREATMENT SHOULD BE CONSIDERED.
THE CITY OF NORTHGLENN HAS PUT TOGETHER A COMPREHENSIVE PLAN FOR TOTAL 0
WATER RESOURCES MANAGEMENT. WHICH INCLUDES A PLAN TO TREAT STORM RUNOFF,
BECAUSE STORM RUNOFF, SEWAGE TREATMENT AND WATER SUPPLY WILL ALL BE COMBINED
INTO A SINGLE SYSTEM, WE WILL MEET THE 1983/85 GOALS OF PL 92-500 FOR BOTH
291
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-3-
POINT AND NON-POINT SOURCE DISCHARGES AT REASONABLE COST, IT WOULD APPEAR
THAT OTHER CITIES COULD DO THE SAME THING AND WORK TOWARD REACHING 1983/85
GOALS NOW RATHER THAN JUST MEET 1977 GOALS NOW AND REBUILD OR EXPAND
IN 1982 TO MEET 1983/85 GOALS,
THE NORTHGLENN LAND AND vJATER RESOURCES MANAGEMENT PROGRAM GOES TO
THE HEART OF THE FIVE MAJOR ENVIRONMENTAL IMPACTS AREAS IDENTIFIED IN THE
EIS,
I. SOCIO-ECONOMIC IMPACTS
THE NORTHGLENN SYSTEM WILL BE CAPABLE OF SERVING THE ULTIMATE
POPULATION OF NORTHGLENN; THE SYSTEM IS RELIABLE & WILL PROVIDE
A HIGHER LEVEL OF SERVICE THAN THE PRESENT SYSTEM; IT WILL
MEET ALL FUTURE WASTEWATER TREATMENT REQUIREMENTS; IT WILL COST
LESS THAN THE PRESENT APPROACH WHEN NON-POINT SOURCE DISCHARGE
PROBLEMS ARE ADDRESSED, IT WILL PROMOTE PRODUCTIVE EMPLOYMENT
IN THE AGRICULTURAL SECTOR WITH RIPPLE EFFECTS THROUGHOUT THE
REMAINDER OF THE ECONOMY,
II. HATER QUALITY IMPACTS
THE NORTHGLENN SYSTEM:
- MEETS THE 1983 GOAL OF FISHABLJE/SWIMMABLE WATERS AND THE 1985
GOAL OF NO DISCHARGE OF POLLUTANTS
- TREATS STORM RUNOFF WATER
- USES FRONT-RANGE WATER RESOURCES FOR FRONT-RANGE USERS
- CONSERVES WATER RESOURCES AND INCREASES WATER SUPPLY
III, AGRICULTURAL IMPACTS
THE NORTHGLENN SYSTEM:
292
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-4-
- PROMOTES A PARTNERSHIP BETWEEN ClTY 8 FARMERS TO PRESERVE
AGRICULTURAL WATER RIGHTS AND PRIME IRRIGATED LAND
- PROVIDES FERTILIZER & INCREASED WATER SUPPLIES TO INCREASE
FARM PRODUCTIVITY
IV, ENERGY IMPACTS
STUDIES HAVE SHOWN ADVANCED MUSTEWATER TREATMENT (AKT) TO BE 5
TO 10 TIMES AS ENERGY INTENSIVE AS LAND TREATMENT, LAND APPLICATION
ALSO SAVES ENERGY ASSOCIATED WITH THE PRODUCTION OF PETROLEUM
BASED FERTILIZERS AND MAKES THE FARM COMMUNITY LESS SUSCEPTIBLE
TO THE NEGATIVE IMPACT OF ENERGY SHORTAGES BY PROVIDING FERTILIZER
TO THEIR CROPS,
V, AIR QUALITY
A LAND LXKED ClTY WAS ABLE TO FIND A WAY TO HELP PRESERVE AGRICULTURAL
LANDS, THEREBY HELPING TO PREVENT URBAN SPRAWL AND AIR POLLUTION
PROBLEMS OF SPRAWL & AUTO TRANSPORT,
IN CONCLUSION, WE DO NOT AGREE WITH MESSRS, HENDRICKS AND BUUESTEIN'S
STATEMENT REFERRED TO ON PAGE IV-95 OF THE EIS THAT "IMPROVEMENTS OF WATER
QUALITY IN THE PLAINS SOUTH PlATTE TO 1983 LEVELS (AS SPECIFIED BY PL 92-500)
WILL RESULT IN FEW BENEFITS AND AT VERY HIGH COSTS," Vfe ARE JUST BEGINNING
TO UNDERSTAND THE PROBLEM, SO TO THROW UP OUR HANDS IN DEFEAT IS INAPPROPRIATE,
THE NORTHGLENN PROGRAM COULD BE USED BY MANY OTHFR CITIFS TO BEGIN TO SOLVE
THEIR WATER SUPPLY, SEWAGE TREATMENT AND STORM RUNOFF TREATMENT PROBLEMS,
IT WILL TAKE A COOPERATIVE EFFORT BY CITIES, FARMERS, ENVIRONMENTALISTS,
ECONOMISTS, CONSERVATIONISTS, ENGINEERS, BIOLOGISTS, POLITICAL SCIENTISTS
AND MANY OTHER DISCIPLINES TO CLEAN UP OUR NATION'S WATERS, THIS EIS
293
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-5-
SHOULD ENCOURAGE SUCH COOPERATION AND FEDERAL FUNDING SHOULD BE ALLOCATED
IN SUCH A WAY AS TO FAVOR COOPERATIVE VENTURES WHICH COMBINE ALL ASPECTS
OF WATER RESOURCES MANAGEMENT,
294
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RESPONSES TO COMMENTS BY
THE CITY OF NORTHGLENN
18 JULY 1977
1. The guidelines for effluent quality for land application stated
in the Draft EIS were in error. There are valid concerns which
must be addressed in land application. In some instances,
primary treatment may be all that is required as for fodder
crops for non-dairy cattle. In other instances, as for non-
processed food crops, very high levels of wastewater treatment
may be required to avoid contamination with pathogenic organisms.
Dissolved salts and heavy metals may cause soil and crop damage
and/or require more intense farm management, cultivation and
excess irrigation. See discussions in Volume 1, subsections
III-3 and IV-3.
2. This is a valid point. Please see discussions in Volume 1,
subsections III-8 and IV-8.
3. A valid point, however, please see discussions in Volume 1,
subsections III-3, 5 and IV-3, 5.
4. No response required.
295
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Phone
(303)
289-5801
CITY OF THORNTON
8992 N. WASHINGTON ST., THORNTON, COLO. 80229
July 18, 1977
Mr. John A. Green, Regional Administrator
Environmental Protection Agency, Region 8
1860 Lincoln Street, Suite 900
Denver, CO 80203
Dear Mr. Green:
The City of Thornton wishes to thank you for this opportunity
to comment on the E.P.A.'s draft environmental impact state-
ment. The City has a number of concerns about this draft; the
primary ones will be discussed in this letter.
The City's first major concern is the recommendation that no
grants be made in Adams and eastern Boulder Counties. The
vast majority of land inside incorporated boundaries of this
area has already progressed in the land conversion chain from
agricultural to land corporation or investment company owner-
ship. This is a fact that must be dealt with in realistic
terms. Lack of federal funding for waste water construction
would do little more than increase the already high cost of
housing.
We appreciate the E.P.A.'s concern for water rights. However,
over the years a fairly elaborate and sophisticated structure
for dealing with the water right situation within the State
Constitution has evolved. To superimpose a federal agency
such as the E.P.A. over a State matter such as water rights
seems extremely burdensome. We ask that this matter be left
at the State level where it has historically been dealt with
in a competent and efficient manner.
The City's third area of concern is the draft's discouraging
approach toward land waste treatment. The many benefits of
these programs should be addressed and amplified in the draft
environmental statement. It seems to us that Region VIII's
approach to this problem is out of step with the President's
mandate concerning land treatment and its priority position
concerning funding.
296
_ ,
i •";-'; .-•",/
Lx"" * ***'*'
-------
Mr. John A. Green, Regional Administrator
Page Two
July 18, 1977
Thornton strongly disagrees with the draft environmental
impact statement concerning further restrictions on the abi-
lity of municipalities to obtain water. We strongly urge re-
consideration of this matter. House Bill No. 1555 (1975) al-
ready imposes substantial restrictions to the condemnation of
water rights. It is our belief that the E.P.A. should con-
sider the practical problem of restricting the City's ability
to acquire water rights held in combination with land for
speculative purposes.
Again, we appreciate this opportunity to participate in the
review of the Environmental Protection Agency's draft environ-
mental impact statement. If we can be of any further assis-
tance, please do not hesitate to contact us.
Sincerely,
CITY OF THORNTON, COLORADO
On hS
^fS^Lcu^CA.
Richard L. Gerstberger, P.E.
Director of Utility Operations
RLG:ls
cc: C. Palmer, Utilities Engineer
J. Perry, City Manager and Utilities Director
file
297
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RESPONSES TO COMMENTS BY
THE CITY OF THORNTON
18 JULY 1977
1. Please see discussions in Volume 1, subsections III-9 and IV-9.
2. Please see discussions in Volume 1, subsections III-6 and IV-6.
3. Please see discussions in Volume 1, subsections III-4 and IV-4,
and responses to City of Northglenn's comments immediately
preceeding.
4. Please see discussions in Volume 1, subsections III-7 and IV-7.
298
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July 14, 1977
Office of the City Manager
Mr. John A. Green, Regional Administrator
Environmental Protection Agency, Region VIII
1860 Lincoln Street, Suite 900
Denver, Colorado 80203
Dear Mr. Green:
The City of Westminster thanks you for the opportunity to comment
on the EPA's draft EIS. The City has a number of concerns about the
draft; the primary ones will be addressed in this letter.
The first major concern is the discouraging approach taken towards
land waste treatment. While the quality of effluent used in such pro-
jects is indeed a concern, with present technology it hardly deserves
the emphasis placed on it in the EIS. Attached for your reference are
portions of supporting reports adopted by EPA. The many benefits of
these arrangements, including the participating municipalities' stake in
maintaining agricultural use on affected land, should be addressed and
amplified. With President Carter's suggested mandate that this process
receive funding priority, Region VIII's approach seems particularly out
of step. It is also paradoxical that this quality issue receives such
attention while the fact that 120,000 people are drinking water that
receives direct discharge of less than secondary effluent goes unmen-
tioned.
The second area of concern is the cursory treatment of the pluton-
ium situation. This is an issue that must be addressed and resolved
while the possibility of implementing a solution, should one be needed,
exists. A Denver Regional EIS which does not begin to address this
issue has a serious shortcoming.
The City's third area of comment is the recommendation that no
grants be made in Adams and eastern Boulder Counties. The practicality
of the situation is that the predominance of land inside incorporated
boundaries of this area has already progressed in the land conversion
chain from agricultural to~land corporation or investment company
ownership. This is the reality that must be dealt with. Lack of
Federal funding for wastewater construction would do little more than
increase the already high cost of housing.
Westminster urges the draft EIS's statement favoring further
restrictions on the ability of municipalities to obtain water to be
(Continued)
3031 West Seventy Sixth Avenue • 80030
299
• 303 429-1546
-------
Mr. John A. Green -2- July 14, 1977
reconsidered. House Bill 1555 (1975) already imposes substantial
barriers to the condemnation of water rights. The EPA should consider
the practical problem of restricting the City's ability to acquire water
rights held in combination with land for speculative purposes. Much of
the water currently under condemnation is in this category.
EPA's concern with water rights is understandable. However, in the
100 years of Colorado's statehood, a fairly elaborate and sophisticated
structure for dealing with the water rights situation under the State
Constitution has evolved. To suppose a federal agency, such as EPA,
should at the "last minute" require satisfaction with what has for a
century been a state matter seems extremely overreaching. We ask that
this be left to those who have historically proved competent to deal
with the matter.
Although the EPA did not recommend one of the three wastewater
alternatives, the choice seems to be between the no-action and local
alternatives. The City of Westminster urges selection of the local
alternative for the following reasons:
1. The no-action alternative would place undue economic hardship
on the region's citizens.
2. The area has a good record of meeting water quality goals thus
far and is actively striving to meet future goals.
3. Denial of funds for the region based on future growth or urban
runoff cannot be justified.
4. The ambitious goals set by PL92-500 go hand in hand with
federal funding commitments. Without this the act must be
seriously re-examined.
Enclosed are the City's comments on specific items. Please feel
free to call us at the City if you need any amplification on our concerns.
Very/truly yours,
Steve Ca
City Manager
cc: Water Quality Control Commission
Denver Regional Council of Governments
300
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CITY OF WESTMINSTER July 14, 1977
TECHNICAL COMMENTS on EPA's DRAFT EIS
Draft Page Comment
1-11 A likely decision option occurs at the junction of
alternative systems and agricultural land loss.
11-24 The statement that new water will come from importations
is misleading. This ignores exchange programs based
on a change of agricultural rights to municipal use,
non- tributary groundwater, developed water, conservation
savings and the purchase of water rights. It also ignores
the fact that water in the region is not managed to
achieve maximum use.
11-49 Refer to letter comment.
11-62 Westminster's current tap fee is $720 for wastewater
service. User charges are based on winter water use at
$.65 per thousand gallons of average monthly consumption.
III-3 Westminster and Broomfield have accepted management
responsibility for the upper Big Dry Basin as defined by
DRCOG. It is generally the land west of 1-25.
111-10 The 201 facility plan is considering expansion to 7.0
MGD for Broomfield and Westminster.
111-17 The Draft EIS recognizes that the water rights issues
involved in various effluent reuse, successive use and
exchange plans are too complex and too individualized
for it to discuss in any detail. However, the Draft
EIS does make several statements about the water rights
aspects of such wastewater systems and to those state-
ments the City of Westminster submits this response.
Initially, it should be noted that the Draft EIS does not
consistently use the various terms ("reuse", "successive
use", and "exchange") which describe different types of
effluent use systems. It may be helpful to note that in
City and County of Denver v. Fulton Irrigating Ditch Co. ,
179 Colo. 47, 506 P. 2d 144 (1972), the Colorado Supreme
Court set forth the following definitions as to trans -
mountain (foreign) water:
"Reuse" means a subsequent use of imported water
for the same purpose as the original use. For
example, this could embrace the treatment of
sewage resulting in potable water which is re-cycled
into the regular water system.
(Continued)
301
-------
TECHNICAL CQWENTS -2- July 14, 1977
Draft Page Comment
"Successive use" means subsequent use by the water
importer for a different purpose. This includes
the practice of the City of Aurora and possibly
other municipalities which treat sewage containing
imported water for further use by the city for
irrigation of public parks and facilities and for
industrial uses.
"Right of disposition'' means the right to sell,
lease, exchange or otherwise dispose of effluent
containing foreign water after distribution through
Denver's water system and collection in its sewer
system. (179 Colo, at 52)
Although these definitions are used in regard to foreign
water, the EIS may wish to adopt them for general use in
its Statement.
The plan contemplated by the contract between Farmers'
High Line Canal and Reservoir Co. and Westminster is a
water exchange plan. An exchange of water as contemplated
by statute (CRS 1973, 537-80-120(2)-(4) and 537-83-101,
et seq.) allows municipal use of hitherto agricultural
irrigation water and repayment of water to the agricultural
water owners from effluent from Westminster's Big Dry
Creek Wastewater Treatment Facility. Since under this
plan the water will be first used for municipal purposes
and the effluent then used for agricultural purposes, it
is an exchange plan which is somewhat analogous to what
the Court has defined as "successive use", yet also
follows the concept of "right of disposition".
The draft EIS fails to adequately describe the concept of
a water exchange. It confuses the ability of a water
user to reuse, successively use and to dispose of imported
water with the ability of a water user to exchange water.
Under Colorado law (see CRS 1973 537-80-120(2)-(4) ) a
water user may not impair the availability of water
lawfully divertible by others. The concept of exchange
is not restricted to imported, non-tributary, or developed
water but may be exercised as to any water. Therefore,
the statements in the draft EIS on p. 11-46, III-17,
IV-83 and Appendix 22 concerning the restrictive use of
water which is not imported omit a significant concept.
IV-15 Although the derivation of the per cent of growth to 2000
accommodated is unclear, 71 for Westminster/Broomfield
seems incorrect. Improved treatment is an objective of
the facility plan.
(Continued)
302
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TECHNICAL COMMENTS -3- July 14, 1977
Draft Page Comment
IV-28, IV-30 Please check with DRCOG for updated Westminster figures.
An explanation of its allocation technique will also
clarify why the local and regional numbers seem so far
apart.
IV-34 The conclusion that agricultural demand is less flexible
than municipal is wrong. Municipalities have at most a
30 per cent margin of flexibility. Farmers have
historically adapted to the natural supply which roughly
varies from 40% to 150% of average.
IV-67 The present Big Dry Plant is discharging 1 MGD or 1.5
cfs. Removal of this flow from Big Dry Creek can hardly
be called a significant flow reduction.
IV-76 Groundwater water supply is a designated use for the
South Platte below MDSDD #1.
IV-82 See comments on III-17.
IV-94 Refer to letter comment.
V-3 Refer to letter comment.
V-15 Refer to letter comment.
V-16 Refer to letter comment.
303
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£PA-50Q/2-73-C35b
"August 1073
Environmental Protection Technology Series
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304
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SECTION IX
LAND APPLICATION POTENTIAL
Many benefits as well as limitations involved in land appli-
cation have been discussed in this report. In this section
the intent is to place both limitations and positive aspects
of land application in perspective and to attempt to analyze
the future potential of the various methods. The first
part of the discussion deals with municipal wastewater;
the second part deals with industrial wastewater.
MUNICIPAL WASTEWATER
Land application of municipal wastewater in this country
has been done mainly by irrigation, to a lesser extent by
infiltration-percolation, and not at all by overland flow.
The limitations and benefits of each approach are different
and will be discussed separately.
In comparing the three approaches to land application it is
helpful to define the objectives to be achieved with treated
wastewater and to observe the response of each approach
in realizing those objectives. In Table 29 a list of
objectives has been assembled and the ability of each
approach to realize those objectives is tabulated. As
can be seen, each approach has several potentialities as
well as limitations. In addition to considerations of man-
agement objectives, an analysis of land application must
include considerations of the Federal Water Pollution
Control Act Amendments of 1972.
Federal Amendments of 1972
Land application was given a substantial role in the Federal
Amendments of 1972 to implement the "national goal that dis-
charge of pollutants into navigable waters be eliminated
by 1985." Section 201(b) of the Act stipulates that:
(b) Waste treatment management plans and prac-
tices shall provide for the application of
159
305
-------
Table 29. Comparison of Irrigation, Overland
Flow, and Infiltration-Percolation for
Municipal Wastewater
Objective
Use as a treatment process viitli
a recovery of renovated water
Use for treatment beyond
secondary:
1. For BOti an J suspended
solids renoval
2.- For nitrogen removal
3. For phosphorus renoval
Use to grow crops for sale
Use as direct recycle to
the land
Use to re eh. irne groundwurer
Use tn cold climates
Irris.it i on
Impractical
(tO-9'.>*
Up to 90'.*
SO -93;
Excellent
Coaplvtc
o-.io:
Fairb
Tvpe of .itiiiroach
Ovvrl.iiiJ flow
50 to 60 ',
recovery
90-09'.
70-90:
50-00'.
Fair
Partial
o-in:
••C
liii'i 1 1 r.it ioii-
p«' rv'i'tut i on
Up tn 99?
recoverv
3.1 • 3? V
0-SO'.
70-95'.
t'oor
CorpU'te
Uji to »Ui
l.xcclU'nt
a. Dependent upon crop uptake.
b. Conflicting data—woods irrigation'acceptable, cropland irrigation margin.il.
c. Insufficient data.
the best practicable waste treatment tech-
nology before any discharge into receiving
waters, including reclaiming and'recycling
of water, and confined disposal of pollu-
tants so they will not migrate to cause
water or other environmental pollution and
shall provide for consideration of advanced
waste treatment techniques.
Land application is emphasized in Section 201(d)(l) by the
stipulation that:
(d) The Administrator shall encourage waste
treatment management which results in the
construction of'revenue producing facili-
ties providing for —
(1) the recycling of potential sewage pollutants
through the production of agriculture,
silviculture, or aquaculture products, or
any combination thereof;
306
-------
Thus, land application must be considered as an alternative
to conventional and advanced wastcwatcr treatment in the
prevention of surface water pollution.
Irrigation
The benefits of irrigation are many: economic return on
the sale of crops; saving of potable water supplies through
exchange by irrigating landscapes,.golf courses, parks, and
highway medians with wastewater; fire protection by hill-
side spraying (especially in California [141]); and serving
as a positive and reliable alternative to advanced waste
treatment and/or surface water discharge. The latter
benefit applies to most land application methods.
As shown in Section VIII, economic benefits from the sale
of crops have been substantial'in some cases. Operating
costs arc low due to the relative simplicity of operation.
Irrigation with municipal wastewater may be allied with the
need for open space and green belts in urban and suburban
areas. The Golden Gate Park wastewater reclamation plant
in .San Francisco, California, has been producing 1 mgd
of water for this purpose for the last 40 years [70, 48,
73]. Irrigated lands have also been leased for recreational
purposes such as duck hunting in the fall. In Section
201(f) of the 1972 Federal Amendments it is stipulated that
"waste treatment management which combines open space and
recreational considerations w-ith such management" shall be
encouraged.
Several limitations to irrigation have been mentioned in
this report. The principal ones are the considerable
land area required, its relatively high cost, and its
relatively long distance away from large urban sources of
wastewater. In climatic Zones A and B in moderate-sized
cities near agricultural areas, the practice is quite
feasible, and many cities have followed this approach. In
climatic Zones C, D, and E the need for irrigation water is
less and agricultural land has considerable value without
irrigation; therefore, the practice requires other
motivations. At Muskegon, Michigan, where nearly 10,000
acres will be irrigated, the need was for an economic
and feasible alternative to surface water disposal [34].
Limitations to spray irrigation for health reasons are less
severe. Adequately disinfected wastewater should pose no
danger to health when it is sprayed. Aerosols for spraying
should be kept from traveling as heavy mist outside of the
irrigation tract by rows of trees or buffer zones. Any
aerosolizing of inadequately disinfected municipal
307
-------
wastewater, be it in an activated sludge plant, a river
outfall, or in a spray field, produces some risk to human
health, and these risks should all be minimized. Sprinklers
that spray downward or horizontally, especially with low
nozzle pressure, adequate disinfection, and buffer zones
all function to increase the safeguards.
Overland Flow
Overland flow is subject to the same types of limitations
as irrigation, but it can be done with a relatively im-
permeable soil and a gently sloping terrain. These latter
two factors may combine to yield a land site of moderate
cost. In general, suitable sites will be as difficult
to find within economic transmission distances of cities
as they are for irrigation.
Overland flow has considerable potential for treatment of
municipal wastewater. At Ada, Oklahoma, comminuted munici-
pal wastewater has been sprayed at low pressures in an ex-
perimental system at a loading rate of about 4 in./wk.
The results show an effluent of a quality approaching
that from tertiary treatment. In addition to a relatively
low construction cost, the system produces no sludge,
which is an aspect with great appeal.
Operating costs are considerably lower than for conventional
plus advanced waste treatment because of the relative sim-
plicity of operation. Further research and development of
this highly promising approach is required in the area of
phosphorus removal, loading rates, and applicability to
cold climates.
Overland flow has the advantages of avoiding groundwater
degradation, of providing economic return through the growth
and sale of hay, and providing a high quality effluent suit-
able for many additional reuse applications. As indicated
in Table 29, it cannot be used as a complete direct recycle
of wastewater to the land. However, the runoff will be of
high quality and can be directly recycled by any other land
application approach.
Infiltration-Percolation
Benefits from infiltration-percolation of municipal waste-
water include (1) an economic alternative to surface water
discharge, (2) a treatment system with nearly complete re-
covery of renovated water possible, and (3) a method of
repelling salt water intrusion into aquifers. The high
rate systems pioneered in the southwest have the further
benefit of requiring very little land area.
162
308
-------
The major limitations of the process are in connection with
groundwater effects. The fact that influent nitrogen is
converted to the nitrate form, which is leached to the
groundwater, is of major concern. If the groundwater zone
becomes anaerobic, conversion of sulfates to hydrogen sul-
fide may also be a problem.
Nitrates can be a problem (1) if the groundwater is reused
for potable supply, (2) if the groundwater is reused for
recreation lakes, and (3) if the groundwater is reused for
unrestricted irrigation.
These problems arc (in the order mentioned) related to
(1) causing methemoglobinemia in children, (2) eutrophica-
tion, and (3) ovcrstimulation of crops, such as grapes, in
which nitrate nitrogen concentrations above 30 mg/L are
reported to cause abundant growths of foliage at the ex-
pense of fruit production.
At Flushing Meadows, Arizona, research and operational
changes have been aimed at increasing the nitrogen removal
of. their high rate system. Further research needs to be
conducted on this subject.
Less critical limitations include the following: (1) phos-
phorus retention in the soil matrix may be neither complete
nor of long duration; (2) suitable soils must be highly
permeable yet must contain enough fine particles to ensure
adequate renovation; and (3) the groundwater aquifer re-
ceiving the water needs to be monitored and controlled
for high rate systems to prevent groundwater degradation.
INDUSTRIAL WASTEWATER
The potential use of land application for industrial waste-
waters is nearly as great as that for municipal wastewater.
In addition to the food processing, pulp and.paper, and
dairy industries which have utilized land application ex-
tensively, such diverse industries as tanneries [91] and
chemical plants [140] have used land application
successfully. In general, for plants located in rural or
scmirural areas that produce wastexvaters with mainly organic
contents, land application offers great potential. For
industries producing toxic or high inorganic content waste-
waters, land application probably offers small promise.-
There are so many modifications and combinations of land
application methods that could be used for any given indus-
trial wastewater, that no sweeping limitations can be
stated solely on the basis of a type of industry.
163 309
-------
In general, industries are more able than municipalities to
include new technology in their wastewater management plans ,
which partially explains their use of the overland flow
approach. Industries have allowed the soil matrix to pro-
vide a greater amount of treatment than have municipalities
and have tended to search out the limits of loading for
soil'systems. With this approach it is likely that new
improvements or modifications to the common methods will
continue to come from industries as well as from soil
scientists and researchers.
310
164
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RESPONSES TO COMMENTS BY
THE CITY OF WESTMINSTER
14 JULY 1977
1. Please see discussions in Volume 1, subsections III-3 and IV-3;
and responses to comments from the City of Northglenn.
2. Please see the material added to Volume 2, Section II (p. 62).
3. Please see discussions in Volume 1, subsections III-9 and IV-9
and comments from the city of Northglenn.
4. Please see discussions in Volume 1, subsections III-7 and IV-7.
5. Please see discussions in Volume 1, subsections III-6 and IV-6.
6. Please see Volume 1. EPA has chosen the local alternative
with certain conditions.
7. Corrected and updated information on user charges is presented in
Table II-O, p. 73.
8. Unable to find reference to Big Dry Basin on page III-3, Volume 1.
9. This has been updated in Section III, Volume 2 (p. 95). Also see
Table III-A information for Lower South Platte, Broomfield/West-
minster and Northglenn facilities plans (pp. 88 and 90).
10. Table IV-E has been updated (p. 121). Increased capacity appears
to be an equally important objective.
11. Figures for Westminster have been updated on Table IV-H, Section
IV, Volume 2 (p. 133).
12. Text has been modified in Section IV, Volume 2 (p. 140).
13. Text has been changed in Section IV, Volume 2 to reflect this
comment (p. 179).
311
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JAMES L. OGILVIE
Secietaiy-Manager
''Board of ^lOater
144 Weit ColJax Avenue Denver, Colorado S0202
222-5511
COMMISSIONERS
CHARLES F. BRANNAN. President JAMES B. KENNEY, JR., 1st Vice-President
WILLIAM G. TEMPLE JOHN A. YELENICK DON FRIEDMAN
July 18, 1977
Mr. John A. Green
Regional Administrator
United States Environmental Protection
Agency Region VIII
1860 Lincoln Street
Denver, Colorado 80203
Dear Mr. Green:
From our review of the Denver Regional Environmental Impact
Statement for Wastewater Facilities and the Clean Water
Program, we feel the obligation to transmit our comments.
The recent water situation and the increasing awareness of
water as a limited natural resource is beginning to influence
policy decisions in the current administration. Regional
and national offices of EPA are beginning to view successive
use of water in a new light. Successive use has already
been shown both possible and beneficial in the areas of
•agriculture and industry. We feel that the potentially
beneficial possibility of potable reuse should be evaluated
by construction and operation of such a facility on a re-
search basis. It is of national and international interest
to determine the actual benefits and/or problems of such
an operation. The result could be that potable reuse will
present a very timely alternative to local water use planning,
Reuse facilities would not only have positive affects on
water quality by removal of pollutants, but would reduce the
demand and subsequent degredation of the unpolluted waters
of the region.
The following is an excerpt of the draft Environmental Impact
Statement (pp.III-17). "EPA's chief concern is, of course,
protection and enhancement of water quality. If any of the
potential reuse or land application systems have positive
water quality benefits that would result in attainment of
relevant stream standards, such systems may be eligible for
construction grant funding."
We feel the above paragraph should be modified to specific-
ally afford construction grant funding for successive use
plants and to provide for demonstration of potable reuse.
312
-------
Mr. John A. Green
July 18, 1977
Page 2
Regarding the slide show which accompanies the public pre-
sentations of the Environmental Impact Statement, we feel
it is not correct to say that reuse will reduce stream flow
and increase occurance of zero flow conditions and associated
problems. The only waters which could be used in a reuse
situation are those owned by the user - waters which would
not have reached the stream historically. Regulation of this
historic flow is governed by Colorado's appropriation doctrine.
Please consider these comments when finalizing the draft
Environmental Impact Statement.
Thank you for your consideration in this matter.
Sincerely,
y /J. L. Ogilvie
Manager
JLO:pp
313
-------
RESPONSES TO COMMENTS BY
THE DENVER BOARD OF WATER COMMISSIONERS
18 JULY 1977
1. Please see discussions in Volume 1, subsections III-3, 6 and 7
and IV-3, 6 and 7.
2. Please see discussions in Volume 1, subsections III-6 and IV-6.
314
-------
Aboard ol
OGILVIE ft&^/tf*;? 144 Wert Colftt Avenue Denver, Colorado 80202 Pkone 222-5511
(•toy-Manager %^SS£&^
COMMISSIONERS
CHARLES F. BRANNAN, President JAMES B. KENNEY, JR., 1st Vice-President
WILLIAM G. TEMPLE JOHN A. YELENICK DON FRIEDMAN
August 15, 1977
Mr. John A. Green
Regional Administrator, United States
Environmental Protection Agency
Region VIII
1860 Lincoln Street
Denver, Colorado 80295
Re: Draft Denver Regional Environmental Impact Statement for Water Facilities
and the Clean Water Program (DEIS)
Dear Mr. Green:
The purpose of this letter is to supplement my earlier letter dated July 18, 1977
providing comments on the above captioned environmental impact statement. It is
our understanding that the Record in this matter is to remain open until the close
of business August 15, 1977.
Our earlier comments suggested that potable reuse of secondarily treated waste-
water might present a viable future program for local water use planning. Action is
needed now to put into early operation a prototype research project with which to
study all aspects of the health effects of such a program. Even with such an early
start, the lead time to provide the necessary health information upon which a decision
on the feasibility of using a large scale potable reuse plant can be made, is so long
that developing a large scale operational plant cannot reasonably be expected to occur
prior to the 1990's. For that reason, it is critical that action on such a research
program occur now so that decisions may be made for the future regarding potable
reuse of secondarily treated waste-water.
We note that the DEIS utilizes population projections prepared by DRCOG, We concur
in your recognition that: a) land use decisions involving population growth are properly
the prerogatives of local government; and b) DRCOG's population projections produced
as the result of lengthy and coordinated planning at the local level by its member
jurisdictions are the best available. For you to use projections other than theirs for
your purposes would be to frustrate their extensive effort and it is certain that no
other projections could be more accurate; we rely on them ourselves in our water
supply planning.
We note comments made by those who have no expertise in the water-utility field
which argue that the demand for water supply can be substantially reduced by requiring
universal metering and utilizing progressive rate structures. It was further argued
that these assertions, which are unverified by utility experience, should influence
your decision making.
The Denver Water Department has studied this subject matter over the last several
years and has been unable to discover hard operating facts which support claims that
are often made regarding the substantial conservation benefits to be derived from
315
-------
Mr. John Green
August 15, 1977
Page 2
progressive rates and metering. We continue to recognize the necessity for period:
reviews of the value of requiring universal metering in the older parts of our servic
area, however, the Department has yet to conclude that universal metering would
provide sufficient benefits when viewed together with the hardships and cost. Furthe
the Charter of the City and County of Denver prohibits progressive rate pricing. Wi
regard to other comments concerning the value of permanent retention of mandatory-
re strictions on water use, it is our view that such a program would entail too great
mandated change in life style with attendant loss of personal and economic freedom
to be acceptable to the customers we serve. In summary, there are no reliable fad
available which would require you to alter your basic assumptions concerning waste
water treatment plant sizings based on per capita flow generation.
It is hoped these additional comments benefit your review.
Sincerely,
. L. Ogilvie
Manager
JLO/
ee
316
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RESPONSES TO COMMENTS BY
THE DENVER BOARD OF WATER COMMISSIONERS
15 August 1977
1. Please see discussions in Volume 1, subsections III-3 and IV-3.
2. No response required.
3. Please see discussions in Volume 1, subsections III-7 and IV-7.
317
-------
DENVER REGIONAL COUNCIL OF GOVERNMENTS
1776 SOUTH JACKSON STREET . DENVER. COLORADO SO21O . 758-5166
July 21, 1977
Mr. John A. Green
Regional Administrator, Region VIII
U< S. Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
Dear Mr. Green:
The Denver Regional Council of Governments appreciates the opportunity to
comment on the Draft Regional Environmental Impact Statement for Wastewater
Facilities and the Clean Water Program prepared by the U.S. Environmental
Protection Agency. These comments have been reviewed and approved for
transmittal to EPA by the Program Committee of Council.
The DRCOG believes that making an areawide EIS is the appropriate way to
assess the impacts of multiple wastewater facilities, and that the process
will save time and money In the planning, design and construction of facil-
ities. The Inclusion of the 208 Clean Water Program In the EIS Is also
appropriate since all of the proposed wastewater facilities are encompassed
by the Clean Water Plan. We believe that. In general, the Draft EIS has
successfully related the proposed wastewater facilities to the 208 Plan, and
provided Information which supports acceptance of the 208 Plan and the con-
struction of all proposed wastewater facilities assessed in the Draft EIS.
The DRCOG supports the major point made by the Draft EIS that If the economic
advantages of growth are not to be curtailed or eliminated, then public concern
about the effects of growth should be directed toward Identifying and mitigating
potentially deleterious Impacts while guiding development toward the attainment
of regional land use patterns which are environmentally sound. This is a posi-
tive direction as opposed to an arbitrary "no growth" position which would halt
construction of wastewater treatment facilities in an attempt to stop population
318
COUNCIL OFFICERS
DON DC DECKER. CMwi JAMU J. NOLAN. Vlcf CItmlrmim WILLIAM THORNTON. SKmvt-Tnmmm ROBERT O. FARLCV. Clfcutfv* Dlmlar
EXECUTIVE COMMITTEE
WILLIAM M. MCNICHOLS. JR. ROBERT r. CLEMENT JOHN O. CAMPBELL DON DC DECKER
Donvr Mmrar Jrtmo* Comar fommittioittr Atlfna Conor Commialamtr Ltkfwfoi Cilf Cnnrttan
•CMn«M "Vlcr CkUrmm
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Mr. John A. Green
July 21, 1977
Page 2
growth which in turn would presumably solve the area's environmental prob-
lems. The "no growth" position is a specious argument, as we believe the
Draft EIS clearly shows. The Council hopes that EPA will recognize this
significant conclusion of the EIS and act accordingly in evaluating proposed
wastewater and other service facilities. Good planning must consider all
factors in community life, not just one or two in an attempt to achieve a
narrow or singular objective.
Enclosed are our specific comments on the Draft EIS. Please call on me if
we can be of any further assistance in review of the Draft EIS or you have
any questions concerning our review and comment on the EIS .
Sincerely ,
Robert D. Farley
Executive Director
raz
Enclosure
319
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COMMENTS ON THE
DRAFT REGIONAL ENVIRONMENTAL IMPACT STATEMENT FOR WASTEWATER
FACILITIES AND THE CLEAN WATER PROGRAM
BY THE
DENVER REGIONAL COUNCIL OF GOVERNMENTS
I. GENERAL COMMENTS
1. The Draft EIS reaches too far In assigning the cause of energy
shortages, agricultural land conversion, fog on thoroughfares,
suburban migration, mass transit problems, hillside development,
mining hazards, wind damage, park vandalism and a number of
other environmental Impacts to the construction of wastewater
facilities. The DRCOG does not believe that a logical cause-
effect relationship between these environmental Impacts and the
construction of wastewater facilities exists. Neither does the
DRCOG believe that air pollution problems are caused by waste-
water facilities.
2. The air pollution problem In the Denver region Is largely caused
by motor vehicles, and they should be the focus of efforts to reduce
air pollution as the EIS properly suggests. Federal vehicle emis-
sion standards with an effective vehicle Inspection and maintenance
program may be adequate mitigating measures as proposed by the
EIS.
3. It Is Inappropriate and outside Its legislative authority for the
Environmental Protection Agency (EPA) to attempt to dictate the form
of local government In the Denver region as a prerequisite for
federal funding of wastewater facilities.
II. MAJOR CONCERNS
1. Failure to Meet 1983 Water Quality Goals
Concern
The 1983 water quality goals will not be met by any of the three
proposed wastewater system alternatives. (Vl-2)
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Comment
The fa lure to meet 1983 goals Is attributable to urban runoff, about
which there Is little understanding here or In most of the nation.
What Is known Is that the costs of controlling runoff for water quality
reasons will be enormous, and that the federal government has no
program to fund such facilities. While some progress In controlling
runoff can be made without building structures, some facilities will
be needed.
Even though urban runoff problems will preclude meeting the 1983
goals, the DRCOG believes that point source wastewater facility
controls should be pursued with federal funding assistance. Very
substantial improvement in stream quality can be obtained with
point source controls and the 1983 goals would be met during much
of the year. This Is a worthy objective, though perfection may not
be attainable because of the non-point source Issue.
2. Institutional Requirements for Water Quality Management
Concern
"...there Is no assurance that the 208 Plan recommendations will
be carried out, given the complex Institutional setting of the Denver
region. Without such assurance, the long-term value of EPA Invest-
ments In treatment level and capacity of municipal wastewater treat-
ment plants In the region is open to question." (X-l)
Comment
The Implication Is that the Denver region cannot meet the 1983 goals
simply because It has a governmental structure which EPA believes
Is Incapable of achieving that goal. In fact, the Council believes
that the "complex Institutional setting" has added treatment capacity
and levels In recent years sufficient to virtually meet the 1977 interim
federal water quality requirements and local agencies are now actively
working, In coordination with the DRCOG, to achieve the 1983 goals.
The presumption that the form of government must be radically changed
In order to meet the 1983 goals Is unwarranted. It Is Inappropriate
and outside Its legislative authority for EPA to dictate the form of
local government In this region. The 1983 goals will be met through-
out the nation by a great diversity of local governmental arrangements.
The DRCOG has proposed, In the 208 Clean Water Plan, significant
changes In how local governments are to relate to one another to
achieve the 1983 goals on time while lowering costs, meeting standards
321
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and Improving the water related environment. These changes are
being made with recognition by DRCOG that better decision making
mechanisms are needed to further pursue the complex and expensive
water quality management programs needed In the next five to six
years.
3. Federal Funding of Wastewater Facilities
Concern
The EPA appears to be taking a position that If the 1983 water quality
goals cannot be met In this region, continued federal funding assis-
tance for wastewater facility construction would be Ineffective In
Improving water quality.
Comments
This position Is not conducive to water quality Improvement. It Is
certainly true that meeting and maintaining water quality goals every
day of the year may not happen by 1983 because of runoff problems.
However, that does not mean that efforts to achieve the goals should
be halted. The region has been progressing In an orderly fashion to
meet the goals, and If EPA continues to fund water quality Improve-
ment, the goals will be met during most periods of the year with
new faculties.
With federal funding, water quality will be significantly Improved,
and much earlier than without federal funding. A significant finan-
cial burden would be placed on local governments If federal funding
of wastewater faculties In the Denver region Is terminated and It
would take many years beyond 1983 for local governments to finance
the needed wastewater facilities on their own.
4. Local Funding of Wastewater Facilities
Concern
The "No-Action Alternative," I.e. no federal funding assistance for
wastewater facilities, may be reasonable because the construction
of the faculties wUl only be delayed about three years, with local
governments paying the difference. (IV-70)
Comments
This concern Is related to the concern with federal funding. The
"No-Action Alternative" Is not clearly "no-action" with regard to
wastewater faculties Improvements. The Alternative Is, In fact,
322
-3-
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no more than a no-funding decision by EPA, which Is Inconsistent
with the local and regional wastewater system alternatives. While
EPA assumes there will only be a short delay of two or three years
If funding for the construction of facilities Is denied, In reality,
an Indefinite delay should be expected since construction would be
entirely dependent upon limited local financial resources and a
willingness to spend up to four times as much In local funds as
would be required for the local and regional wastewater system
alternatives.
It seems clear that the federal water quality law was written with
the assumption that adequate funding would be authorized and
appropriated to meet the standards, goals and other requirements
of the act. The passage of PL 92-500 on that basis created strong
precedent and a moral obligation of the federal government to relate
standards to available funding. If the federal government now decides
not to fund wastewater facilities, for whatever reason, we believe
that the standards, goals and requirements of PL 92-500 should be
scaled down accordingly. With all of their other obligations and
responsibilities, many local governments will not be financially
able to meet the higher water quality standards on their own, and
certainly not by 1983.
5. "Wastewater Facility/Growth Relationship
Concern
The construction of wastewater facilities alone will encourage growth
with accompanying negative environmental impacts.
Comment
The Draft EIS does not attempt to define the environmental "carrying
capacity" for the Denver Metropolitan Area. The DRCOG adopted
year 2000 population forecast of 2.35 million, employment forecast,
and regional land use plan are used in the EIS for the evaluation of
environmental Impacts. The EIS states that as there are few Induce-
ments, whether fiscal, economic or legal, resisting pressures for
dispersal of economic activity throughout the Region, the DRCOG
forecasts of future economic activity and consequent population and
land use changes appear valid given all that Is known.
The EIS finds that no single municipal service stimulates or con-
strains regional growth, or can be considered the dominant factor
In growth-related environmental Impacts, but that the provision of
a single service can Influence development patterns and the rate of
development. Major Investment In public facilities supports growth
323
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by opening up land for development, and the lack of capacity In
any one geographic area may limit .growth of that area. From a
regional perspective, however, the lack of service capacity In
one area often just directs growth to another area. Growth will
go where facilities are available to serve It, without affecting
the overall growth of the region.
The DRCOG supports the major point made by the Draft EIS that If
the economic advantages of growth are not to be curtailed or elim-
inated, then public concern about the effects of growth should be
directed toward Identifying and mitigating potentially deleterious
Impacts while guiding development toward the attainment of regional
land use patterns which are environmentally sound.
6. Wastewater Faclllty/Alr Pollution Relationship
Concern
To what extent does population growth planned for In sewage treat-
ment plant and interceptor capacity relate to further growth In vehicle
travel In the metropolitan Denver area and resulting greater air
pollution?
Comment
The EPA undertook the EIS with a major objective of defining EPA
policy and decision options for assuring consistency between the
EPA's Air and Water Programs and the goals of the National Environ-
mental Protection Act. An apparent premise was that stopping the
funding, or directing the location, of wastewater facilities would
solve the air pollution problem, though It Is acknowledged to be
largely caused by the automobile. The Draft EIS does not support
this thesis, nor does It establish either a direct or Indirect relation-
ship between wastewater facilities and air pollution.
The relationship of growth and development patterns to air pollution
was examined, and the EIS finds that "the results of this analysis
Indicate that region-wide control of pollutant concentrations is not
achelved by a substantial redistribution of emissions.. .thus, It
would not appear to be fruitful to utilize restrictive local land use
controls, which might promote development elsewhere, In order to
relieve regional air pollution problems." This Is a very significant
finding with far reaching Implications for both air and water quality
management as the conclusion Is that forcing population and resultant
vehicle emissions, by whatever means, to a particular part of the
region will not solve the region-wide air pollution problem. DRCOG
hopes that EPA will accept this analysis and act accordingly In the
324
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evaluation of proposed wastewater facilities. The locations of
these facilities are, and will continue to be decided by local govern-
ments consistent with the 208 Clean Water Plan, as acknowledged
by the U.S. EPA.
7. Air Pollution
Concern
Partlculates will be a major air pollution problem In the future, though
ozone and carbon monoxide can be reduced to below standards with
only occasional "hot spots" or Incidents of exceeding standards,
through a vehicle Inspection and maintenance program. (VI-1)
Comment
The Draft EIS suggests that Improvements In automobile engines and
an Inspection and maintenance program can largely solve the air
pollution problem In the Denver region over a period of years. There-
fore, the DRCOG does not believe that more drastic air quality con-
trol measures are called for, and that, therefore, even If a cause-
effect relationship could be proved, the air pollution problem would
not be sufficient cause to stop 'federal funding of wastewater facilities
8. Wastewater Facility/Agricultural Land Use Relationship
Concern
"The region will continue to grow In both population and urbanized
areas at the expense of existing and potential agricultural areas."
(Vl-1)
Comment
The projected growth and development of the region Is presumed to
result In the loss of "prime agricultural land." How much of the
previous loss of land In agricultural production was prime farmland
Is not known nor can the future loss be projected with any certainty.
Difficulties In measuring this problem are admitted by EPA and have
not been resolved by the EIS. It Is believed by DRCOG that the
actual extent of Important farmlands, that Is, lands with an adequate
Irrigation water supply and prime agricultural soils, within the pro-
jected area of urbanization Is actually much less than that Indicated
by the EIS.
325
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The relationship between expanded wastewater facilities and the
loss of Important farmlands has not been demonstrated, and the
socio-economic Impacts which are projected In the EIS cannot,
therefore, be attributed to wastewater facility construction. The
EIS states that Irrigation water supply, not land, is the real issue,
but the extent of the probable loss In irrigation water supply Is not
quantified, nor Is Its relative Importance In meeting future muni-
cipal supply requirements demonstrated.
The EIS suggests that the conversion of prime agricultural lands In
Adams and Eastern Boulder Counties might be mitigated by not pro-
viding federal funds for expanding wastewater treatment facilities.
The DRCOG agrees with EPA that the effectiveness of such a measure
would be limited since growth Is supported by other urban services
besides wastewater treatment facilities, and the measure would
require carefully coordinated policy support by federal, state and
local governmental agencies, an unlikely event in the foreseeable
future.
dlv
07-13-77
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RESPONSES TO COMMENTS BY
THE DENVER REGIONAL COUNCIL OF GOVERNMENTS
21 JULY 1977
1. No response required.
2. Please see the Introduction to Section V, Volume 2 and response
3.
3. Please see discussions in Volume 1, subsections III-l and IV-1.
4. Please see discussions in Volume 1, subsections III-4 and IV-4.
5. Please see discussions in Volume 1, subsections III-5 and IV-5.
6. EPA generally agrees with this comment and proposes to fund
additional wastewater treatment facilities. General conditions
and policies are explained in Volume 1 and specifically sub-
sections III-3 and IV-3.
7. Please see discussions in Volume 1, subsections III-9 and IV-9.
327
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IB&wd, o tVatei and Setucn
~K01 West Sixteenth Avenue Lakewood, Colorado 802 1 5 Phone 233-6(>30
COMMISSIONERS
C W. Ri:iTLl:R. Chairman K. L. NORTHWAY. Vice Chairman I-:. W. liRAY, JK. Sixrciary
A M. nt'RSI-Y L\ I . HF.NDKJCKSON R. I. KRIU Cl K
II A LAM B. S. VOUKOVITCH K. J. KKONI HCKCII R
August 9, 1977
Mr. John A. Green
Regional Administrator
U. S. Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
Re: Denver Regional Environmental Impact Statement
for Wastewater Facilities and the Clean Water Program
Dear Mr. Green:
The following is submitted as our comments with respect to the
above environmental impact statement.
The difficulty with responding to this environmental impact state-
ment is the difficulty in knowing what the environmental statement
addresses. The actions under consideration in the environmental
impact statement are actions contemplated with respect to waste
water treatment systems under Sections 208 and 201 of the Federal
Water Pollution Control Act, Public Law 92-500. Despite this,
however, the EPA suggests that one of the purposes of the EIS is
to discuss the entire environment of the Denver region considering
the Housing and Urban Development [HUD] EIS on the FHA housing
program and the Bureau of Land Management [BLM] EIS on the Foothills
Water Treatment Plant. Neither of those proposed environmental
impact statements has yet been issued, and both will necessarily
be concerned with the overall question of population expansion and
urban growth and the attitude toward growth that either or both
of those environmental impact statements will require consideration
of availability of sewage treatment.
What makes this particular environmental impact statement confusing
is, as this study points out, some construction of sewage treatment
capacity is already necessary in order to meet the FWPCA requirements ,
and the construction of additional capacity will not cause growth.
Why then when two other agencies are preparing environmental impact
statements which may have an effect on growth is it necessary for
this EIS to so thoroughly discuss the question? How can it be
328
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2 - Mr. John A. Green - August 9, 1977
accurately said that the water treatment facilities produce
irreversible and irretrievable commitments of resources by
conversion of prime agricultural lands to urbanization by
commitment of inadequate supplies of natural gas upon which
residential, commercial and industrial sectors are dependent
and by increased commitment of available water to urban uses in
an area of a nation concerned by limited water resources? These
are not commitments of resources which result from the actions
being considered by the EIS, but rather are commitments of
resources resulting from growth. Since this EIS was issued prior
to the proposed HUD and BLM studies, it appears that its true and
improper intent and purpose is to enable its use in a regulatory
fashion to influence other studies which more directly relate to
growth. In this as well as in any other environmental impact
statement directed at units of local government, we are concerned
that the EIS might be used as a substitute for the judgment of
locally elected,publicly responsive officials.As a regulatory
document it may be used as a veto ,x whereby private special interest
groups, neither influential nor numerous enough to alter the decisions
of local officials, may be used to influence those officials who are
not responsive to the local political processes.
If growth is to be considered as a result of the actions being
considered within the EIS, the result which should be considered
is the effect of federal action which might restrain growth.
Surprising, however, no mention in the report is made of the local
effect of the failure to increase population or provide for urban
growth. Rather, the study suggests that growth will continue to
occur despite any action which might be taken under the EIS.
Bearing in mind that the purpose of an environmental impact state-
ment under the National Environmental Policy Act is to study the
impact of significant federal action on the quality of human
environment, and in that context this environmental impact statement
ignores some of the most important human environmental impacts
which are social, political and economic.
The most objectional feature of this environmental impact statement,
therefore, is that its study and conclusions far exceed its expressed
scope. As a final general comment, it is sad that the authors of the
329
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3 - Mr. John A. Green - August 9, 1977
statement have punctuated the comments with carefully chosen words
expressing their own attitude rather than through direct statements.
SPECIFIC COMMENTS.
The summary, page 11, editorially suggests that the City and County
of Denver has decayed and the rich have moved to the suburbs.
Examination of the extensive and expensive development in the
downtown Denver area does not justify this statement. Furthermore,
the post war growth of the suburban area occurred principally,
because affordable housing was not available within the city, and
while that housing may be newer, the majority of the affluent and
advantaged probably still remain inside the City and County of Denver.
Eastern Colorado is and has always been so arid that whatever prime
agricultural land exists exists solely because of the availability
of water. Probably most any farmland anywhere in Eastern Colorado
would be made prime agricultural land by the application of irriga-
tion of water. Consequently,prime agricultural land would not be
withdrawn as a result of growth, so long as water was made available
in another area.
Furthermore, whether the prime agricultural land ought to be main-
tained as such ignores fundamental principles of the Colorado
Constitution relating to water law as well as basic principles of
hydrology. Colorado has always recognized that water was a limited
resource and demand has virtually always exceeded its supply. That
recognition led to the customary law of Colorado and the priority
system which antedates even the state constitution, and this priority
system and the propriety of the water rights doctrine has been
acknowledged by the United States Supreme Court in a number of
cases.
In addition to the general priority system, the Colorado Constitution
has also recognized for more than 100 years which uses of water are
to be preferred. Those using water for domestic purposes shall have
the first preference. Those using water for agricultural purposes
shall have the second preference. Those using water for manufacturing
purposes shall have the third preference.
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4 - Mr. John A. Green - August 9, 1977
It has also been generally recognized that urban and agricultural
development of the eastern slope has increased the total amount
of water available and has made possible minimum stream flows in
what had formerly been intermittent streams. Water resources studies
have shown that precipitation runoffs in a plains area range from
1/4" to 1" per year; whereas, precipitation runoffs from the
mountainous areas of the western slope range from 10" to 20" per
year. By storing the winter runoff for level release into the
sewage system during the year, minimum stream flows have been
maintained. Further, the application of irrigation waters to
farmland with the subsequent migration of the water back to the
stream has had the effect of storage of even agricultural water
and increased the potential season for agricultural use.
It is also generally recognized that actual consumption of water
when used for domestic and municipal purposes is only in the order
of 10% to 15% of the water diverted, that is for each 7 gallons of
water diverted, only 1 gallon is used. In agricultural applica-
tions, 1 gallon of water is consumed for each 2 gallons diverted.
However, since recreational purposes, as well as minimum stream
flows, require that no diversion occur, the actual consumption of
water for those purposes requires that 1 gallon of use can only
be supported by 1 gallon of diversion.
It would appear from the relative consumptive uses that urban
development is preferable that urban development occur upstream
of agricultural development, because a smaller percentage of
agricultural water is returned to the stream.
With respect to park and recreation sites, most municipal authorities
have undertaken a program to provide park and recreation facilities
for a future rather than present population. Intensified use is,
therefore, already contemplated, and in fact if use were not to be
intensified, the maintenance expense and devotion of. water resources
to maintenance of those facilities would be an uneconomical burden
on the area.
In addition, since these park and recreation facilities are
principally for summertime use and are economically developable
for year round use, they are not especially efficient. The
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5 - Mr. John A. Green - August 9, 1977
extensive mountainous area of Colorado offers not only summertime
recreational opportunities as well as wintertime recreational
opportunities, but much of that land is not so conveniently
developable and is consequently much more efficient for recreation,
There is certainly no shortage of outdoor recreational areas, nor
considering the municipal programs already underway does it appear
that intensified use as a result of growth would adversely affect
available facilities to a degree not contemplated by local
authorities .
The suggestion that Colorado water right laws should be amended
ignores not only that they are a fundamental part of the organic
laws, but also ignores the property rights aspects, subject to
other federal and state constitutional limitations with respect
to depriving the people who depend on these municipal sources
of significant substantial property rights without compensation
or due process of law.
An adequate environmental impact statemen t f or this subject would
be substantially more limited than the draft and would more
seriously be concerned with the adverse environmental effects of
negative actions which might be taken within the scope of the
report .
Sincerely ,
. - / ) •-• / /
_ '/' I C<- <-.C-
C. W. Reitler, Chairman
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RESPONSES TO COMMENTS BY
THE LAKEWOOD BOARD OF WATER AND SEWER COMMISSIONERS
9 AUGUST 1977
1. Please see the Introduction to Section V, Volume 2.
2. It has been noted under "Population" in Section II, Volume 2,
that some cursory indicators point to a slowing of the "white
flight" to suburbia, with white families moving back to the
city center (p. 69).
3. Please see discussions in Volume 1, subsections III-9 and IV-9.
4. Please see discussions in Volume 1, subsections III-9 and IV-9,
and III-6 and IV-6.
5. No comment required.
6. Please see discussions in Volume 1, subsections III-6 and IV-6.
7. Please see discussions in Volume 1, subsections III-6 and IV-6,
and III-7 and IV-7.
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Statement Concerning the
Denver Regional Environmental Impact Statement
for Kastewater Facilities arid the Clean Water Program
by William E. Korbitz, Manager
Metropolitan Denver Sewage Disposal District No. 1
July 18, 1977
Several general comments would appear to be in order before comments on spec-
ific portions of the Environmental Impact Statement and Summary are offered.
Four areas of general comments are as follows:
1. According to the Environmental Impact Statement findings,- an
air pollution problem will be present in the metropolitan Denver
area in the future and will intensify or be alleviated without
any impact by or to the wastewater facilities covered by this
Environmental Impact Statement;
2. A number of areas of contradiction exist in and between the
Environmental Impact Statement and the Summary, especially
concerning the degree of treatment of urban wastewaters and
the quality of the South Platve River and other streams in the
metropolitan Denver area;
3. It is gratifying to see in the Environmental Impact Statement
a realization that even with tremendously high levels of treat-
ment of the Metropolitan Denver Sewage Disposal District waste-
waters and other urban wastewaters in the metropolitan Denver
area, the 1583 goals of fishable and swimmable waters will not
be achieved. It should follow that reasonable treatment levels
will thus be required of the metropolitan Denver area Wctstewa-.-.er
agencies;
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4. It is also gratifying to see a realization in the Environmental (4*)
Impact Statement that non-point sources of pollution rather
than point sources of pollution are the real problem in attempting
to achieve the 1983 goals of fishable and swimmable waters, and
also that the cost of both point source and non-point source
treatment would be much out of proportion to the minor
improvements in water quality which could be expected from such
treatment.
The first of the comments about specific parts of the Environmental Impact/^
Statement and the Summary deal with the excessive detailed discussions
concerning air quality and pollutants in the metropolitan Denver area now
and in the future. The findings of the environmental assessment work
together with logic indicate that there is no relationship between air
quality and wastewater treatment facilities. The many pages dealing with
air quality and air quality improvement would thus be better placed in an
environmental impact statement or study concerning air quality improvement,
It should be obvious that land use control rather than refusal to approve
construction of wastewatar treatment facilities should be utilized to mini-
mize land development in the metropolitan Denver area.
On page 11-43 of the Environmental Impact Statement is a statement "However,
even if the Metropolitan Denver Sewage Disposal District No. 1 plant dis- (bj
charged pure water, recommended levels of water quality in the South Platte
would still be routinely exceeded". Such a finding should be followed by
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regulatory agencies and the EFA Construction Grants Office in establishing
realistic levels of treatment for the Metropolitan Denver Sewage Disposal
District No. 1 as well as other wastewater treatment agencies in the met-
ropolitan Denver area.
The energy shortfalls mentioned on page 17 of the Summary and in other
places, should .encourage increased efforts for development of the proposed
Metropolitan Denver Sewage Disposal District No. 1 sludge drying basin pro-
ject to conserve fertilizer and the resources required to produce fertilizer
On page 14 of the Summary in the last paragraph is an error in the state-(T)
ment that "About 6.5 million gallons a year, of the Metro discharge is
diverted to the Burlington Ditch". The quantity should be 6.5 billion
gallons per year rather than 6.5 million gallons per year.
On page 11-62 in the first full paragraph, is a statement concerning income
to the Metro Denver Sewage Disposal District being based on charges to ®
"other District". This statement should be revised to indicate that the
income is based on charges to cities and sanitary districts which are
members cf the Metro District.
A statement on page 11-67 of the Environmental Impact Statement would lead
the reader to believe that the loss of agricultural land or v/ater supply Q?)
to urban uses may result in a decline in agricultural output. This is in
the first paragraph on the cited page. The urban use of water is less
336
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than five percent of the state water, and the urban use of land likewise
is extremely small compared to agricultural use. There certainly is serious
doubt that the urban use of land or water in the foreseeable future would
have any significant effect whatever on agriculture. It should be obvious
that major water conservation in the urban area would have virtually no
impact on the amount of water available in the state of Colorado. On the
other hand, even a 10 or 20 percent decrease in agricultural water waste
would amount in total quantity to much more than the total amount of water
presently used in urban areas of the state.
On page III-2 of the Environmental Impact Statement are the statements "The
^
11
208 Plan has estimated that non-point source control, which would result
in the achievement of tha 1983 goals, would cost the area approximately
$255,000,000 per year amortized over the 20 year planning period. The
conclusion of the 208 study is that this cost is excessive for the "minor"
improvement in water quality that would be expected." This should make it
clear that the 1933 goals and stream classifications must be made to be
realistic, namely for agricultural use and not for fishing or swimming.
On page III-ll in the section on expansion of the Metropolitan Denver
Sewage Disposal District No. 1 Central Treatment Plant is a statement that
"ammonia removal facilities will have to be added to this plant by 1983
in order to meet effluent standards at that time". This is not consistent
with statements on page 11-43 and page III-2 of the Environmental Impact
Statement which indicate that even with pure water from the Metropolitan
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Denver Sewage Disposal District No. 1 Central Treatment Plant and adequate
non-point source treatment the stream quality of the South Platte River
would still not meet 1983 goals. Standards of treatment and stream clas-
sifications must be changed to reflect realistic qualities in the South
Platte River and other streams. In addition, Table 111-13 on page 111-12,
shows a recommended ammonia level for the Metropolitan Denver Sewage Dis-
posal District No. 1 Central Treatment Plant of 18 milligrams per liter
which indicates no ammonia removal. The same table indicates a recommended
20 milligrams per liter of BOD which according to realistic South Platte
River stream quality would also not be a necessary level of treatment.
On page 15 of the Summary in the first paragraph the final two sentences
would mislead the reader concerning the use of wastewater treatment plant
discharges for agricultural irrigation. Such wastewater treatment plant
discharges have been used for many years for irrigation purposes in the
form of water taken from rivers such as the South Platte River which during
irrigation season are largely composed of wastewater treatment plant dis-
charges. The terms "unrestricted use" and "under certain circumstances"
probably eliminate any realistic meaning from these sentences, thus perhaps
the sentences should be omitted.
Page 22 of the Summary includes a section on establishment of a formal M2)
environmental review procedure. It is suggested that such a procedure
would merely add more delay and red tape which would interfere with planning
construction and operation of wastewater facilities unless the requirements
of the National Environmental Policy Act of 1969 would be eliminated. The
338
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one overabundant factor in wastevater facilities planning, construction
and operation today is red tape with resulting delays. We do not need more,
The section on acceleration of development of parks and recreation sites
at the bottom of page 23 of the Summary probably should include concern
about the large quantity of water which would normally be required for
maintenance of recreational and park sites, especially with water
shortage problems facing the people of the metropolitan Denver area.
The first paragraph on page 24 of the Summary improperly would lead the
reader to believe that growth in the north and northeastern portions of
the Denver region would be drastically affected by eliminating grant
funds for expansions of wastewater treatment facilities in these areas.
Land USG regulation certainly would be a more effective measure to
discourage growth in these areas if such growth discouragement would be
proper.
The section on mitigation of water quality impacts on page 24 of the (f
Summary should lead to the obvious conclusion that the 1983 goals as well
as other standards and stream classifications should be realistically
revised together with discharge permit requirements.
In the first full paragraph on page 25 of the Summary, mention is made
again of the conclusion that an effective non-point source control program
would be necessary to meet year round water quality goals. It is suggested
that extensive study be undertaken to determine actual sources of certain
339
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pollutants in the South Platte River rather than assuming that certain
pollutants come primarily from Metro Denver Sewage Disposal District No. 1
treatment facilities.
The information contained in the last paragraph on page 25 of the
should indicate the need for establishing realistic stream classifications,
water quality standards and discharge permit conditions inasmuch as non-
point sources of pollutants would apparently be reduced by only 30 percent
by non-structural methods as compared to 60 to 75 percent reductions being
required. With structural methods being too costly, and non- structural
methods ineffective, the conclusions are obvious.
The regional monitoring system mentioned on page 27 of the Summary
be instituted, and could be based on the monitoring system already estab
lished by the Metropolitan Denver Sewage Disposal District No. 1.
The air pollution emission sections on pages 28, 29, 30 and 31 of the
mary and in several sections of the Environmental Impact Statement perhaps
are not properly included in a water quality environmental impact statement,
but rather in a study or environmental impact statement concerning air pol-
lution only.
As a part of the section on mitigation of agricultural impacts on pages 31
and 32 of the Summary, it is suggested that a need exists for improved \2s
controls over agricultural discharges to waterways.
In connection with the energy conservation and energy use sections on pages
33 and 34 of the Summary, it is again suggested that EPA do everything
340
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possible to expedite the Metropolitan Denver Sewage Disposal District
No. 1 sludge drying basin project and to encourage the use of sludge for
fertilizer and to encourage the use of methane gas from anaerobic diges-
tion of sludge.
The stated major unavoidable adverse impacts included on page 35 of the
Summary include several which are misleading or not properly included
within the wastewater treatment and clean water environmental impact
statement. The adverse impact No. 4 as stated would lead people to be-
lieve that strict effluent quality standards would avoid public health
or soil damage impacts which could occur as a consequence of agricultural
irrigation with wastewater treatment plant effluent. No such impacts have
been realized during the many decades during which such treatment plant
effluent has been used for agicultural irrigation in Colorado.
The adverse impacts No.'s 5 and 6 on page 35 of the Summary deal with ai
pollution which is in no way related to the regional wastewater treatment
facilities and clean water environmental impact statement, and should be
omitted from this document.
The adverse impact No. 1 on. page 35 of the Summary should be stressed in
such a way as to bring about revision of the 1983 clean water goals, stream
classifications, effluent standards and discharge permit conditions.
On page 37 of the Summary the first paragraph indicates a complete mis- (12,
trust of local government, an attitude which is completely inaccurate,
341
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improper and unfounded. There is no reason for the feeling that because
many local agencies are involved in implementing a Regional Wastewater
Management Plan there would be any less likelihood of its success than if
a single agency on the federal, state or local level would be handling the
management responsibilities.
On pages 37 and 38 of tha Summary are additional statements concerning air
quality issues which must be resolved. It is again suggested that no sig-
nificant relationship exists between the specific air quality discussions
and the wastewater treatment and clean water program environmental impac
statement. A single statement putting the air quality and water quality
matters in proper perspective would suffice in these documents.
It is suggested that on the basis of the Environmental Impact Statement
and Draft Summary of the Environmental Impact Statement for wastewater
facilities and the clean water program in the Denver region, the findings
that are set forth in these documents be used to amend the 1983 clean
water goals, amend the stream classification and effluent standards of
the state of Colorado and also the discharge permits of agencies dis-
charging wastewater treatment plant effluent into the waterways of the
state. It is encouraging to find that this EPA environmental impact
statement recognizes the need to set reasonable levels of treatment of
urban wastewaters as well as the realization that there is a definite
need to control the quality of rural and urban non-point sources of pol-
lution before the costs of additional point source treatment are
forced upon the people of the urban areas.
WEK/j 342
7/15/77
-------
RESPONSES TO COMMENTS BY
THE METROPOLITAN DENVER SEWAGE DISPOSAL DISTRICT NUMBER 1
18 JULY 1977
1. Please see discussions in Volume 1, subsections III-l and IV-1.
2. Please see discussions in Volume 1, subsections III-2 and IV-2,
and III-3 and IV-3.
3. Please see discussions in Volume 1, subsections III-5 and IV-5,
and III-3 and IV-3.
4. Please see discussions in Volume 1, subsections III-5 and IV-5.
5. Please see the Introduction to Section 5, Volume 2.
6. Please see discussions in Volume 1, subsections III-2 and IV-2.
7. Please see discussions in Volume 1, subsections III-8 and IV-8.
8. This point is acknowledged. No changes have been made to the
draft summary, however, because there will be no separate sum-
mary volume for the final EIS.
9. Corrected and updated information on user charges is presented
in Table II-O, p. 73.
10. Please see discussions in Volume 1, subsections III-7 and IV-7,
and III-9 and IV-9.
11. Please see discussions in Volume 1, subsections III-2 and IV-2,
and III-5 and IV-5, and revise Section III of Volume 2.
12. Please see discussions in Volume 1, subsections III-4 and IV-4.
13. Please see discussions in Volume 1, subsections III-9 and IV-9.
14. Please see the Land Waste Treatment discussions under Direct
Environmental Impacts in Section IV, Volume 2 (pp. 193-198).
-------
REGION XII
NORTH WEST COLORADO COUNCIL OF GOVERNMENTS
Holiday Center Building - Suite 200
P. O. BOX 73f
FRISCO, COLORADO 80443
.-'(303)
GLE COUNTY
\RALT
\GLE
fPSUM
NTURN
'.DCLIFF
ML
AND COUNTY
'ASER
IANBY
•1AND LAKE
nr SULPHUR SPRINGS
<)EMMLING
'tKSON COUNTY
ALDEN
fKIN COUNTY
''EN
iJTT COUNTY
'•K CREEK
t AMBOAT SPRINGS
-------
August 3, 1977
Page 2
appear to be in the making through acceptance of plans
which do not meet aquatic life standards and fail to link
the actions of land use management agencies to wastewater
management agencies in any constructive sense. We thus
feel that a "dual standard" has been developing at the
State and Federal level and is manisfested in many of the
actions of EPA and the State. We do not believe that a
dual standard for east slope and west slope, either written
or implied, can be effectively administered on an equitable
basis under current institutional arrangements available
within Colorado.
Water Quantity Relationships
The issues of water conservation, agricultural re-use of
wastewater, domestic water re-use, population projections
and conversion of agricultural land in the Denver Region all
have implications outside of Denver, and specifically within
Region 12 and the Colorado River Basin Each of these issues
relate directly to how much water will actually be diverted
from Region 12 to supply the Denver Metropolitan Area with
municipal water.
Water is presently diverted from the Eagle River Sub-
Basin, Blue River Sub-Basin, Williams Fork Sub-Basin, Fraser
Sub-Basin, and the upper Colorado River Basin to supply muni-
cipalities within the Denver Region. According to figures
developed by the Bureau of Reclamation, an increase of 1 mg/1
in TDS at the international border on the Colorado River can
be equated to at least $230,000 in annual damages to users
within the Colorado River Basin. On an average basis, salinity
in the Colorado River will increase 1 mg/1 for every 22,500
acre-feet of water diverted from the basin. This can also
be translated to an annual cost of $10.22/A-F diverted or a
present worth of $205 per A-F diverted.
According to the 208 Clean Water Plan, water supply systems
in the Denver Region must be increased from their current
capacities of 250,000 A-F/yr. to 479,000 A-F/yr. There are only
two basic options for achieving this expansion of supply to
customers:
1. Develop new supplies.
2. Re-use and conserve existing supplies.
Developing new supplies is practically limited to developing
transbasin diversion facilities and conversion of agricultural
water. Re-use and conservation options include metering, pricing
strategies, urban irrigation re-use, agricultural re-use, and
exchange and potable water re-use
345
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August 3, 1977
Page 3
The most expensive of these options is potable water re-use at
approximately $3,500/A-F of water produced at the end of the
study period. Figure 7-8 of the Denver 208 Plan seems to in-
dicate that it is presently far more cost effective to develop
new water supplies than it is to re-use water. However, it is
later stated, page 7-27, that the cost of producing transbasin
water is estimated as high as $2,700/A-F. These costs do not
include external costs to users in the Colorado River Basin
such as the costs of increased salinity ($205/A-F diverted)
and other environmental costs which are far more difficult to
quantify but just as real in effect including:
1. Higher wastewater treatment costs in Region 12 due to
protection of water supplies service charges for waste-
water treatment in Region 12 range as high as $40/
month compared with Denver's charge of $4/month.
2. Increased treatment costs due to failure to maintain
historic minimum stream flows.
3. Loss of aquatic habitats due to diversions.
4. Loss of recreational uses due to diversions.
5. Failure to meet water quality goals in the Colorado Basin.
We can thus conclude that re-use and conservation options
are much closer to being cost competitive when the full range of
costs to the enviroiment is considered.
We believe these issues are statewide in importance and must
be dealt with responsibly in a statewide basis. The implications
of not dealing with the quality aspects of water resource develop-
ment vs. water conservation and re-use are obvious:
1. Developing new raw water supplies will continue to appear
more economical to east slope comnunities than re-use and
conservation because the true costs of transbasin diver-
sions have been externalized (i.e. costs are born by
Colorado River water users and residents).
2. Failure to require conservation and re-use options will
result in depleted streamflows in the Colorado River Basin.
3. Failure to meet historic minimum streamflows upon which
the State bases its discharge permits will not allow
Region's 12 streams to maintain the water quality goals.
4. A program to compensate for the lack of minimum stream-
flows will require still more advanced wastewater treatment
plants and even more strict controls for non-point sources
than currently envisioned.
346
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August 3, 1977
Page 4
5. The end result is that current Inequities in the costs
of providing for clean water in the Colorado River
Basin vs. the South Platte Basin will be even more
exaggerated, while even the best efforts of local govern-
ments to attain water quality goals will fall short of
the mark in Region 12.
Precedents Established
The second factor which links Region 12 to actions taken in
the Denver Region is in setting precedents for the level of
performance required by water quality and environmental manage-
ment programs. It appears that the state and EPA are evaluating
each facility and 208 Plan based on economic considerations for
that area alone, without considering the question of equity through-
out the State. It is unlikely that local governments within
Region 12 will continue to comnit a large proportion of their re-
sources to maintaining clean water unless they see a similar level
of comnitment throughtout the State. Denver would be the most
visible example of the failure to meet the 1983 goals because of
its population concentration and location of State government
offices. The most frequently asked question in Region 12 is not
whether our streams can or should be protected, but rather "what
is Denver doing to solve its problems?" This is a basic form of
"finger pointing" but has historically been a key reason cited
for the failure to meet water quality goals, nationwide. The
Federal Water Pollution Control Act Amendments were intended to
overcome this mentality by establishing a national goal of
fishable swimmable streams in addition to a minimum level of
treatment for all pollution sources.
In reading the Denver Overview EIS, there are more apparant
similarities in the environmental management problems than one
might expect in tro such diverse areas as Region 12 and the Denver
Region. The major similarity is evidenced by the fact that non-
point sources overshadow point sources as a cause of water quality
degradation. A second similarity is that there are relatively
major efforts currently under way through the EPA construction
grant program to solve the point source problem, while the non-
point source control problem remains relatively unregulated with
only a small percentage of State and Federal pollution control
funds committed towards the solution of the problem. A third
similarity is that the expansion of wastewater treatment facilities
accomodates growth, thereby increasing the relative magnitude and
distribution of non-point source control problems.
Yet, with all these similarities, we have seen remarkably
different approaches at the State and Federal levels towards the
solutions to these problems. In Region 12, EPA has determined
that where the above situation exists, Federal participation
in the construction grant program must be suspended until the
347
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August 3, 1977
Page 5
appropriate local land use agencies (not sanitation districts
applying for the federal assistance) establish strict land use
regulations which will control non-point source runoff. In the
Denver Region, no such actions have been taken and the con-
struction grant program continues to refine the degree of
treatment provided by municipal wastewater facilities while
failing to link non-point source control requirements to the
grant program. Which approach is correct is certainly a matter
txfi debate. However, it is certainly safe to imply that in-
consistent treatment of similar situations has been the case
to date.
The D.R.C.O.G. 208 Clean Water Plan provides some of the
answers to existing non-point source pollution. However, the
plan does little to avoid the spread of non-point source
pollution in the future despite a projected 45% increase in the
amount of developed residential land in the next 20 year period.
Controls for new development are very general in nature and do
not appear to be designed for implementation through local land
use regulatory programs. Within Region 12, we have made sub-
stantial negotiations on the behalf of local governments with
the State and EPA, maintaining that development of non-point source
land use controls for new development through the 208 Program
is sufficient to allow the construction grant program to proceed
unencumbered. This was not considered by EPA as sufficient
assurance that land use controls for non-point sources would be
implemented and special conditions have been added to Step II
Grants to require these actions from local governments. Again,
we feel that a "dual standard" of performance is emerging from
the State and EPA with regard to control of non-point sources in
two areas which appear to have similar problems.
Examples of this type also emerge in the handling of air
quality related to development and wastewater facilities. Where
air quality standards are expected to be violated in Region 12
due to secondary growth impacts of wastewater treatment facilities,
a position very similar to the one on non-point sources has been
taken. We know of no such actions regarding air quality relation-
ships in the Denver Region.
The adoption of the D.R.C.O.G. Clean Water Plan as proposed
and expansion of wastewater treatment facilities without such
special conditions as required in Region 12 raises severe
questions concerning the level of equity which can be expected between
rural and urban regions of the State and Nation.
Summary and Recommendations
The Northwest Colorado Council of Governments finds that
there are definite physical and social ties between water quality
management in the Denver Region and management of water resources
and water quality in Region 12. We also find that policies which
348
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August 3, 1977
Page 6
appear to be emerging at the State and Federal levels require
inequitable levels of performance from urban and rural areas
of the state.
In order to minimize the effects of Water Quality Manage-
ment Programs in the Denver Region on users of Colorado River
water and to minimize the degree of inequity, we recommend the
following actions to be taken by the State and EPA:
1. A broader view should be established at the State and
Federal levels regarding water conservation, re-use.
land application, and other options for reducing imported
raw water supplies as they apply to wastewater treat-
ment and water quality management. Cost effectiveness
guidelines allow decisions to be made on these options
without including the full cost of the entire water
system (i.e. costs of transbasin diversions to Colorado
River water users).
2. Because of the direct relationship of water development
and re-use options in the Denver Area to the water
quality in Region 12, the State and EPA establish
regulatory or other control mechanisms which:
a. Provides information on the costs of alternative
treatment methods on a total system basis, in-
cluding wastewater treatment, water supply systems,
and costs to the environment (including water
quality impacts and costs on Colorado River).
b. Encourages the options of water conservation,
potable water re-use, and agricultural water re-use.
Incentives could include priority bonus points,
and federal participation in grant programs.
c. Internalizes the costs of existing and proposed
transbasin diversions which are now born by users
of Colorado River water as opposed to the entity
which causes the problem.
d. Provides disincentives for those entities which do
not exercise water conservation or re-use options
where the total costs (both economic and environ-
mental) of traditional systems exceed those of con-
servation and re-use on a total system basis. Dis-
incentives could include federal grant participation
denial, denial of site application requests, etc.
3. Establish guidelines for levels of performance of water
quality management programs which incorporate concepts of
equity. Options for accomplishing this are:
349
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August 3, 1977
Page 7
a. Establishing a minimm stream standard which must
be met statewide wherever attainable. (Attain-
ability established as a concept where technical
considerations and not economic ones preclude
attaining the goals).
b. Establishing stream standards which vary throughout
the state because of economic constraints but
allowing for costs to areas with more stringent
standards to be re-distributed.
c. Establishing procedures which will insure that
the same degree of non-point source controls will
be required by EPA and the State where circum-
stances are similar.
Thank you for the opportunity to present our perspective on
this matter.
Sincerely,
Phil Overeynder
208 Coordinator
Lee R. Vfoolsey
Executive Director
cc: Gary Broetzman
208 Policy Advisory Group
Colorado 208 Directors
Colorado Dept. Natural Resources
350
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RESPONSES TO COMMENTS RECEIVED BY
THE NORTHWEST COLORADO COUNCIL OF GOVERNMENTS,
3 AUGUST 1977
1. Please see discussions in Volume 1, subsections III-7 and IV-7.
2. Please see discussions in Volume 1, subsections III-2 and IV-2.
3. Please see discussions in Volume 1, subsections III-3 and IV-3.
4. Please see discussions in Volume 1, subsections III-9 and IV-9.
5. Please see discussions in Volume 1, subsections III-4 and IV-4.
6. No response required.
7. Please see discussions in Volume 1, subsections III-8 and IV-8.
8. Please see discussions in Volume 1, subsections III-2 and IV-2
and III-5 and IV-5.
351
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Regional Transportation District
in i IT 9 1 i o 7 7 1 325 South Colorado Boulevard
JUiy Zi, Vill Denver, Colorado 80222
303/759 1000
Mr. John A. Green
Regional Administrator, Region VIII
United States Environmental
Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
Dear Mr. Green:
The Draft Environmental Impact Statement for the Denver Regional
Wastewater Facilities and Clean Water Program has been reviewed
by the RTD staff with the following comments.
The statement addresses many relevant regional issues which generally
have not been identified in other statements on subregional projects
for discussion of the impacts of regional growth, regional develop-
ment patterns and the conversion of agricultural lands, and the possi-
ble mitigation measures for these impacts is an important facet of
the draft statement. The document serves to bring the growth and
development issues into focus and at least begins to identify some
potential methods for dealing with it.
On the negative side, the section on mitigation of air quality impacts
mentions public transportation only indirectly in reference to bus
and carpool lanes. The potential of an effective regional public
transit system to assist in the reduction of VMT is totally ignored.
Even under the most conservative estimates of future ridership on a
region-wide transit system a general but not large improvement in
air quality has been projected. Given the current energy situation
and its implications with regard to limiting automobile use, a more
significant impact on air quality (VMT) might reasonably be expected.
A more complete discussion of these public transportation related issues
should be included in your draft statement.
RTD will be happy to provide any necessary documentation to support thir
type of discussion. We will be glad to meet with you or your staff to
discuss the issues identified.
Sincerely,
Ralph* E. Jagtson
Director of Planning
REJ/hj
352
cc: Kenneth Slyziuk
Sibyl Guereca
An Equal Opportunity/Affirmative Action Employer
-------
RESPONSE TO COMMENTS BY
THE REGIONAL TRANSPORTATION DISTRICT
21 JULY 1977
1. Please see discussions in Volume 1, subsections III-l and IV-1.
353
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COLORADO OPEN SPACE COUNCIL 1325 DELAWARE ST. DENVER, COLO. 8O2O4 3O3/573-924:
August 8, 1977
Mr. John A. Green
Environmental Protection Agency
I860 Lincoln St.
Denver, Colorado 80295
Dear Mr. Green,
The Denver Regional Draft Environmental Impact
Statement for H'astewater Facilities and the Clean
Water Program has been reviewed by the Land Use
Workshop of the Colorado Open Space Council. We find
your effort to be one of the more comprehensive and
thorough analysis' of growth impacts for the area we
have read. We have always believed that an informed
citi-enry is essential for maintaining our environment.
This statement clearly illustrates how educational and
beneficial the EIS process can be when it is properly
addressed and researched. We sincerely commend you
and your staff.
The statement reiterates and confirms many of the
concerns our group has voiced over the years; mainly
that growth carries with its economic benefits a large
package of negative, cumulative results upon the quality
of our regional life. That our choices in the future are
never going to be simple or inexpensive is made quite clear.
We find two areas in the document we would like to
comment on. Throughout the statement, the loss of agricul-
tural land is sited as one of the large impacts within the
region of projected growth. You quote a policy statement
354
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COLORADO OPEN SPACE COUNCIL 1325 DELAWARE ST. DENVER,COLO. 80204 303/573-9241
of TRCOG to the effect that prime farmland should not
be converted to urban uses and urge that those areas to the
north and northeast discourage urban growth. The question
of how this can be achieved i not addressed as throughly
as we would like. Land transfer taxes may be helpful, but
it is our belief that such an action does not get to the
heart of the matter which must consider the economic status
of the farmer, We don't have a magic answer but certainly
many more mechanisms exist than the land transfer tax
for slowing down this trend. Purchasing development rights
such as was done on Long Island, New York; creating
agricultural districts as has been tried in Mesa County,
Colorado or instituting a land gains tax similar to that
in Vermont are all part of the attempt to handle this
problem.
Secondly, we would urge that when and if funding is (Y)
granted by the SPA for the proposed projects that such
grants be contingent upon the resolution of some of the
issues raised in the course of this statement. Certainly
the site of the wastewater treatment plants should be an
area of considerable discussion. It also seems appropriate
to suggest that as part of the funding process some committment
be extracted by EPA from the grant recipients to, at the
very least, encourage individuals to lessen their dependence
upon the automobile and to support the RTD. This could be
achieved through funding some media progrmas, advertising,
etc. As the automobile plays a major role in non-point
pollution as well as air pollution, it should be targeted
for some continuous, selective educational campaigns about
the cause and effect relationships you have described.
355
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COLORADO OPEN SPACE COUNCIL 1325 DELAWARE ST. DENVER,COLO. 8O2O4 303/573-9241
Again we commend the SPA for their diligent and
detailed statement. It was well worth the hours spent
reading. We look forward to perusing the final draft and
offer any assistance we can give.
Pur nee Me Court, Ghrm.
Land Use Workshop
356
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RESPONSES TO COMMENTS BY
THE COLORADO OPEN SPACE COUNCIL
8 AUGUST 1977
1. Please see discussions in Volume 1, subsections III-9 and IV-9.
2. A number of policies and conditions proposed by EPA are discussed
in Volume 1 of this final EIS. For discussions pertinent to air
quality, please see discussions in Volume 1, subsections III-l and
IV-1.
357
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COMMENTS ON THE
DRAFT REGIONAL ENVIRONMENTAL IMPACT STATEMENT FOR
WASTEWATER FACILITIES AND THE CLEAN WATER PROGRAM
BY THE DENVER CHAMBER OF COMMERCE TO THE
ENVIRONMENTAL PROTECTION AGENCY
AUGUST 15, 1977
358
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COMMENTS ON THE
DRAFT REGIONAL ENVIRONMENTAL IMPACT STATEMENT FOR
WASTEWATER FACILITIES AND THE CLEAN WATER PROGRAM
BY THE DENVER CHAMBER OF COMMERCE TO THE
ENVIRONMENTAL PROTECTION AGENCY
AUGUST 15, 1977
WE AT THE DENVER CHAMBER OF COMMERCE HAVE PARTICIPATED WITH
INTEREST IN THE DEVELOPMENT OF THE CLEAN WATER PROGRAM OF THE
DENVER REGIONAL COUNCIL OF GOVERNMENTS. WE HAVE REVIEWED THE
E.P.A. DRAFT ENVIRONMENTAL IMPACT STATEMENT ON WASTEWATER
FACILITIES AND THE CLEAN WATER PLAN, AND APPRECIATE THIS OPPOR-
TUNITY TO OFFER OUR COMMENTS .
WE FIND IT ENTIRELY REASONABLE FOR THE E.P.A. TO DISCUSS THE
BROADER SOCIO-ECONOMIC ISSUES THAT FACE THIS REGION, INCLUDING
AIR POLLUTION, GOVERNMENTAL RELATIONSHIPS , LAND USE PATTERNS, AND
TRANSPORTATION SYSTEMS. WE NOTE THE STATED PURPOSE OF THE DOCU-
MENT IS TO ELICIT A PUBLIC DIALOGUE ON THESE AND OTHER ISSUES, AND
AS SUCH, THE E .1 .S. IS AN EXCELLENT OVERVIEW. HOWEVER, WE ARE CON- ( 1
CERNED THAT SUCH A BROAD APPROACH MAY BE COUNTERPRODUCTIVE TO
THE PURSUIT OF THE GOALS OF THE CLEAN WATER PROGRAM.
REGARDING THE SPECIFIC ELEMENTS OF THE ENVIRONMENTAL IMPACT
STATEMENT, WE HAVE THE FOLLOWING CONCERNS:
WE CANNOT SUPPORT THE "NO-ACTION" ALTERNATIVE, WHICH AMOUNTS
TO A NO-FUNDING POSTURE ON THE PART OF THE E.P.A. THE ADVERSE
IMPACTS OF SUCH A POSTURE ARE NOT EXAMINED IN THE E .1 .S ., BUT MIGHT
INCLUDE THE FOLLOWING:
1. IT IS UNLIKELY THAT NON-FUNDING OF WASTEWATER TREATMENT
FACILITIES AND POLLUTION ABATEMENT PROGRAMS WOULD SIGNIFICANTLY
359
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CONSTRAIN POPULATION GROWTH, ALTHOUGH IT WOULD CONTRIBUTE TO
INFLATED HOUSING COSTS.
2. IT IS PROBABLE THAT LOCAL GOVERNMENTS WOULD BE UNABLE TO
AFFORD THE ADDITIONAL ELEMENTS OF MORE ADVANCED WASTE TREAT-
MENT NEEDED TO IMPROVE WATER QUALITY.
3. DEGRADATION OF WATER QUALITY AND STREAMSIDE ENVIRONMENTS
WOULD CONTINUE AT AN ACCELERATED RATE; RECREATIONAL OPPOR-
TUNITIES ALONG WATERWAYS WOULD BE LOST OR SEVERELY RESTRICTED.
4. THE EFFORT TO MAKE A SIGNIFICANT IMPACT ON THE IMPROVEMENT
OF WATER QUALITY, WITHIN THE FRAMEWORK OF THE CLEAN WATER PLAN,
WOULD BE VIRTUALLY CANCELLED.
THE ENVIRONMENTAL IMPACT STATEMENT APPEARS TO JUSTIFY THE
OPTION OF NON-FUNDING OF WASTEWATER FACILITIES BY MAKING THE STATE-
MENT THAT THE ALTERNATIVES PROPOSED BY THE D.R.C.O.G. CLEAN WATER
PLAN WILL NOT MEET THE 1983 GOALS. THE FEDERAL MANDATE OF FISHABLE
AND SWIMMABLE WATERS IS, HOWEVER, QUALIFIED BY THE TERM "WHERE
ATTAINABLE," AND THE INTERPRETATION OF SUCH A GOAL MUST REFLECT,
INTER ALIA, A STRONG SENSE OF FISCAL RESPONSIBILITY. THE CLEAN WATER
PLAN ALTERNATIVES ARE BASED UPON FUNDING PROJECTIONS SUPPLIED BY
THE E.P.A., UTILIZE REASONABLE PRIORITY CRITERIA (BENEFICIAL USES) ,
AND ATTEMPT TO DEVELOP A COST-EFFECTIVE PROGRAM ENTIRELY CONSIS-
TENT WITH THE SPIRIT OF THE FEDERAL WATER POLLUTION CONTROL ACT.
WE SUPPORT THE FUNDING OF PROGRAMS TO DEVELOP CRITERIA FOR
THE CONTROL OF NON-POINT SOURCES OF WATER POLLUTION (URBAN
360
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RUNOFF) AS DESCRIBED IN THE E.I.S. , INCLUDING A CONTINUAL STREAM-
QUALITY MONITORING SYSTEM.
WE FEEL STRONGLY THAT THE REVIEW AND DISCUSSION OF THE
CLEAN WATER PLAN GENERATED BY THIS ENVIRONMENTAL IMPACT STATE-
MENT SHOULD NOT DELAY THE APPROVAL OF 201 FACILITIES PLANS NOW
BEFORE THE E .P. A. THE CLEAN WATER PLAN IS A DYNAMIC DOCUMENT
LENDING ITSELF TO CONTINUED SCRUTINY AND REVISION IN THE COMING
YEARS. DELAYS IN APPROVING FACILITIES PLAN, HOWEVER, RESULT IN
UNJUSTIFIABLE COST OVERRUNS AND ADDITIONAL TAX BURDENS TO OUR
CITIZENS.
THE DENVER CHAMBER OF COMMERCE HAS LONG SUPPORTED PROGRAMS
TO DEVELOP REALISTIC AIR POLLUTION CONTROLS , INCLUDING AUTO EMISSION
CONTROLS, AND TO BRING ABOUT REASONABLE LAND USE PLANS AND
REGULATIONS. WE HAVE STRONGLY SUPPORTED EFFORTS TOWARD A MORE
EFFICIENT AND BALANCED TRANSPORTATION SYSTEM FOR THIS REGION,
AND WORKED FOR THE PASSAGE OF MEASURES AIMING AT THE CONSOLIDATION
OF REGIONAL SERVICES , SUCH AS THE URBAN SERVICE AUTHORITY. WE ARE
SENSITIVE TO THESE BROADER ISSUES AND APPRECIATE THEIR INCLUSION
IN THE E.I.S. WE MUST INDICATE, HOWEVER, THAT SUCH PROPOSALS AS
THE ALTERATION OF OUR FORMS OF LOCAL GOVERNMENT, OR THE CENTRALI-
ZATION OF LAND USE AUTHORITY , AS MAY SEEM APPROPRIATE TO THE E .P .A.,
CANNOT BE MADE PREREQUISITE TO THE GRANTING OF FUNDS FOR WASTE-
WATER TREATMENT FACILITIES. WE BELIEVE SUCH TACTICS STEP OUTSIDE
THE BOUNDARIES OF E.P.A.'S PEROGATIVE AND AUTHORITY.
361
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RESPECTFULLY SUBMITTED
HOWARDD. HIGKS
STAFF PROJECT R1ANAGER
DENVER CHAMBER OF COMMERCE
362
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RESPONSES TO COMMENTS BY
THE DENVER CHAMBER OF COMMERCE
15 AUGUST 1977
1. Please see the Introduction to Section V, Volume 2.
2. Please see Section III, Volume 2.
3. Please see discussions in Volume 1, subsections III-5 and IV-5.
4. Please see discussions in Volume 1, subsections III-4 and IV-4.
5. Please see discussions in Volume 1, subsections III-l and IV-1.
363
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ENVIRONMENTAL PROTECTION AGENCY PUBLIC TESTIMONY
Marriot Hotel
July 18, 1977
Re: Environmental Impact Study/Clear Water Plan
This testimony is very much in support of parts of PL 92-500. The Denver County
Republican Party water task force encourages the cleaning up of our water ways,
streams, air polution and in general our environment as a major city continues to
grow. The West and Southwest are presently absorbing the major population shifts
from the East as forecasted long ago by United States Census and private research
teams. In addition to this natural phenomena is the recent focus of the world to
the many energy resources in Colorado and the West. President Carter has emphasized
many times our future dependances on the West for her coal, uranium, natural gas,
shale oil. The President of Richfield Oil recently announced that if the price of
world oil continues to rise at the present rate, by the year 2000, coal will be the
Nations number one source of energy. Also announced last week was the expected
move of United California Bank and many other major financial institutions to
move into the Denver Metropolitan area as the financial arm to the energy industries.
This concentration of industry with its army of employed is certainly going to
have a major effect on Metro Denver in providing shelter, food, water and municipal
services and also places a tremendous need for masterful, long range planning.
PL 92-500 gives the Environmental Protection Agency the power to administer and
enforce the various sections of that law, specifically sections 201 and 208. This
is the planning and development of systems to clean polutants of air and water and
the environment.
Environmental Protection Agencies Environmental Impact Statement to Denver Regional
Council of Governments Clean Water Plan explains in detail the various problems
the Denver Metro area faces, but sheds little light on progressive measures to put
our various waste water treatment facilities in compliance with PL 92-500. Instead,
it seems to me, that the Environmental Protection Agency is saying "Stop Federal fund-
ing to Denver for waste treatment which will effectively stop the population growth
and therefore the need for improved waste treatment facilities will no longer be
needed." Now gentlemen, that is a direct contradiction to the governments decision
to develop the West! Where then do we put the people? Ship them in from Alaska?
364
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Section 208 also requires that air standard qualities and non-point water polution
sources be contained to its minimum. To stop the non-point source of polution, says
Environmental Protection Agency, we must stop urban sprawl. To clean the air qualities
of the cities we must stop driving our cars. Here, it seems to me, is a glarring ex-
ample of the divergence of planning by at least three government bodies. The Secretary
of Transportation, two years ago, refused RTD funding for a mono-rail system which if
in use would greatly reduce the amount of air polutants in the city. Reason given for
the decision was that the population in Denver would not support this form of mass
transportation. In other words, come back when you have a larger population. What
do we do with the air in the meantime?
HUD also is spending millions of dollars to attract people back into the city. But
the Environmental Protection Agency says in its Environmental Impact Statement, stop
growth in the Denver Metropolitan area to reduce the amount of air and water polutants.
Finally, President Carter, before his election promised to work closely with local
municipal governments to work out the nations cities problems. Now we see in
PL 92-500 that Section 208, regional planning on a Federal basis with the blessing
of the Govenor, is encouraded over Section 201, planning on a local project-by-
project basis, which is encouraged by the Environmental Protection Agency. I ask,
does the Carter administration really want'to work with local government, regarding
local problems or would it prefer to turn the entire local water and water treatment
problems to another Federal Bureaucracy?
The Republican Party Denver Water Task Force strongly urges the Environmental
Protection Agency to work closely with Denver Regional Council of Governments and
the local municipalities in solving the waste water and air polution problems and
encourages Federal funding to local municipalities for needed treatment facilities
to meet the ever increasing population and industrial growth in the Denver Metro-
politian area. Today is the time to stop the decision process of whether Denver
needs Federal funding and start immediately to implement the projects which are now
so badly needed. ~)
Rik Toren
GOP DENVER WATER TASK FORCE, CHRMN
365
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RESPONSES TO COMMENTS BY
THE DENVER COUNTY REPUBLICAN PARTY WATER TASK FORCE
18 JULY 1977
1. Please see discussions in Volume 1, subsections III-l and IV-1.
2. Please see discussions in Volume 1, subsections III-4 and IV-4.
366
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Statement Concerning the Regional Draft EIS For Wastewater Facilities
and The Clean Water Program
The Denver Sierra Club commends the Environmental Protection Agency
for taking a long necessary approach in the study of the effects of a plan of
action-in this case concerning wastewater facilities . The EPA has done a fine
job of trying to stimulate thought concerning all aspects of the area that will be
effected by continued population growth.
The Denver Sierra Club would like to see the growth rate of the area
cut back to a minimal amount before 1980 otherwise we fear that water, air, land
and other tangible -.qualities will be irreparably damaged. The suggested growth
control recommendations in the DEIS are wholeheartedly endorsed.
"1. Prohibit floodplain development and/or require a 200 foot stream
setback.
2. Minimize impervious areas and vehicle areas and vehicle use.
3. Provide for the collection and temporary storage of initital or low
volume runoff from commercial and industrial sites for evential
discharge and treatment by wastewater treatment plants during off
peak hours .
4. Ban the use of septic tank leach fields."
To the goal of growth control a land use program that protects agricul-
tural land against "irreversible" conversion to other uses and legislation to enact
a Family Farm and Antitust Act in Colorado and Region VIII would be most useful.
Funding for water and waste water treatment should not be provided where loss of
prime agricultural land is involved. HAdi-tiowalW e*f should vjs«-Vts £i
-
The Denver Sierra Club feels that the agricultural segment should
have preference where water consumption is concerned, and also feels that there
could be more sharing of water rights between municipal and agricultural users ,
i.e. where the urban area ftrst uses the water and forwards it on to the farmers
somewhat enriched in nitrogen and phosphorus content. A change in water laws as
outlined in the DEIS to include an Agricultural Land Transfer Tax or outright buying
and »»leasing to family farmers in the form of a Land Trust should be investigated.
Certainly conservation of water measures are necessary, especially
though the means suggested in the DEIS, they are. . . .
"1. Continuing education programs on the need and ways of conserving
water.
2. Metering of all water users so that excessive use can be determined
and water conservation measures enforced.
3. Establish water use goals with a" progressive "rate structure for
excessive use.
4. Ban the sale and installation of water using appliances that use ex-
cessive amounts of water. "
367
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Please note that point #3 has been altered to require progressive rather than the
presently stated "regressive"water rate charges. If the rates are higher per unit
as the rate of useage increases then there is less likely to be excess waste.
The Denver Sierra Club would like to see the recent EPA education
campaign expanded to include composting toilets and municipal code changes to
allow their installation and use in Metropolitan areas as well as discouragement
of garbage grinders in kitchen sinks,and a stablizing in the number of water tap
connections.
EPA, Congress, Legislatures and City Administrators, including
Sanitary Engineers must be reoriented to chage over from the traditional municipal
wastewater treatment plant improvements to a dedication to a program based on
land application of sewage and effluent until such a time as the composting
toilet is made available to all. We would hope that the increased soil value
of land application would be taken into account when considering the cost effective-
ness of land application in the Clean Water Plan.
The Denver Sierra Club would like to see a change from the present
contests for lawns with imported grasses to contests concerning those grasses which
are indiginous to our arid land.
A Denver Regional Council of Governments monitoring system is im-
perative and point source control must be enforced for water quality, especially
where industry is concerned; potentially toxic industrial wastes must be controlled
at the source as is presently being attempted.
Non-point source pollutants can be minimized by introducing a weekly
street cleaning program by the municipalities and/or home owners and with en-
forcement of local municipal codes concerning the "depositing or littering in
streets, alley ways, or any public place, ashes, bottles, cans, garbage, glass,
nails, tacks, rubbish, trash, wastepaper, wire, or other waste materials or any
snow, or ice removed from private property" (Denver Municipal Code 135.12).
A weekly street cleaning program would also reduce particulates in
the air. Demonstration studies must be instituted regarding volume of traffic,
sanding and salting programs, especially in high volume areas,in conjunction
with regional transportation systems as substitution for the automobile. More
bicycle paths should be built and downtown roads should be made safe for such
vehicles. There are also needs for parking for bicycles which are not now met.
Natural gas shortfalls and secondary impacts on electrical power
generators and distribution must be allocated on the basis of SOCIAL needs- not
on industry production demands and not on products using the most energy and
least basic to trie full vital needs of the people. We need to have a full intensive
continually expanding PR program concerning both energy and water usage in the
region, especially.Consolidation of responsibility while making it easier for the
368
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for the EPA to effctively carry out the mandates of Congress by no means
insures that the reorientation necessary will automatically occur. This will
only happen when EPA enormously increases its grass roots education of the
U. S. population.
Respectfully Submitted
' < ' ' "-^"
f the Denver Sierra Club
1935 Delaware Street
Denver, Colorado 80204
369
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RESPONSES TO COMMENTS BY
THE DENVER SIERRA CLUB
1. Please see discussions in Volume 1, subsections III-5 and IV-5.
2. Please see discussions in Volume 1, subsections III-9 and IV-9.
3. Please see discussions in Volume 1, subsections III-6 and IV-6.
4. Please see discussions in Volume 1, subsections III-7 and IV-7.
5. Please see discussions in Volume 1, subsections III-A and IV-4.
6. Please see discussions in Volume 1, subsections III-3 and IV-3.
7. This comment is acknowledged.
8. Please see discussions in Volume 1, subsections III-l and 1V-1.
370
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Historic Denver, Inc.
June 23, 1977
TO: United States Environmental Protection Agency
FROM: Historic Denver, Inc.
RE: Denver Regional Environmental Impact Statement for Wastewater Facilities
and the Clean Uater Program
Historic Denver's major concern is with the aspects of the EIS which deal with
historic sites and buildings. The list of major historic sites, given on page
A 59 in the Appendices, does not adequately cover the major cultural resources (J
found in Denver and surrounding areas. The list should include all the buildings,
sites, and districts that have been designated as landmarks by city or county
ordinances and those listed on the National Register of Historic Places. These
are available at the Denver Planning Office and the State Historical Society of
Colorado.
Historic Denver recommends that local and state inventories and surveys be
consulted during the planning process. The Revised Denver Inventory, available
through the Denver Planning Office, gives listings by neighborhoods of buildings
and districts designated as Denver Landmarks and listed on the national Register.
It also lists those qualified for landmark designation. Attention should be given
to those buildings, sites, and districts that are in the process of landmark
designation, either local or national.
It should be noted that the surveys and inventories are not definitive on
what is significant. They are a record or listing of information known at a
particular point in tine and are subject to additions or deletions at a later
date.
Every effort should be made to determine what cultural resources are in the
project areas through the use of aVj_ available information.
Barbara Norgren
Preservation Consultant
371
770 Pennsylvania Street • Denver, Colorado 80203 • 303/837-1858
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RESPONSES TO COMMENTS BY
HISTORIC DENVER, INC.
23 JUNE 1977
1. Information is acknowledged and appreciated. Volume 1, sub-
sections III-9 and IV-9 address this issue and present EPA's
proposed policies.
372
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July 25, 1977
Mr. John A. Green
Regional Director
Environmental Protection Agency
I860 Lincoln Street
Denver, CO 80295
Dear Mr. Green:
On behalf of the Jefferson County Board of REALTORS, I am responding to
your request concerning citizens input on the Environmental Impact Statement
prepared on waste water facilities for the Denver Metropolitan area.
It appears that the EID takes the strategy of holding out to the general public
that the lack of construction of sewer facilities will control growth in the Denver
Metropolitan area. I would suggest to you and the EPA that the control of growth
is a concern of the Jefferson County Board of REALTORS and the public. For
the EPA to choose waste water treatment facilities as the mechanism to control
growth in the metropolitan area is ridiculous. I do not believe it is the intent of
Congress to control growth in the Denver metropolitan area through Public Law
92-500. It appears to me that the goals pf Public Law 92-50O are not possible
without the complete ruination of the current economic and social structure of
the metropolitan area. I would suggest that the Environmental Impact Statement
speak to the issue of the difficulty in reaching the goals as presently set, and
should offer some solutions as to how these goals should be amended in order to
be reached within a reasonable time and economic framework.
I also believe that the Environmental Impact Statement summarily dismisses
Land Application Sewage Treatment without any analysis of the advantage of this
system. Although your report does make references to the health dangers of
land application, I would draw your attention to the use of land application since
1898 in Sidney, Australia. Government research indicates no deaths or adverse
health effects attributable to this Land Application Method. It would appear that
the Environmental Protection Agency, in the semiarid Denver Metropolitan region
should concern itself with this viable method of sewage treatment. Just to con-
tinue to build concrete treatment plants is not a good use of our money, nor is
it a good use of the energy available to this country. The Jefferson County Board
of REALTORS would prefer to see your agency concentrate its efforts on estab-
lishing economically efficient sewage disposal systems, such as land application,
instead of your agency attempting to establish growth control policy for the Denver
Metropolitan region.
373
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Page two
Your consideration of these ideas will be appreciated by the Jefferson County
Board of REALTORS. I hope that you will further analyze the Environmental
Impact Statement as prepared and change it to reflect the reality in which we
live and our ability to solve our problem within the money available to us.
In addition, I must tell you of my displeasure with the slide presentation at the
public hearing on July 19, 1977. This presentation was not anly ill conceived, but
not informative.- I expect more sophisticated treatment of the environmental
problems facing the Denver Metropolitan area than was expressed by that presen-
tation .
I appreciate the opportunity to respond to your Environmental Impact Statement
and hope that my input will be helpful.
Sincerely,
Capp F. Shanks (/Jr.
Governmental Liaison
Jefferson County Board of REALTORS
374
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RESPONSES TO COMMENTS BY
THE JEFFERSON COUNTY BOARD OF REALTORS
25 JULY 1977
1. Agreed. Environmental Protection is EPA's primary concern.
Please see Discussions in Volume 1, subsections III-4 and IV-4.
2. Please see discussions in Volume 1, subsections III-2 and IV-2.
3. Please see discussions in Volume 1, subsections III-3 and IV-3.
See also EPA's responses to comments from the City of Northglenn,
pages 290 and 295.
4. Please see the Introduction to Section V, Volume 2.
375
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Gambles
9456 West 58th Avenue
Arvada, Colorado 80002
July 22, 1977
Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80295
Attention: John Green
Dear Mr. Green:
As chairman of the Legislative Forum of the Arvada Chamber of
Commerce, it has been brought to my attention that the "No Federal
Funding" alternative for waste water treatment facilities is really
not an alternative. This approach would cast an unbearable burden
upon municipalities and would therefore be passed along to the home
owner and renter and businessman.
While I do not presume to speak for the group, it is my opinion
and the concensus of the group, that a protest to the "alternative"
be registered.
Respectfully,
Robert A. Close
376
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RESPONSES TO COMMENTS BY
THE LEGISLATIVE FORUM OF THE ARVADA CHAMBER OF COMMERCE
22 JULY 1977
1. EPA agrees. See Volume 1 for a description and discussion of
EPA's planned actions and policies.
377
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*
metro^ denver
league of women voters
1600 Race Street
Denver, Colorado 80206
July 27, 1977
Mr. John Green
Regional Administrator
USEPA
1860 Lincoln
Denver, CO 80203
Dear Mr. Green:
The League of Women Voters of Metro Denver has been concerned for sometime about
the lack of coordinated and comprehensive planning in the Metropolitan area. The
Draft Environmental Impact Statement for Wastewater Facilities and the Clean Water
Program goes a long way in addressing this need. We are very supportive of the
evaluation done by the Environmental Protection Agency of the environmental impacts
of attaining cleaner water and air in the Denver Metropolitan Region. The EPA has
done an excellent job in setting forth issues that need to be resolved. We also wish
to commend the Agency on its attempt to involve the public through slide presentations,
a newspaper supplement and public hearings.
The League supports the local alternative with a plant on Clear Creek as
presented in the EIS. The construction or expansion of local facilities would allow
for more innovative approaches in the utilization of water, an obviously scarce
resource in this region.
The consolidation of wastewater treatment facilities at only a few sites as
presented in the regional alternative is unacceptable. This approach would, we
believe, foreclose the development of efficient reuse, exchange, and land application
schemes. We should have learned by now, from experience in other Metropolitan areas,
that large regional plants are not the answer.
We do not support the no action alternative. Efforts to reduce the amount of
pollutant loadings from point sources is essential even though pollutants from non-
point sources will continue to increase. The control of non-point sources is a
relatively new issue being addressed by the nation. We should proceed to address this
difficult problem through all means available taking into consideration the attendant
social, economic and environmental factors. Adopting the no-action alternative would
be costly to the region and would allow for a further delay in the reduction of non-
point sources of pollution.
The problems surrounding control of non-point sources have been adequately
addressed in the Draft EIS prepared by EPA. However, the Denver Regional Council of
Government's 208 plan is lacking in this area. A more aggressive stance should be
taken and an institutional arrangement must be established which will allow for the
control of non-point sources of pollution.
The LWV of Metro Denver believes that the 208 plan as presented in the Draft
Clean Water Plan should be adopted. While we agree that there are some serious
county, arapahoe county, aurora, boulder, denver, Jefferson county
-------
-2-
weaknesses in the plan, they can probably be better dealt with if a compliance
schedule for upgrading the plan is adopted. Funding for upgrading and implementation
must be considered. There is real concern that without further funding plans
developed under Section 208 will not be implemented.
The DRCOG 208 plan has devised an institutional arrangement which we believe
should be consolidated further. Funding decisions by EPA should be easier to make
based on a more coordinated approach.
There are a few specific points which we think should be more fully addressed
in the EIS.
It would appear that the EPA is over emphasizing the construction of treatment
plants to improve water quality. More consideration should be given to land application^
methods. Colorado requires secondary treatment for land application and where
indicated a system should be devised so that the beneficial properties of effluent
can be utilized. It seems somewhat incongruous, considering the energy problems
facing the nation, to remove at a high energy cost, nutrients which then will be
replaced by fertilizer which also saps our energy supply.
Utilization of secondary effluent may go a long way to retain agricultural land
and open space. Informal systems of land treatment (including sludge) have been used
all over the United States. In addition, there have been more formal systems such as
application to golf courses and parks. Continuation of these practices should be
considered.
We disagree with your proposal to ban septic systems. The construction of
interceptors to collect waste from remote areas may be very disruptive to the
environment and may open up additional areas for development. We would suggest that
septic systems if constructed properly and cleaned and inspected regularly may be
more appropriate in some areas. Also, installation of septic systems for small rural
communities should be investigated. These systems could be required to be monitored
and maintained.
We appreciate -the innovative approach taken by the Environmental Protection Agency
in addressing the air and water problems of the region as a whole and not on a
project by project basis. We would hope that the document would be a basis for much
decision making, and that it will be further refined. Much of the refinement must
come from decision makers and citizens in the area. We, as one organization, will
attempt to work on this aspect in the future.
Sincerely yours,
Toni E. Worcester
President
cc - Douglas Costle
Gary Broetzxnan
Bob Doyle
Bill Geise
David Pampu
Jack Hibert
379
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RESPONSES TO COMMENTS BY
THE METRO DENVER LEAGUE OF WOMEN VOTERS
27 JULY 1977
1. EPA essentially agrees.
2. Please see discussions in Volume 1, subsections III-5 and IV-5.
3. Please see discussions in Volume 1, subsections III-4 and IV-4.
4. Please see discussions in Volume 1, subsections III-3 and IV-3,
and responses to City of Northglenn's comments pages 290 and 295.
380
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7626 Oak Street
Arvada, Colorado 80005
July 17, 1977
Environmental Protection Agency
1860 Lincoln
Denver, Colorado 80295
Attention: John Green
Dear Sir:
I intend to obtain a copy of the draft Denver Regional Environmental
Impact Statement for Wastewater Facilities and the Clean Water Program.
In addition, I wonder if there is any regularly published literature
that will help me keep up to date on the issues you have covered and
current activities related to them.
I am gravely concerned about the projected growth in the metropoli-
tan area and its consequences.
Thank you.
Mrs. N. J. Besch (Patricia)
422-5852
381
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RESPONSE TO COMMENTS BY
MRS. N. J. BESCH
17 JULY 1977
1. EPA Region VIII has joined with the Energy Research and Develop-
ment Administration and other federal agencies to establish and
fund an energy/environment information center at the Denver Pub-
lic Library. The center's staff provides information search and
retrieval services, referral services and acts as a depository
for important regional information.
382
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9905 W. 21st Ave., #4
Lakewood, Co 80215
July 13, 1977
Bob Doyle
Environmental Protection Agency
1860 Lincoln
Denver, Co 80295
Dear Mr. Doyle:
My congratulations on EPA's "It's Your Future...". I can't tell
you how happy I feel when I see someone looking at Denver's growth from
a view point other than monetary!
Please send me: "The Denver Regional EIS for Wastewater Facilities
and the Clean Water Program." and any additional information.
I would also appreciate receiving EISs on the Foothills and Two
Forks Projects.
Thanks,
Dan Chiras
232-6868
383
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RESPONSES TO COMMENTS BY
MR. DAN CHIRAS,
13 JULY, 1977
1. No response required.
384
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'HUalden,
7 July 1977
Mr. Robert Doyle
U.S. Environmental Protection Agency
Region VIII
1860 Lincoln Street
Denver, Colorado
Subject: Draft EIS for Denver Regional Wastewater Facilities
and Clean Water Program
Dear Mr. Doyle:
I wish to comment briefly on the draft EIS. During the past two years
I have had an opportunity to study some of the environmental issues
concerning Rocky Mountain Arsenal near Denver, Colorado. Through site
visits, discussions with Denver USGS personnel, visits to Boulder,
Colorado institutions, and a review of U.S. Army documents, I have become
acquainted with studies of groundwater aquifers, waste disposal, and
wildlife in the Denver area.
The subject EIS is a concise and generally clear discussion of the principle
impacts involved in the proposed actions. However, a close reading of
Section II revealed that, in keeping with the overall program priorities,
the biology portion has received only a superficial treatment. You may
wish to reexamine this section.
The "Biology" section (page 11-43) is of uneven quality. For example,
in the first paragraph we are told in very general terms that human
settlement has brought great ecological changes, obliterated many wildlife
habitat areas, caused almost no effects on several steppe community areas,
and even replaced lost habitat and increased ecological diversity in other
areas. In the final sentence one learns of only potential danger to several
animal species and to no plant species. This introductory paragraph gives
the impression of some bad and some good ecological effects, but does not
come to a definite conclusion. It is imperative that this informational
document reach a conclusion based on scientific data.
The second paragraph describes Denver in very general terms, but is unduly
qualitative. With the exception of the words heron, cottonwood, and willow,
there is no mention of genera or species. Likewise, there is no mention
of the size of the wildlife areas in either miles of shoreline or acres
of water bodies, gallery forests, or grasslands. We are given no idea
of the extent of cold or warm water fisheries within the city.
WALDEN DIVISION OF,
. 850 Main Street - Wilmington =MAn01887a 617/657/4250 Telex 710 3476537
385
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Mr. Robert Doyle Page 2 7 July 1977
The introductory sentence to paragraph three - "In the outlying areas,
human activity is less intense and many areas still retain much of their
natural condition." - is misleading. For instance, prairie dogs are
numerous, not in the (farm) areas surrounding Denver, but in areas south
of Denver and in areas, such as Rocky Mountain Arsenal, which are strictly
controlled. The two sentences on the black-footed ferret are misleading.
Are there any black-footed ferrets in Colorado?
The biology section, as written, consists of four paragraphs:
1. Introductory nonsense;
2. Nature travelogues of Denver;
3. Inaccurate, incomplete descriptions of unusual or rare mammals
and birds in outlying areas; and
4. Fire hazards.
To more properly satisfy NEPA intent, you should provide meaningful
baseline documentation against which to judge the impact of the proposed
actions. It is urged that you alter your format to include:
1. Areas (acres) of each major type of habitat (including human
dominated uses, such as farming and residential) for outlying
areas and for Denver;
2. Principal vegetation types -
Native vegetation
Introduced vegetation
Farm crops
3. Principal species and habitat requirements -
Mammal s
Birds
Fish
Amphibians
386
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Mr. Robert Doyle Page 3 7 July 1977
4. Factors which have altered the range and abundance of
principal plant and animal species -
Direct loss of habitat due to construction
Loss of habitat due to farming
Fire
Changes to water courses
Loss of prey species
In summary, the vague statement you offer should be replaced by more
quantitative statements available from the scientific community.
Sincerely,
David R. Cogley
Manager
Environmental Studies
Technology Development Department
DRC:ccr
Enclosure
WALDEN DIVISION OF .
. 850 Main Street c Wilmington GMAD01887Q 617/657/4250 Telex710 3476537
387
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ATTACWENT A: ADDITIONAL COMMENTS
Page Comments
x—>
II-5 Table II-A. The primary standard for participate matter (2
reads "75 ym3", but should read "75 yg/m3".
11-21 Paragraph two, second line. "Bartonitic" should read (T
"bentonitic". ^
11-34 Table II-H. Under "dissolved oxygen" average and peak (T
values are listed. Minimum values should also be listed.
The reason being that ecological stress occurs at low
oxygen levels. Low dissolved oxygen levels limit stream
productivity.
IV-63 Table IV-Q. The "Alternative Classification Levels"
specified in this table are of limited value as they stand.
Table IV-Q should be improved by combining salient aspects
of Table II-D (11-29) so as to be of maximum utility to
the reader.
Map E The most north-westerly "perennial lake" on Rocky Mountain
Arsenal is not a lake, but rather an asphalt lined waste
basin (Basin F) devoid of wildlife.
388
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RESPONSES TO COMMENTS BY
MR. DAVID R. COGLEY,
7 JULY, 1977
1. Please see the introduction to this section.
2. This error has been corrected in Section II of Volume 2 (p. 19),
3. This error has been corrected in Section II of Volume 2 (p. 32).
4. Table IV-Q in Volume 2 has been amended as recommended (p. 175).
5. This comment is acknowledged.
389
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John Green
Environmental Protection Agency
1860 Lincoln
Denver, Colo. 80295
Dear Mr. Green:
Just heard a discussion of the E.P.A. proposal on Wastewater
Non Funding for the Denver Metro Area.
This seems to me to be an unrealistic approach to the problem.
While water quality is important to all of us we must use a reasonable
approach to solve the problem.
I would urge you to closely review the Denver Regional Council of
Government recommendation - as well as correspondence from the "Elected"
officials in the Metro area.
Jim Fisher
Arvada
P. S. The elected local officials - have a better sense of the pulse of
the community than the "Sierra Club" - or a non elected Federal
government employee. The elected officials on a local level
represent the Silent majority. — Please heed their advice.
390
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RESPONSES TO COMMENTS BY
MR, JIM FISHER
1. As a result of EPA and public review of the Draft EIS, EPA
has decided that the no-action (non-funding) alternative
is not the appropriate course of action. Volume 1 of this
EIS explains EPA's decisions.
391
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5OO EQUITABLE BUILDING
73O SEVENTEENTH STREET
DENVER,COLORADO SO2O2
July 14, 1977
Mr. John A. Green
Regional Administrator
U. S. Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
Dear Mr. Green:
Thank you for your notice headed "We are Looking
for your Ideas".
I was a member of the Water Quality Task Force
which prepared the DRCOG report. I also received the four
volume EIS from the EPA, which I have read. My chief
interest is to hold down the overall growth, as well as
the sprawled nature of metropolitan growth, in order to
prevent worse air pollution. I have some knowledge in this
matter as trustee of the Webb-Waring Lung Institute.
Keep up the good work.
Yours cordially,
Tohn L. J. Hart
S/
JLJH:j s
392 JUL1 ? 1S77
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RESPONSE TO COMMENTS BY
MR, JOHN L. J. HART,
14 JULY, 1977
1. No responses required.
393
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14632 E. Carpian PI.
Denver 80232
July 10, 1977
Environmental Protection Agency
1860 Lincoln Street
Denver, Co 80295
Bob Doyle
Dear Sir:
This is to say the American Public is anxious for our leaders to
tell us the truth and to take action for a better future.
We need one unified government for the Metro area, in all matters.
We can treat and re-use waste water. We must do so for the growth
that is inexorable.
We must maintain rigid standards for air quality control, if we all
have to drive Hondas.
We must plan the use of our land, keep good agriculture land for
that purpose, build on marginal land, maintain open space and generally
plan ahead for growth rather than reacting after the fact.
There are so many matters of interest to me in your ad that I would
appreciate receiving your synopsis mentioned in the body of ad.
I feel, after reading the supplement and responding to the question-
naire, that Mr. Green and staff are ready and able to give us some real
facts and answers and leadership.
I would like to become involved in this effort.
Yours,
Cal Harvey
Res. 750-5608
Off. 837-8842
394
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RESPONSE TO COMMENTS BY
MR. CAL HARVEY,
10 JULY, 1977
1. No response required.
395
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Environmental Protection Agency
1860 Lincoln
Denver, Colorado 80295
Attention: John Green
Dear Sir:
I am here as a private citizen because I was incensed when I read
proposal #2, the one with regard to superseding the local governmental
authority & the surrendering of same to "Metro" professionals who will
replace elected officials, thereby giving up our rights as private citi-
zens to make our own land development decisions.
* The question is - would the formation of regional government mechan-
isms be acceptable? My answer is NO - and I urge each one here if, indeed,
this comes to a vote, not to be hoodwinked by these Metro plotters who
seek to destroy local self-government on the pretext of water treatment -
air pollution or anything else.
Bonnie Irvine
396
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RESPONSES TO COMMENTS BY
MS. BONNIE IRVINE
1. Please see discussions in Volume 1, subsections III-4 and IV-4.
397
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THE REGENTS OF THE UNIVERSITY OF COLORADO
Byron L. Johnson
Chairman, Board of Regents
2451 S. DAHLIA LANE
80222
To the
Re: Regional Impact Statement for Wastewater Facilities — Denver region
'..'hen I represented all of Denver's suburbs in the 86t"" Congress, I found
that we had 55 separate wastewater districts, no cooperation, and terribly
inadequate facilities. There was no incentive to cooperate.
orking with John Blatnik, HL1-I, and others, \
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You raise questions also about air pollution, energy, and transportation.
T..lth better land use planning, we could use more high density clusters
in planned unit developments and design away from the need for so much
reliance upon personal automobiles. With automated guideway transit
for goods as well as persons between such clusters and other activity
centers, we could shift from polluting to non-polluting transportation.
rtith electric cars and mopeds we could sharply reduce the remaining
pollution from internal combustion engines, regardless of the success
of emission controls afe this altitude.
With -.-ore encourage, ent of energy conservation, as well as of the use of
solar heading, we can cut fuel requirements further, and help clear up
the air.
The Federal overn-.ent could do much to encoura-e introduction of total
energy s -stems into major apartment complexes, with hipb te perature
solar collectors being used first for power, then for space and hot
water heatia?. Because EPA seems to exoect ore ccal fired plants,
it seers appropriate to sue est that thesex be built where new housing
is Roing in, so that the waste heat can be converged into space and hot
water heating, rather than thermal pollution of air and water.
If Colorado gains a .other 750,000 people by 1^50, as it ;;ay, and if
each family were to want a five acre tract, and they .vere to settle east
of the Front Range, they would consume a strip of land equivalent to
1800 square miles, or a stript the full length of the state, B s:.uth to
north,'six riles wide. If these 750,OCO were to live in clusters
averaging 15 family units to the acre,'they would need no more than
2k square railes, for their housing. And service to them would require
less utility lines, less water, less roads, etc.
..e expect Uncle Sam to pick up more and more of the tab. Perhaps Uncle
ought to set some standards of reasonableness before he pays the bill .
The EPA could help us all take better care of our rich patrimony by
preaching a gospel of stewardship, "we dcn't really own the land in
fee sir.Tle, or any other way. .'e can't take it with us when we ~o.
e are truly but trustees of the land for our children and their
children's children. Only as we cor.e to see the long run impact upon
generations yet unborn of our recksless use cf all land, air, and water
do we be~in to recognize the need for a sense of stewardship over
these resources. It is a stewardship in which we all share^ ^tenarts,
landlords, local -overnren.s, corporations, States, and the Federal
government--alike. We have bee i a State for s century, and the frc::t?er
was really closed when we were admitted to statehood. We need a larger
vision for the next century, and the centuries tc co.^e. The practices
that could be tolerated in the first century, and in part of the second,
can no longer te accepted for the third, -'e cannot ir;ove on any longer.
The frontier is closed. Either we reduce the pollution, or it reduces
us.
/
399
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RESPONSES TO COMMENTS BY
MR. BYRON L. JOHNSON
18 JULY 1977
1. Please see discussions in Volume 1, subsections III-4 and IV-4.
2. Please see discussions in Volume 1, subsections III-l and IV-1.
3. Please see discussions in Volume 1, subsections III-8 and 9, and
IV-8 and 9.
400
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Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80295
Attention: Mr. John Green
Dear Sir:
AIR CONTROL: I believe this is important but the government as usual
follows the most complicated course in the effort to decrease air pol-
lution. They are now on the right track by demanding higher milage
per gallon of gas. This can be increased substantially by eliminating
all the mechanism on the autos. We all should realize that by burning
one gallon of gas in 35 miles without any pollution control we will
pollute considerably less air since the engine will burn most of it
using so little gas.
WATER QUALITY: This is extremely important since it involves the health
and welfare of the public. This is a must for government control and
costs money. Recycling will cost more but we have a limited supply
of water and it must be utilized to the maximum.
URBAN LAND USE PLANNING: Land use will take care of itself. Houston,
Texas has no zoning or land use legislation and is a model city. The
lenders, appraisers, and estute builders will better make the determina-
tion of land use through economics than any public body. Also, the
availability and cost of utilities, marketability and location should
determine land use. Land use is the most unfair and unconstitutional
legislation to any land owner. Often land use is determined by voters
pressure on the elected officials. The same is true of zoning, but is
not always the best policy, since everyone is looking out for only
themselves and their personal interest. The free market will best
determine land use.
RECREATICN AND OPEN SPACE: This is fairly important and Senate Bill 35
already requires a donation of 10% of the land to be donated by every
developer for public use. In addition often the developer is required
to supply funds to develop the open space and recreation area. Many of
the developments have their private recreation areas controlled by the
owners association. I believe that we have sufficient legislation at present.
AGRICULTURAL LAND USE: This also is mostly determined by the free market
enterprise; farmers cannot continue to grow crops at a loss. It is very
important that good farm land be conserved, especially in low lands and
flood plains which has the best production but this is very limited and
other land is needed. Recycled water should all be used for agriculture
where it is not used for domestic use. We need more dams and reservoirs
limiting to a minimum the flow of our fresh water into the sea.
401
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ENERGY CONSERVATION: This is most necessary since there is only a limited
amount of all resources in the earth and one day will be depleted, not
during our lifetime but in some future generation. Every effort should
be made to find new sources of energy, wind, solar, possibly some yet to
be discovered.
ENVIRONMENTAL IMPACT STUDIES: This was not mentioned in your questionnaire
but is one of the most ridiculous monsters ever conceived. .Nowhere can
anyone establish a definite criteria to evaluate the environmental impact
of many things. I have found that environmental impact studies are evalu-
ated mostly on the basis of how favorable any project appears to the judge
of the impact study; it is like beauty to the beholder. The environmental
impact studies could be made meaningful if they eliminated 75% of the
gobbeldy gook and adhered to 25% of the factual items, such as water use,
utility availability, traffic, air pollution, appearance, and a few more.
C. J. Medema
402
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RESPONSES TO COMMENTS BY
MR. C. J. MEDEMA
1. Please see discussions in Volume 1, subsections III-l and IV-1.
2. Please see discussions in Volume 1, subsections II1-3 and IV-3.
3. Please see discussions in Volume 1, subsections III-9 and IV-9.
4. Please see discussions in Volume 2, beginning pages 77 and 139.
5. Please see discussions in Volume 1, subsections III-3 and IV-3.
6. Please see discussions in Volume 1, subsections III-7 and IV-7.
7. No response required.
403
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Mr. John A. Green, Regional Administrator
Environmental Protection Agency
i860 Lincoln Street
Denver 80295
Dear Mr. Greea:
This is with regard to your request
for comments relative to the newspaper ads you placed:
I would like to suggest that you close up shop, get the
hell off the taxpayers back, go home and leave us alone e
What say, old chappie, there is still time to save the
consumer a great big bundle and stop all this government
q CRAP??????
James £• Mogan
404
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RESPONSE TO COMMENTS BY
MR. JAMES E, MOGAN
1. No response required,
405
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Environmental Protection Agency
1860 Lincoln
Denver, Colorado 80295
Attention: John Green
Gentlemen:
In response to "It's Your Future; Look Into It", I think you are
doing a wonderful job in letting people know how serious water, air, and
gasoline are. We as a nation have always wasted and now we see that we
won't have as much of everything as in the past. You must realize that
the one most important factor is WATER. You & I cannot survive without
it. Why don't you educated people try & figure a way in which to produce
more water; it is the most important subject. I read in the Denver Post
about seeding the clouds in the San Juan area & how much it cost. I as
a tax payer shared in the project & nothing was said about if they cre-
ated more water or if it was a total failure, I believe the amount was
$200,000. I believe that Cloud Seeding is necessary to produce water.
I am sure that God won't object to helping out with this problem. It
is my opinion that there is too much talk and quibbling among you fine
and educated people whom I am sure could solve our-(WATER)problem. It
is my opinion if you leave politics out of this problem (water) and get
people involved (I know it's difficult) it's everyone's problem & we
must solve it.
We as a nation are weathy in many ways. I would like to propose that
every tax payer or not a_ tax payer be charged 50c a month until there is
enough money in the til to come up with an idea on how to get more water!
We drink plenty of booze, spend money on motorcycles, boats & expensive
homes, etc.; it wouldn't hurt a dam bit to take out 50c a month. Just
think of it, the capital you would have?? In regard to gasoline, some-
where along the line the issue has become twisted & the people are
confused. If there is a shortage of gasoline, why don't you just say
we &TP running out of gasoline and other means must be obtained. I
read in the paper a couple of weeks or months ago about "Gasachol" and
it seems feasable when I read the article, and in my opinion if this is
the solution to the gasoline shortage then instead of bickering & criti-
cizing the man or company that invented it, put it on a scale so as to
give the consumer a chance to try it. They mentioned that it would be
64c a gallon. Well, for the time being it would be high until it was
perfected better and on a larger scale. As for money, I would again
propose 50c per month per individual. We must accept the 50c in order
to survive.
Again I will stress that politics stay out of it for the betterment
of the people. The people (you & I) work 5 or 6 days a week and we de-
serve to know the real truth about gasoline shortage. I would like to
know why they built th "great Alaska pipeline"? Please give me a frank
answer?. Aside from the gasoline shortage & the water shortage I hope
that you will seriously adopt some of my ideas which would indeed solve
these (2) issues gas & water.
Respectfully yours,
Clarence Paquet
406
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RESPONSES TO COMMENTS BY
MR. CLARENCE PAQUET IN HIS FIRST LETTER
1. Please see discussions in Volume 1, subsections III-7 and IV-7.
2. Please see discussions in Volume 1, subsections III-4 and IV-4.
3. No response required because the issues raised by the comment
are beyond the scope of the proposed projects and their impli-
cations for the region.
407
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Denver, Colo
Aug. 1, 1977
To Mr. Bob Doyle:
Thank you for sending me the literature on Wastewater facilities etc.
After reading your book and understanding more about "Pollutants" and
various other information on our future needs of water etc. Mr. Doyle,
you people are missing the boat on the whole issue of water (especially).
As I stated in my previous letter WATER is the main issue over everything
else; without water you & I will no longer exist and that is a fact!
All the material that you people put together is beautiful & it must have
taken quite a long time to put together, but on paper it is just a lot
of writing & no action. I realize that your hands are tied by the govern-
ment & all its red tape, but we must eliminate & cut through so as to get
the job done. Mr. Doyle, you did not answer some of my questions about
seeding the clouds and forcing mother nature to snow in large amounts on
our beautiful mountains & thus produce WATER!!! We must assert ourselves
and reassure the people that there is enough water for Colorado & maybe
other cities will follow our example on how to produce more water. I
have read that there is laws governing Seeding Clouds & its impact on other
towns and where they (sue) other towns because of the results of producing
water. "Mother Nature" plays funny tricks on us humans, but aside from
that we must get water & have it available & dam it up so as the future
can enjoy what we have done for them.
Aside from talking about water, last Sunday my wife & I were going
to Church & we saw this couple washing their car with the hose full blast
& the children running through the sprinklers with no concern whatsoever
about conserving water because they felt they were paying their share of
the water & to hell with everybody else, that is the impression we got.
We must educate young people as well as the old and its about time to
fine people severely so as to get the message home.
The next point of issue is the Car which does pollute the air, no
question about it. I believe by eliminating the car from going downtown
it would help considerably, but how can you do this without hurting people
from their jobs, the Car is essential & it is the main tool to make money
for the individual so as he can pay taxes etc. - You understand what I
am saying? I have a suggestion which may solve yours & mine solution on
the pollution from Cars. This would be to erect as many as needed, large
fans of some kind to suck in all the pollutants and somehow re-use the
pollutant waste for something useful. I realize that it takes money.
So what, if we are to survive people must understand the vital necessity
of life & that, my friend, is WATER & AIR, P.S., mostly water?
Please don't think that I am a crackpot, I am only interested in the
welfare of the whole of U.S. and that is the truth. I love America & for
what she is & to see her destroyed by people that don't give a dam is awful
sickening. It's high time to tell those type of people get in line or fall
out.
Please answer my letter, Mr. Doyle. I would appreciate it very much.
Respectfully yours,
Clarence Paquet
408
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RESPONSES TO COMMENTS BY
MR. CLARENCE PAQUET IN HIS SECOND LETTER
1. Please see discussions in Volume 1, subsections III-7 and IV-7.
2. Please see discussions in Volume 1, subsections III-l and IV-1.
409
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5716 Ammons (At Ralston Road)
Arvada, Colorado 80002
23 July, 1977
Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80295
Attention: Mr. John Green
Dear Sir,
In regard to the Denver Region Clean Water Program, we feel that
the "No Funding" solution is not acceptable. We feel there has to be
a better, more equitable solution.
Sincerely,
Harry & Betty Ann Parmenter
410
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RESPONSES TO COMMENTS BY
MR. HARRY PARMENTER AND MRS. BETTY ANN PARMENTER
23 JULY 1977
1. EPA agrees. See Volume 1 of this final EIS for an explanation
of what EPA proposes to do.
411
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July 17, 1977
955 South Columbine Street
Denver, Colorado 80209
Mr. Robert Doyle
Region VIII Office
Environmental Protection Agency
i860 Lincoln Street
Denver, Colorado 80203
Dear Mr. Doyle:
I am writing to express my strong opposition to the use of
EPA grant funds for the design, construction and expansion
of wastewater facilities in the Denver region. It seems
evident from reading the "Denver Regional EIS for Waste-
water Facilities and the Clean Water Program" that it would
be counterproductive for EPA to fund activities that would,
as a consequence of secondary impacts, have a net effect of
degrading environmental quality.
The EPA should be the first to recognize that the front
range of Colorado, particularly the Denver region, has a
finite "carrying capacity" determined primarily by the avail-
ability of water, natural gas and other resources and by the
capacity of the atmosphere to deal with auto and other emis-
sions. It seems fairly obvious that the carrying capacity
of the Denver region has already been surpassed — air qual-
ity is now comparable with, if not worse than, that of Los
Angeles; the demand for raw water exceeds the supply, sever-
ely so in times of drought; natural gas shortfalls are expect
ed within five years; due to the overuse of nearby National
Forests, permits may soon be required to hike or camp; and
so on. With each attempt to push carrying capacity fceyond
its reasonable limits, quality of life suffers.
In light of the adverse impacts identified in the EIS, I
strongly urge that EPA NOT fund any design, construction
or alteration of any wastewater treatment facility if such
construction or alteration will result in an increase in
operating capacity beyond what is needed to serve present
population levels. Funding under these conditions would be
counterproductive to EFA's involvement in air quality con-
trol and would adversely effect the quality of life in the
Denver region.
412
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Kr. Robert Doyle
Page 2
I would like also to express my concern over the manner in
which Denveris depicted in the draft summary EIS and in the
accompanying slide presentation. Both indicate thai; as the
region grows, physical and economic decay of the urban core
in inevitable. The EIS contends that the affluent will
take flight to the suburbs, leaving in their wake a popula-
tion of indigents. Such statements seem to be somewhat contrary
to recent trends — Denver's CBD is in the midst of the big-
gest and most impressive building boom in its history. Young,
affluent individuals and families, dissatisfied with!- the hum-
drum of suburban living, are moving backinto the core in sub-
stantial numbers and rehabilitating the housing stock. Too
often — and hopefully not in Denver's case — statements about
the long-term viability of urban centers become self-fulfilling
prophecies.
I hope these comments will be given careful consideration in
formulating policies for the funding of wastewater facilities
in the Denver region. Thank you very much for the opportun-
ity to comment.
Sincerely,
David A. Wicks
413
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RESPONSES TO COMMENTS BY
MR. DAVID A. WICKS
17 JULY 1977
1. EPA has decided that the no-funding alternative is not
appropriate. See Volume 1.
2. Please see discussions in Volume 1, subsections III-l, 7, 8 and 9,
and IV-1, 7, 8 and 9.
3. Please see the information added to "Population" in Section II,
Volume 2 (p. 69, paragraph 1).
414
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VI. Glossary and
Bibliography
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SECTION VI
GLOSSARY
Activated sludge—A process which removes organic matter from sewage
by saturating it with air and adding biologically active sludge.
ad valorem tax—A general property tax levied annually on real and
personal property as listed with the county assessor.
Aerosol—A suspension of fine solid or liquid particles in a gas.
In wastewater treatment processes involving spraying, aerosols can
transport micro-organisms and dissolved liquids in the wind for
considerable distances.
Aggregate—Any of several hard, inert materials, such as sand,
gravel or slag, used for mixing with a cementing medium to form
concrete, mortar or plaster.
Agricultural multiplier—A term which describes the number of times
money generated by the agriculture sector of a regional economy
changes hands before leaving that economy.
Anaerobic digester—A type of equipment used to digest sludge in
the absence of oxygen to reduce the volatile organic material to
methane gas by microbial activity.
Aquatic environment—The ecologic conditions extant in the region's
streams and water bodies.
Aquifer—A water-bearing stratum of porous rock.
Benthic organisms—Organisms which live on the bottoms of water
bodies.
Berm—A structure resembling a dike which is used as a means of
physical separation.
415
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BOD,.—An abbreviation representing the amount of oxygen required
for the biological decomposition of dissolved organic solids to
occur under aerobic conditions for five days at 20°C.
Braided stream—A stream with an interlacing network of channels.
Brown-out—A period of reduced illumination resulting from demands
for electric power which exceed generating capacities.
Carbon monoxide (CO)—A very toxic, colorless and odorless gas.
Carrying capacity—A relationship reflecting the number of animals
and/or humans that a given unit of land can support without a
substantial degradation of that land unit's extant conditions.
cfs—An abbreviation for cubic feet per second. It is a unit of
measurement commonly used to describe volume of streamflow.
Dewatering—A process where sewage is reduced in volume by removing
a portion of its water content.
Diurnal—A term used to describe a 24-hour cycle.
Effluent—The liquid that comes out of a treatment plant after
completion of the treatment process.
Emissions—Substances discharged into the air.
Environmental limitations—Those features of a defined area of
land which could be degraded if new land uses were introduced.
Environmental opportunities—Those features of a defined unit of
land which provide distinct advantages to certain introduced land
uses.
Epidemiological—The sum of the factors controlling the presence or
absence of a disease or pathogen.
Eutrophication—A process by which a body of water becomes overly
rich in nutrients and deficient in oxygen.
Fugitive dust/particlesr-Dust and soil particulates carried by winds
away from an earth disturbance.
416
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Gaussian plume model—A mathematical model used to predict the
distribution and dilution of air-borne substances from stationary
sources.
General obligation bonds—Bonds secured by the full faith and
credit and by the general taxing power of the issuer.
Holistic—A view that nature is correctly seen in terms of
interacting wholes that are more than the mere sum of elementary
particles.
Hydrograph—A graphic presentation of quantified streamflow
characteristics.
In-lieu of fees—As used in this document, recreation facility
in-lieu of fees would be payed by residential developers, if they
were not required by local jurisdictions to provide outdoor
recreation facilities within their developments. The monies
collected would be used by local jurisdictions to develop parks
and playgrounds.
Interceptor—Interceptor sewers in a combined system control the
flow of the sewage to the treatment plant. In a storm, they allow
some of the sewage to flow directly into a receiving stream. This
protects the treatment plant from being overloaded in case of a
sudden surge of water into the sewers. Interceptors are also used
in separate sanitation systems to collect the flows from main and
trunk sewers and carry them to the points of treatment.
Intermittent stream—A stream which flows only during a part of a
year. This contrasts with perennial streams which flow all year
and ephemeral streams which carry only stormflows.
Inversion (temperature)—A reversal of the normal atmospheric
temperature gradient.
Isopleth—A line on a map connecting points at which a given
variable has a specified constant value.
417
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Mill levy—An ad valorem tax.
Mini-NEPA laws—State and local laws, such as the California
Environmental Quality Act, which are modeled after the National
Environmental Policy Act to assure environmental review of state
and local actions which might adversely affect the quality of the
environment.
NO, N0_ and NO —Oxides of nitrogen which are significant contri-
£• X
butors to the formation of photochemical smog.
Non-point source—An activity distributed over a wide area that is
a source of pollution.
Nonstructural control measures—Regulations and maintenance
activities which reduce the production of pollutants without
relying on equipment or facilities specifically designed to reduce
the target pollutants.
Ozone (0,)—A major agent in photochemical smog.
Particulate matter—Any material, except uncombined water, that
exist in a finely divided form as a liquid or solid.
Perturbation—As used in this document, a perturbation is a
hypothetical disturbance or change to extant conditions for the
purpose of comparative modeling.
Point source—A stationary, readily identifiable pollution source.
Potable water—Drinkable water.
Precursor—A substance from which another substance is made.
Prototype meteorological day—A day whose quantified weather
characteristics are representative of an area. These characteristics
are used in mathematical models of air pollution conditions.
Radiation fog—A ground fog produced when the dew temperature
(point of condensation) is reached through direct radiation of
ground heat.
418
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Revenue bonds—Bonds secured by a pledge of revenue which is to
be derived from the operation of a public facility.
Rilling—A form of water erosion where very narrow and shallow
furrows are created on exposed ground surfaces.
Riparian corridors—Biotic communities along stream courses used
by wildlife as movement corridors.
Riparian habitat—A streamside biotic community.
Sedimentation—The process of particulates settling out of their
transporting medium, e.g., silt, sand and gravel settling to the
bottom of a stream.
Sediment load—The amount of particulates carried in a transporting
medium.
Seismic activity—Earth shaking and movements.
Septic tank leachate—The incompletely treated liquid component of
sewage processed by a septic tank.
Service/user charges—A regular charge levied on sewer system users
by a responsible agency for the provision of services.
Setbacks—A land use restriction commonly employed for a number of
health, safety and environmental reasons to prevent or limit
construction in a given area, ususally to provide a buffer zone.
Shedding—Load shedding is a prearranged action by electrical power
supplier and its major consumers where voltage is cut back by the
supplier to the consumer or power demand is reduced by the consumer
to prevent system-wide power shortfalls.
Sheet erosion—Soil erosion where water draining from an exposed
ground surface does so in wide, even "sheets" and thus does not
form any rills, rivulets or gullies.
Shortfall—As used in this document, a shortfall is a failure to
meet an energy need.
419
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Shrink-swell—A characteristic of soils containing clay which
describes the range of volumes per unit weight of soil under wet
and dry conditions.
Sludge—Sludge is the solid matter that settles to the bottom,
floats or becomes suspended in the sedimentation tanks and must
be disposed of by filtration and incineration or by transport to
appropriate disposal sites.
SMSA, Standard Metropolitan Statistical Areas—Geographical units
of land established by the U.S. Census Bureau to aid in its population
data collection and analysis activities in urban areas.
Stationary sources—Nonmobile air pollution sources, e.g.,
refineries and factories.
Steppe—An arid, mid-latitude, continental natural region characterized
by vast, flat and treeless expanses.
Strata—Sheets of sedimentary rock or earth covering one another.
Stream channelization—A human activity intended to modify natural
stream channels to increase their volumes of flow.
Structural control measures—Facilities or equipment, such as
wastewater treatment plants, which are specifically designed and
constructed to abate a given pollution problem.
Subsidence—An event or occurrence where the ground surface settles
or sinks to a new level.
Suspended solids—The small particles of solid pollutants which are
present in sewage and which resist separation from the water by
conventional means.
Synergistically—Several discrete agents having the ability to
cooperate such that the total effect is greater than the sum of the
agent's effects taken independently.
Tap fees/Connection fees—Initial fees charged by a sewer agency to
allow connection to a sewer system.
420
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Transition Life Zone—A term categorizing environmental
characteristics found between 5,500 feet and 8,000 feet elevation.
Trickling filter—A support media for bacterial growth, usually a
bed of rocks or stones. The sewage is trickled over the bed so the
bacteria can break down the organic wastes. The bacteria collect
on the stones through repeated use of the filter.
Upper Sonoran Life Zone—A term categorizing environmental
characteristics found between 3,500 feet and 5,500 feet elevation.
Volatilization—A process whereby a liquid is caused to atomize or
evaporate quickly.
Wildfire—Uncontrolled fire in undeveloped areas such as forests,
brushlands and grasslands.
Wind corridors—Stream valleys descending out of the mountains onto
the plains where valley depressions channel downslope winds. These
channeled winds attain higher velocities than winds found elsewhere
in the area due to Venturi effects resulting from the constricting
stream valley landform.
Windrow—Linearly planted, closely-spaced trees.utilized as a wind
barrier.
421
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706. U.S. Department of Agriculture Soil Conservation Service (in co-
operation with Colorado Agricultural Experiment Station), Soil
Survey Boulder County Area, Colorado, U.S. Government Printing
Office, Washington, D.C., January 1975.
707. Davis, R. M., U.S. Department of Agriculture Soil Conservation
Service, "Land Inventory and Monitoring Memorandum - 3," re:
Prime and Unique Farmlands, 15 October 1975.
708. U.S. Department of Agriculture Soil Conservation Service (in co-
operation with Colorado Agricultural Experiment Station), Soil
Survey, Castle Rock Area, Colorado, U.S. Government Printing
Office, Washington, D.C., November 1974.
709. U.S. Department of Agriculture Soil Conservation Service, map
showing "Land Use, Boulder County, Colorado," July 1973.
710. U.S. Department of Agriculture Soil Conservation Service, "General
Soil Map, Boulder County," May 1972.
711. U.S. Department of Agriculture Soil Conservation Service, "General
Soil Map, Jefferson County," June 1972.
712. U.S. Department of Agriculture Soil Conservation Service, "General
Soil Map, Elbert County," July 1972.
713. U.S. Department of Agriculture Soil Conservation Service, "General
Soil Map, Douglas County," June 1972.
439
-------
714. U.S. Department of Agriculture Soil Conservation Service, "General
Soil Map, Arapahoe County," March 1972.
715. U.S. Department of Agriculture Soil Conservation Service, "General
Soil Map, Adams County," April 1972.
716. U.S. Department of Agriculture Soil Conservation Service, land
use map of Douglas County, August 1973.
717. Colorado Department of Agriculture, Colorado Agricultural Sta-
tistics, 1974 Preliminary, 1973 Final, Denver, July 1975.
718. Carey, Merritt, "A Biological Survey of Colorado," U.S.D.A.
Bureau of Biological Survey - North American Fauna #33, 1911.
719. U.S. Department of Agriculture, Economic Research Service, Dy-
namics of Land Use in Fast Growth Areas, 1976.
720. U.S. Department of Agriculture, Economic Research Service, Our
Land and Water Resources - Current and Prospective Supplies of
Uses, 1974.
440
-------
U.S. Geological Survey Publications
801. Department of the Interior, U.S. Geological Survey, Map Showing
Availability of Hydrologic Data, Boulder - Fort Collins - Greeley
Area, Front Range Urban Corridor, Colorado, Reston, Virginia, 1974,
802. Department of the Interior, U.S. Geological Survey, Map Showing
Flood-prone Areas, Boulder - Fort Collins - Greeley Area, Front
Range Urban Corridor, Colorado, Reston, Virginia, 1975.
803. Department of the Interior, U.S. Geological Survey, Land-Use
Classification of the Greater Denver Area, Front Range Urban
Corridor, Colorado, Reston, Virginia, 1975.
804. Not Used.
805. Department of the Interior, U.S. Geological Survey, Map Showing
Availability of Hydrologic Data Published by the U.S. Environ-
mental Data Service and by the U.S. Geological Survey and Cooper-
ating Agencies, Greater Denver Area, Front Range Urban Corridor,
Colorado, Reston, Virginia, 1975.
806. Department of the Interior, U.S. Geological Survey, Map Showing
Potential Gravel Sources and Crushed-rock Aggregate in the Greater
Denver Area, Front RAnge Urban Corridor, Colorado, Reston, Vir-
ginia, 1974.
807. Department of the Interior, U.S. Geological Survey, Maps Showing
the Approximate Configuration and Depth to the Top of the Laramie-
Fox Hills Aquifer, Denver Basin, Colorado, Washington, D.C., 1972.
808. Department of the Interior, U.S. Geological Survey, Generalized
Surficial Geologic Map of the Denver Area, Colorado, Washington,
D.C., 1972.
809. Department of the Interior, U.S. Geological Survey, Map Showing
Outstanding Natural and Historic Landmarks in the Greater Denver
Area, Front RAnge Urban Corridor, Colorado, Reston, Virginia, 1976,
810. Department of the Interior, U.S. Geological Survey, Land-Use
Classification Map of the Boulder - Fort Collins - Greeley Area,
Front Range Urban Corridor, Colorado, Reston, Virginia, 1974.
811. Department of the Interior, U.S. Geological Survey, Map Showing
Potential Sources of Gravel and Crushed-rock Aggregate in the
Boulder - Fort Collins - Greeley Area, Front Range Urban Corridor,
Colorado, Reston, Virginia, 1974.
441
-------
812. U.S. Geological Survey, Map Showing Mined Areas of the Boulder -
Weld Coal Field, Colorado, U.S. Government Printing Office, 1974.
813. Department of the Interior, U.S. Geological Survey, Geologic Map
of the Arvada Quadrangle, Adams, Denver, and Jefferson Counties,
Colorado, 1972.
814. U.S. Geological Survey, "Effect of Mine Drainage on the Quality
of Streams in Colorado, 1971-72," Colorado Water Pollution Con-
trol Commission, Circular No. 21, 1974.
815. U.S. Geological Survey, "Effects of Metal-Mine Drainage on Water
Quality in Selected Areas of Colorado, 1972-73," Colorado Water
Pollution Control Commission, Circular No. 25, 1974.
816. Colorado Water Conservation Board, U.S. Geological Survey map
showing "Index of Flood Plain Information in Colorado, January
1975."
817. U.S. Geological Survey, Lakes in the Greater Denver Area, Front
Range Urban Corridor, Colorado, 1975.
818. U.S. Geological Survey, Map Showing Flood-Prone Areas, Greater
Denver Area, Front Range Urban Corridor, Colorado, Reston, Vir-
ginia, 1975.
819. Smith, Rex 0., Paul A. Schneider, Jrl, and Lester R. Petri,
"Ground Water Resources of the South Platte River Basin in West-
ern Adams and Southwest Weld Counties, Colorado", U.S. Geological
Survey - Water Supply Paper 1658, 1964.
820. Price, Don and Ted Arnow, "Summary Appraisals of the Nation's
Ground-Water Resources - Upper Colorado Region", U.S. Geological
Survey Professional Paper 813-C, 1974.
821. McConaghy, J. A. e± aL., "Hydrogeologic Data of the Denver Basin,
Colorado", U.S. Geological Survey, Denver, 1964.
442
-------
Miscellaneous Publications
901. Engineering Consultants, Inc. (ECE) and the Toups Corporation,
Proposal for the Study of Land Treatment and Water Rights for
Denver Metro Area, Denver, May 1974.
902. Heiss, F. W., Denver Metropolitan Study, Research and Action Plan
1976-1977.
903. Platte River Development Committee, South Platte River Development,
Project Description and Budget; Maps; Newspaper Articles.
904. Denver Urban Observatory, Denver Urban Observatory Five-year
Report, 1970-1975, Denver, 1976.
905. Denver Urban Observatory, The Economic Base of Denver: Implications
for Denver's Fiscal Future and Administrative Policy, Boulder, 1974.
906. U.S. Department of Housing and Urban Development, Proposal for
Denver Metropolitan Environmental Analysis, Washington, 1976.
907. Resource Planning Associates, Inc., 208 Technical Memorandum 302,
Development Criteria to Keep Impact Within Acceptable Levels,
Cambridge, Massachusetts, 19 March 1976.
908. Benedict, H. M., C. J. Miller, and J. S. Smith, Stanford Research
Institute, "Assessment of Economic Impact of Air Pollutents on
Vegetation in the United States: 1969 and 1971", prepared for
coordinating Research Council and EPA, July 1973.
909. Millecan A. A., California State Department of Food and Agriculture,
WA Survey and Assessment of Air Pollution Damage to California
Vegetation 1970 through 1974, April 1976.
910. Resource Planning Associates, Inc., Technical Memorandum 4-1,
Water Duality Analysis of the Local and Regional Forecasts,
(undated, attribution uncertain.)
911. Resource Planning Associates, Inc., 208 Technical Memorandum 6-1,
Detailed Environmental Impact Evaluation Plan, Cambridge, Mass.,
January 1976.
912. Resource Planning Associates, Inc., 208 Task 6-2, Evaluate Basin
Environmental Impacts - Cherry Creek Basin, Preliminary Discussion
Draft, Cambridge, Mass., February 1976.
913. National Academy of Public Administration, Denver Metropolitan
Study, Research and Action Plan, 1976-1977, Denver, 1976.
914. Monarchi, David E. and Ken D. Prince, "Forecasting with the CPE
Model - Some Practical Experiences", Colorado Population Trends,
Vol. 4, No. 4, Boulder, Fall 1975.
443
-------
915. Business Research Division, University of Colorado, "County Popula-
tion Projections - 1970 - 2000", Colorado Population Trends, Vol.
5, No. 1, Boulder, Winter 1976.
916. CH2M Hill and Leonard Rice Consulting Water Engineers, Inc.,
Task Memorandum 6-4, D09523F0.40, Technical Impacts of First
Round Alternatives, Denver, 30 July 1976.
917. CH2M Hill and Leonard Rice Consulting Water Engineers, Inc.,
Task Memorandum 6-3, D09523F0.30, First Round Alternatives,
Denver, 30 July 1976.
918. The Research Group, Inc., A Report to the Denver Regional Council
of Governments Assessing Areawide Water Pollution Management Is-
sues, Attitudes of Public Officials, and Alternative Approaches to
Water Quality Planning and Management for Implementation of the
Denver Regional Clean Water Program, Atlanta, April 1976.
919. The Research Group, Inc., 208 Institutional Memorandum-1, An
Assessment of Existing Water Quality Management Goals, and the
Development of Suggested Regional Water Quality Goals for the
DRCOG, Atlanta, June -1976 (with August 1976 corrections).
920. The Research Group, Inc., 208 Institutional Memorandum-2, Re-
porting on: (1) Areawide Water Pollution Management Issues,
Attitudes of Public Officials and Alternative Approaches to Water
Quality Planning and Management for Implementation of the Denver
Regional Clean Water Program; (2) Preparation for and Participation
in the Institutional Workshop at the Botanic Gardens on April 22,
1976; and (3) Analysis of the Output from the Institutional Work-
shop, Atlanta, June 1976.
921. The Research Group, Inc., 208 Institutional Memorandum-3, Reporting
on: (1) The Existing Institutional System for Dealing with Water
Quality Management in the Denver Region; (2) Alternative Institu-
tional Systems for Dealing with Future Management Programs and
Issues; and (3) A System for Evaluating the Institutional Alter-
natives, Atlanta, June 1976 (with August 1976 corrections).
922. Colorado Division of Planning, The Division of Planning: A Profile,
Information Services Report Number 1, Denver, April 1976.
923. Colorado Division of Planning, Colorado's Regions, Information
Services Report Number 2, Denver, April 1976.
924. Taylor, G. C., Water Demand Projections, Project 5152, Chapter VI,
28 July 1975.
925. Denver Metropolitan Study, The Denver Region Citizen-Voter: RE-
ported Ideas and Concerns, September 1976.
444
-------
926. Western, Warren et al., Voter Attitudes in Denver, Denver Urban
Observatory, 1976.
927. Cristiano, C. R., Water Conservation Measures, Project 5152
Chapter VIII, 30 June 1975.
928. Denver Urban Observatory, Publications list, 13 September 1976.
929. Milliken, J. Gordon (DRI), Demonstration of the Evaluation/Decision
Process, first draft, Chapter XXI, 18 July 1975.
930. Three newspaper articles, unspecified sources.
931. Peterson, Russell W. (CEQ), Memorandum for heads of agencies:
Analysis of Impacts on Prime and Unique Farmland in Environmental
Impact Statements, 30 August 1976.
931a. Objectives of Metro EIS.
932. Description of Denver facilities being planned.
933. Thompson, C. R., G. Kats, and J. W. Cameron, "Effects of Ambient
Photochemical Air Pollutents on Growth, Yield, and Ear Characters
of Two Sweet Corn Hybrids", Journal of Environmental Quality,
Volume 5 No. 4, October-December 1976.
934. Socio Economic Systems, Inc., Service Area Population Projections
for the Boulder EIS, personal communication, letter to EPA,
9 November 1976.
935. Leonard Rice Consulting Engineers, Inc., "Water Engineering in
Colorado", January 1975.
936. Colorado Department of Health, Water Quality Control Commission,
"Proposed Water Quality Standards for Colorado", 28 October 1976.
937. Suhrbier, John H., Cambridge Systematics, Inc., letter to Robert
Kessler, U.S. Department of Transportation, re: "DOT Office of
Environmental Affairs Contract, 'Costs and Administrative Support
for Implementation of Air Quality Transportation Controls1.",
18 October 1976.
938. Suhrbrier, John H., Cambridge Systematics, Inc., letter to Robert
D. Siek, Colorado Department of Health, re: DOT/EPA study in
Denver, 18 October 1976.
939. Engineering-Science, Inc., An Engineering Study for Water Control
and Recycle, as presented to the U.S. Atomic Energy Commission,
Rocky Flats Plant, Golden, Colorado, 21 July 1974.
940. Inter-County Regional Planning Commission, Metropolitan Water Study
Inventory Map showing "Divisions, Storage and Sewage Plant Loca-
tions", 1965.
445
-------
941. State of Colorado, Department of Natural Resources, Division of
Wildlife, "Colorado Breeding Data for Select Bird Species",
Second Revision, May 1976.
942. State of Colorado, Department of Natural Resources, Division of
Wildlife, The Strategy of Today, For Wildlife Tomorrow, Vol. 1,
1975 - 1980, 1974.
943. Leonard Rice Consulting Water Engineers, Inc., Botham, Leslie H.,
memo re: "Status of Flood Hazard Area Mapping in Colorado",
16 December 1976.
944. Botham, L. H., Leonard Rice Consulting Water Engineers, Inc.,
"Status of FIA Studies", 14 December 1976.
945. Colorado Water Conservation Board, "Status of Flood Hazard Area
Designations".
946. Commerce City, "Environmental Assessment, Dahlia Street Bridge",
May 1975.
947. Leonard Rice Consulting Water Engineers, Inc., Wood Brothers
Homes Water Rights Evaluation, 27 July 1973.
948. Ingraham, E. W., "Lead Time for Assessing Land Use: A Case Study",
Science, 194, p. 17, 1 October 1976.
949. Department of Operational Services, Plants Division, 1975 Annual
Report, City of Westminster, Colorado.
950. Northglenn Policy Statement on Cooperative Use of Land and Water
Resources.
951. Uranesh, G., et al., Colorado Water Law and Clean Water by Irriga-
tion with Sewage Effluent.
952. Colorado Air Pollution Control Regulations.
953. Johnston, W. W., memo re: "Basin/Subbasin Population Allocations
for HSP Modeling", to J. Hibbert, WRS, 1 September 1976.
954. Anderson, Gerald A., Systems Applications, Inc., (SAI), .Report on
Status of Photochemical Modeling, SAI Report No. ES76-92 prepared
for EPA, 22 November 1976.
955. Systems Applications, Inc., A Study of the Effect of Changes in the
Spatial Distribution of Emissions, SAI Report NO. ES76-92 prepared
for EPA, 22 November 1976.
446
-------
956. See Reference 114.
957. Gruen + Gruen Associates, Bibliography of Denver EIS.
958. CH2M Hill and Leonard Rice Consulting Water Engineers, Inc., Task
Memorandum 3-1, 3-2, 3-3, 4-la through 4-lf, 4-2a through 4-2e,
5-1, 5-3, 5-5, 6-1 thorugh 6-4, 7-3, 8-1 through 8-6; Institutional
Memorandum 1, 2, and 3; Public Involvement Memorandum 1 and 2,
Financial Memorandum 1-1, 1-2, and 3; Technical Memorandum 2-5,
3-2, 4-1, 6-1, 2-3, 4-3, and 5.
959. CH2M Hill and Leonard Rice Consulting Water Engineers, Inc., 208
Program Profile, Point Sources, Urban Runoff, and Agricultural
Irrigation Return Flow, August 1976.
960. Boulder County, "Ponding Ordinances", in Subdivision Regulations.
961. City of Arvada, Engineering Department, "Basin Ordinances", in
Standard Specifications & Drawings for Design & Construction.
962a. Colorado Energy Research Institute, Summary Report, January 1976.
962b. Colorado Energy Research Institute, Future Energy Alternatives
for Colorado, Vol. I, January 1976.
963. Urban Drainage and Flood Control District, Activity Summary,
March 1976.
964. Resource Planning Associates, Summary of" Interview Findings,
Fishery Potential for Denver Regional Streams, 10 December 1976.
965. Colorado Land Use Commission, Colorado Land Use Map Folio,
January 1974.
966. Krus, John, South Lakewood Sanitation District, personal communi-
cation, 8 February 1977.
967. Dravde, Alwin, Bookkeeper, South Lakewood Sanitation District,
personal communication, 8 February 1977.
968. Colorado Legislature S.B. 142, "Nongame and Endangered Species
Conservation Act," 1973.
969. Tully, R. J., "Endangered Wildlife", in Colorado Outdoors, Colo-
rado Division of Wildlife, March-April 1973.
970. Colorado Energy Research Institute, Future Energy Alternatives
for Colorado, January 1976.
971. Jenkins, David, "Ugly Scars Mar Nature Preserve", in The Denver
Post, p. 33, 25 November 1976.
447
-------
972. Signs, Cheryl, Water Resource Engineer, City of Westminster,
personal communication, 22 February 1977.
973. Schwochow, S. D., R. R. Shroba, and P. C. Wicklein, "Sand, Gravel
and Quarry Aggregate Resources, Colorado Front Range Counties",
in Colorado Geological Survey, Department of Natural Resources,
Denver, 1974.
974. Pearl, Richard Howard, "Geology of Ground Water Resources in
Colorado", in Colorado Geological Survey, Department of Natural
Resources, Denver, 1974.
975. Adams, W. and Ed Mansfield, "Engineering Geology Case Histories
No. 8, Engineering Seismology: The Works of Man", prepared for
the Division on Engineering Geology of the Geological Society of
America, Boulder, 1970.
976. McCall, Ellingson, & Merrill, Inc., City of Longmont - Sewage
Facilities Report, prepared for EPA, February 1975.
977. Pankratz, Howard, "Reward is Bankruptcy: Agribusiness Problems
Grow", in The Denver Post, p. 21, 27 February 1977.
978. Lundahl, Richard P., Project Director of Land and Water Resources
Management, City of Northglenn, personal communication, letter of
10 February 1977.
979. U.S. Department of Health, Education and Welfare, Air Quality
Criteria for Photochemical Oxidants, March 1970.
980. U.S. Department of Health, Education and Welfare, Air Quality
Criteria for Carbon Monoxide, March 1970.
981. U.S. Department of Health, Education and Welfare, Air Quality
Criteria Document, January 1969.
982. Hendricks, D. W. and M. H. Bluestein, "Response of South Platte to
Effluent Limitations", in Journal of the Environmental Engineering
Division, ASCE, Vol. 102, August 1976.
983. Brown, Lester R., "The Urban Prospect: Reexamining the Basic
Assumption" in Environmental Comment, Washington, D.C., December
1976.
983a. Wisconsin, State of, Public Service Costs and Development, State
Planning Office, September 1975.
984. Colorado, State of, Department of Agriculture, Colorado Crop
Census, 1976.
985. Colorado, State of, Division of Planning, "County Population
Projections - 1970 to 2000" in Colorado Population Trends,
Winter 1976,
448
-------
986. Colorado State University, Environmental Resources Center, Physical
and Economic Effects on the Local Agricultural Economy of Water
Transfer to Cities, October 1976.
987. Denver Urban Observatory, The Economic Base of Denver: Implica-
tions for Denver's Fiscal Future and Administrative Policy, Denver,
1974.
988. Farm and Land Realtor, September 1976.
989. Gruen Gruen + Associates and Sedway/Cooke, Approaches Towards a
Land Use Allocation System for California's Coastal Zone - A
Report to the Resources Agency, State of California, October 1971.
990. Hoyt, Homer, The Changing Principles of Land Economics, Urban Land
Institute, Washington, D.C., 1968.
991. Security Pacific Bank, Monthly Summary of Business Conditions,
September 1976.
992. Snyder, Robert W., Agricultural Land Use Policy: Some Perspectives
and Observations, University of Minnesota, Agricultural Extension
Service, 1976.
993. Systems Applications, Inc., Denver Regional Planning Overview
(Preliminary Draft), prepared for the EPA, 24 November 1976.
994. 'U.S. Department of Commerce, Bureau of the Census, 1970 Census of
Population: State Economic Areas, Washington, D.C., 1970.
995. U.S. Department of Commerce, Bureau of the Census, 1970 Census of
Population: General Social and Economic Characteristics (U.S.
Summary), Washington, D.C., 1970.
996. U.S. Department of Commerce, Bureau of Economic Analysis, Survey
of Current Business.
966a. U.S. Department of Commerce, Bureau of the Census, Current
Population Reports; Farm Population, September 1976.
966b. U.S. Department of Commerce, Bureau of the Census, 1969 Census
of Agriculture (U.S. Summary), Washington, D.C., 1971.
997. Jones, S., "Public Response to Air Pollution in the Denver Area"
University of Colorado Environmental Council, pp. 21-52, 1974.
998. Anderson, G.E., etal, A Study of Air Quality in the Denver Metro-
politan Region (1974-2000), Systems Applications Incorporated
report No. ES77-222 for US EPA Region VIII, May 1977.
999. Meyer, H.E., "Shootout at the Johns-Manville Corral", Fortune,
October 1976.
449
-------
Local Agency Plans and Planning Documents
1000. Alonso, William, "The Economics of Urban Size" in Papers of the
Regional Science Association, European Congress, London, England,
p. 67-83, 1970.
1001. Denver Water Department, Metropolitan Water Requirements and
Resources, 1975-2010, Prepared for the Colorado State Legislature
Metropolitan Denver Water Study Committee, January 8, 1975.
1002. U.S. Council on Environmental Quality, The Growth Shapers, Prepared
by Urban Systems Research and Engineering, Inc., May 1976.
1003. Adams County Department of Planning and Development, Adams
County Comprehensive Plan, Brighton, Colorado, 1975.
1004. Arapahoe County Planning Department, Urban Area, Arapahoe County
Comprehensive Plan, Littleton, Colorado, November 1972 including
amandments through September 1976.
1005. Arvada Planning Commission, The Comprehensive Plan for the City
of Arvada, Arvada, Colorado, October 1973.
1006. Aurora Department of Planning and Community Development, Aurora/
The People Within - A Demographic Study, Aurora, Colorado
October 1975.
1007. Aurora Department of Planning and Community Development, Prelim-
inary Revised Population Projections 1975-2000, Aurora, Colorado,
September 1975.
1008. Aurora Department of Planning and Community Development, Long
Range Planning Division, Growth in Aurora, Population and Vacancy
Summary, Aurora, Colorado, July 1976.
1009. Aurora Planning Department, A Report on Economic Analysis of the
City of Aurora, Aurora, Colorado, November 1973.
1010. Aurora Planning Department, A Report on Population Growth in the
City of Aurora, Aurora, Colorado, March 1973.
1111. Aurora Planning Department, The Land Use Plan for the City of
Aurora, Aurora, Colorado, June 1974.
1112. Boulder Department of Community Development, Boulder Valley Compre-
hensive Plan, Boulder, Colorado, 1970.
450
-------
1113. Broomfield, Comprehensive Master Plan - City of Broomfield (by
CNC/NHPQ), Broomfield, Colorado, August 1972 including amendments
through August 1973.
1014. Commerce City Planning Staff and Citizens' Review Committee, Land
Use Plan 1975-2000 - Second Draft, Commerce City, Colorado, June
1976.
1015. Commerce City Planning Staff, Existing Land Use Map, Commerce
City, Colorado, June 1976.
1016. Denver Planning Office, Denver 1985 - A Comprehensive Plan for Com-
munity Excellence, Denver, Colorado, January 1971.
1017. Denver Planning Office, Neighborhood Planning, Denver, Colorado,
1976.
1018. Denver Planning Office, Preliminary Comprehensive Planning Goals _
and Objectives for Denver - A Report for Information and Discussion,
Denver, Colorado, September 1976.
1019. Denver Planning Office, Trends and Issues - Land Use and Physical
Development in Denver - A Report for Information and Discussion,
Denver, Colorado, January 1976.
1020. Denver Planning Office, Planning Services Division, 1975 Census of
Housing and Land Use, Denver, Colorado, July 1975.
1021. Denver Planning Office, Planning Services Division, 1976 Population
Estimate, Denver, Colorado, June 1976.
1022. Douglas County Planning Department, Land Use Plan for Douglas
County, Colorado, Castle Rock, Colorado, 1974.
1023. Edgewater, Comprehensive Plan (by Small, Cooley and Associates),
Denver, Colorado, 1967.
1024. Englewood, A Place to Live, Englewood, Colorado, January 1970.
-------
1025. Englewood, Population and Land Use, Englewood, Colorado, January
1970.
1026. Federal Heights, Federal Heights Zoning Information Map, Federal
Heights, Colorado, February 1966 including revisions through
November 1973.
1027. Golden, A Comprehensive Plan for Golden, Colorado (by Havekost/
Waldman & Associates), Denver, Colorado, April 1971.
1028. Golden, Draft Land Use and Housing Component of Comprehensive Plan,
Golden, Colorado, 1976.
1029. Greenwood, Greenwood Village Master Plan (by Carl A. Worthington &
Associates), Boulder, Colorado, February 1973.
1030. Jefferson County Planning Department, II Comprehensive Plan Policies,
(under consideration for adoption), Golden, Colorado.
1031. Jefferson County Planning Department,. Future Land Use Map, Golden/
Ralston Community, Golden, Colorado, September 1974.
1032. Jefferson County Planning Department, Future Land Use Map, Mountain
Area, Jefferson County, Colorado, Golden, Colorado, 1971.
1033. Jefferson County Planning Department, Future Land Use Map, Northeast
Jefferson County Area, Golden, Colorado, July 1971.
1034. Jefferson County Planning Department, Advanced Planning Section,
The Golden-Ralston Comprehensive Plan, Golden, Colorado, 1974.
1035. Lakewood Department of Community Development, Concept Lakewood: A
Development Plan and Planning Process, Lakewood, Colorado, March 1975.
1036. Northglenn Department of Community Development, City of Northglenn
Zoning District Map, Northglenn, Colorado, January 1973 including
amendments through 25 October 1976.
452
-------
1037. Sheridan, Management Study for the City of Sheridan3 (by Parker &
Associates, Inc.), Denver, Colorado, 15 January 1974.
1038. Sheridan, Official Zoning Map - City of Sheridan, Colorado, (by
Parker & Associates, Inc.), Denver, Colorado, June 1972 including
revisions of January 1975.
1039. Thornton, Thornton: A Comprehensive Plan, Thornton, Colorado, March
1975.
1040. Thornton, City of Thornton Economic Base Analysis (by Harmon,
O1Donne11 & Henninger Associates, Inc.), Denver, Colorado, 10 May
1974.
1041. Westminster City Council, Ordinance Numoer 95Q3 Series of 19763
Westminster, Colorado, June 1976.
1042. Westminster Planning Department, Annexation Criteria, Westminster,
Colorado.
1043. Westminster, Comprehensive Plan - City of Westminster (by Small,
Cooley and Associates), Westminster, Colorado, 1973.
1044. Stromberg and Davidson, personal communication, December 1976.
1045. Zwagerman, personal communication, 12 January 1977.
1046. Fleming, R., Planning Director, Adams Co., personal communication,
13 January 1977.
-------
DISTRIBUTION LIST
Federal Agencies
Regional Forester
U.S. Forest Service
Denver, Colorado
Federal Highway Administration
Denver, Colorado
State Conservationist
U.S. Soil Conservation Service
Denver, Colorado
Regional Director
U.S. Department of Health,
Education and Welfare
Denver, Colorado
Corps of Engineers
Omaha District
Omaha, Nebraska
Regional Administrator
U.S. Department of Housing
and Urban Development
Denver, Colorado
Director (18)1
Environment Project Review
U.S. Department of the Interior
Office of the Secretary
Washington, D.C.
State Director
Farmers Home Administration
U.S. Department of Agriculture
Denver, Colorado
Mr. Dean L. Frohardt
General Services Administration
Denver, Colorado
Council on Environmental Quality (5)2
Washington, D.C.
State Agencies
State Clearinghouse (15)3
Office of State Planning
Denver, Colorado
Air Pollution Control Division
Colorado Department of Health
Denver, Colorado
Water Quality Control Division
Colorado Department of Health
Denver, Colorado
Mr. Jim Monahan
Governor's Office
County Agencies
Division of Planning
Denver County
Department of Health
Adams County
Division of Planning
Boulder County
Division of Planning
Jefferson County
Division of Planning
Douglas County
Division of Planning
Arapahoe County
1 18 copies provided for Department of the Interior offices
2 5 copies provided for Council on Environmental Quality
3 15 copies provided to State Clearinghouse for review by state agencies
455
-------
Local Agencies
Planning Director
City of Arvada
Planning Director
City of Aurora
Planning Director
City of Boulder
Planning Director
City of Broomfield
Planning Director
City of Cherry Hills Village
Planning Director
City of Commerce City
Planning Director
City of Denver
Chairman, Planning Commission
City of Edgewater
Director of Community Development
City of Englewood
Chairman, Planning Commission
City of Federal Heights
Public Works Department
City of Broomfield
Planning Director
City of Glendale
Assistant City Manager/Planner
City of Golden
Planning Director
City of Greenwood Village
Planning Director
City of Lakewood
Planning Director
City of Littleton
Planning Director
City of Northglenn
Planning Director
City of Sheridan
Planning Director
City of Thornton
Planning Director
City of Westminster
Planning Director
City of Wheat Ridge
Housing Authority of Denver
Denver, Colorado
Denver Urban Renewal Authority
Denver, Colorado
Parks and Recreation Department
Denver, Colorado
Board of Water Commissioners
Denver, Colorado
Grant Applicants
Mr. Andy McGown
City Manager
City of Englewood
Mr. Wayne T. Ward
President, Board of Directors
South Lakewood Sanitation District
Mr. Gale D. Christy
City Manager
City of Littleton
Honorable William H. McNIchols, Or.
Mayor, City and County of Denver
Mr. Allen L. Williams
Chairman, Board of Directors
South Adams County Water and
and Sanitation District
456
-------
Grant Applicants (continued)
Mr. William E. Korbitz
Manager
Metropolitan Denver Sewage
Disposal District #1
Mr. Steve Garman
City Manager
City of Westminster
EIS Advisory Cormrittee
Mr. David Pampu (5)1
Denver Regional Council
of Governments
Mr. Leonard Slosky
Colorado Department of Highways
Mr. Kenneth W. Webb
Colorado Water Quality Control Division
Mr. Gary Broetzman
State 208 Coordinator
Governor's Office
Mr. Warner Reeser
Colorado Air Pollution Control Division
Ms. Toni Worcester
League of Women Voters of
Metro Denver
Mr. Larry Smith
Federal Highway Administration
Colorado Division Office
Mr. Halter Kelm
U.S. Department of Housing
and Urban Development
Denver, Colorado
Mr. Ken Slyziuk
Regional Transportation District
Denver, Colorado
Mr. Bob Moore
Bureau of Land Management
Denver, Colorado
Local Elected Officials
James Covey, Chairman
Adams County Commissioners
.John J. Nicholl, Chairman
Arapahoe County Commissioners
Margaret B. Markey, Chairwoman
Boulder County Commissioners
Harold V. Cook
Deputy Mayor and Chairman,
County Commissioners
Joanne Paterson, Chairman
Jefferson County Commissioners
Donald L. Pel and
Mayor, City of Arvada
Fred Hood
Mayor, City of Aurora
Frank Buchanan
Mayor, City of Boulder
William Thornton
Mayor, Town of Bow Mar
Guy R. Sanders
Mayor, City of Brighton
Walter P. Spader
Mayor, City of Broomfield
Beth Jenkins
Mayor, Cherry Hills Village
1 5 copies provided to Denver Regional Council of Governments
457
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Local Elected Officials (continued)
Allen L. Williams
Mayor, City of Commerce City
Don Wise
Mayor, City of Edgewater
James L. Taylor
Mayor, City of Englewood
Lester M. Bauer
Mayor, Town of Federal Heights
George Garson
Mayor, City of Glendale
David Crawford
Mayor, City of Golden
Harold Patton, Jr.
Mayor, Greenwood Village
James J. Richey
Mayor, City of Lakewood
Harold Meyer
Mayor, City of Littleton
Gail Molinaro
Mayor, Town of Morrison
Alvin B. Thomas
Mayor, City of Northglenn
Wilfred D. Corbin
Mayor, City of Sheridan
Anthony E. Richter
Mayor, City of Thornton
Vi June
Mayor, City of Westminster
Frank Stites
Mayor, City of Wheat Ridge
John G. Campbell
County Commissioner
Brighton, Colorado
Charles A. Pitts
County Commissioner
Littleton, Colorado
John P. Murphy
County Commissioner
Boulder, Colorado
James J. Nolan
City Councilman
Denver, Colorado
Robert F. Clement
County Commissioner
Golden, Colorado
Thomas G. Thomas
Councilman
Arvada, Colorado
Dennis Champine
Councilman
Aurora, Colorado
Robert G. Trenka
Councilman
Denver, Colorado
Doris Durdy
Mayor Pro Tern
Brighton, Colorado
Norman A. Smith
Councilman
Broomfield, Colorado
Marjorie Christiansen
Councilwoman
Commerce City, Colorado
George N. Drake
Councilman
Edgewater, Colorado
Douglas T. Sovern
Councilman
Englewood, Colorado
458
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Local Elected Officials (continued)
Public Interest Groups
Arthur J. Tice
Councilman
Federal Heights, Colorado
Lu Ella Terry
Councilwoman
Glendale, Colorado
Ruben Hartmeister
Councilman
Golden, Colorado
Alfred W. Vitt
Councilman
Greenwood Village, Colorado
Don DeDecker
Councilman
Lakewood, Colorado
Brad Stelling
President Pro Tern of Council
Littleton, Colorado
Harold T. Hodges
Councilman
Northglenn, Colorado
Jerrold W. Todd
Councilman
Sheridan, Colorado
Joseph E. McCloskey
Councilman
Thornton, Colorado
Fred Allen
Councilman
Westminster, Colorado
Robert G. Howard
Alderman
Wheat Ridge, Colorado
Colorado Open Space Council (5)1
Denver, Colorado
Rocky Mountain Center on Environment
Denver, Colorado
Thome Ecological Institute
Boulder, Colorado
Colorado Wildlife Federation
Boulder, Colorado
Zero Population Growth
Denver, Colorado
National Wildlife Federation
Washington, D.C.
Environmental Action Committee
Denver, Colorado
Environmental Impact Assessment
Project
Washington, D.C.
Mr, Mohamed Lel-Ashry
Environmental Defense Fund
Denver, Colorado
PREACT
Denver, Colorado
Friends of the Earth
Denver, Colorado
League of Women Voters of Colorado (5)2
Denver, Colorado
League of Women Voters of
Arapahoe County
Denver, Colorado
League of Women Voters of Boulder
Boulder, Colorado
1 5 copies provided to Colorado Open Space Council
2 5 copies provided to League of Women Voters of Colorado
459
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Public Interest Groups (continued)
Special Associations
League of Women Voters of Denver
Denver, Colorado
League of Women Voters
of Jefferson County
Sierra Club
Denver, Colorado
The Wilderness Society
Denver, Colorado
Colorado Aiken Audubon Society
Denver, Colorado
Plan Boulder
Boulder, Colorado
Plan Jeffco
Lakewood, Colorado
Trout Unlimited
Denver, Colorado
Historic Denver
Denver, Colorado
Keep Colorado Beautiful
Denver, Colorado
Plan Metro Denver
Denver, Colorado
Denver Parks and Recreation
Foundation
715 South Franklin
Denver, Colorado 80209
Adams County Chamber of Commerce
Denver, Colorado
American Issues Forum of Denver
Denver, Colorado
American Lung Association
of Colorado
Denver, Colorado
American Water Works Association
Denver, Colorado
American National Cattlemen's
Association
Denver, Colorado
Asphalt Institute
Denver, Colorado
Association of Commerce and Industry
Denver, Colorado
Building & Construction Trades
Council of Colorado
Denver, Colorado
Citizens for Sensible Water Use
Denver, Colorado
Colorado Association of
Wheat Growers
Denver, Colorado
Colorado Automobile Dealers
Association
Denver, Colorado
Colorado Health Care Association
Denver, Colorado
Colorado Heart Association
Denver, Colorado
460
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Special Associations (continued)
Colorado Medical Society
Denver, Colorado
Colorado Pollution Control Association
Denver, Colorado
Colorado Public Expenditure Council
Denver, Colorado
Colorado Public Interest
Research Group, Inc.
Denver, Colorado
Mr. Howard Hicks
Denver Chamber of Commerce
Denver, Colorado
Downtown Denver, Inc.
Denver, Colorado
Englewood-United Suburban
Chamber of Commerce
Englewood, Colorado
Farmers Union
Denver, Colorado
Golden Chamber of Commerce
Golden, Colorado
Home Builders Association
of Metropolitan Denver
Denver, Colorado
Independent Automobile Dealers
Association of Colorado
Denver, Colorado
Arvada Chamber of Commerce
Arvada, Colorado
Aurora Chamber of Commerce
Aurora, Colorado
Brighton Chamber of Commerce
Brighton, Colorado
Brootnfield Chamber of Commerce
Broomfield, Colorado
Boulder Chamber of Commerce
Boulder, Colorado
Evergreen Chamber of Commerce
Evergreen, Colorado
Littleton Chamber of Commerce
Littleton, Colorado
Westminster Chamber of Commerce
Westminster, Colorado
Lakewood Chamber of Commerce
Lakewood, Colorado
South Denver Chamber of Commerce
Denver, Colorado
Wheat Ridge Chamber of Commerce
Wheat Ridge, Colorado
Legis 50
Englewood, Colorado
Lyon Collins and Company
Denver, Colorado
Metropolitan Denver Retail
Merchants Association
Denver, Colorado
National Environmental
Health Association
Environmental Problems Committee
Denver, Colorado
Colorado Energy Research Institute
Golden, Colorado
American Society of Landscape
Architects
Denver, Colorado
461
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Special Associations (continued)
Arapahoe Medical Society
Englewood, Colorado
Center for Research and Education
Denver, Colorado
Colorado Municipal League
Denver, Colorado
Others
Mr. Ron Otsaki
Commerce City, Colorado
Ms. Marcy Abling
Arvada, Colorado
Urban Conservatory
Denver, Colorado
Denver Research Institute
University of Denver
Denver, Colorado
Metro Denver Urban Coalition
Denver, Colorado
Mr. DeWitt John
Denver, Colorado
Mr. J. K. Smith
%Colorado Counties
Denver, Colorado
Mr. Jay D. Jurie
CARA
Denver, Colorado
Ms. Marg Ann Barton
Denver, Colorado
Ms. Darleen Ekland
Denver, Colorado
Mr. John Bermingham
Denver, Colorado
Ms. Ann Herbert
Wheat Ridge, Colorado
Mr. Chuck Hillestad
Denver, Colorado
Mr. Jack Anthony
PARC
Denver, Colorado
Mr. Bill Lament, Jr.
Boulder, Colorado
Ms. Kay Collins
Conservation Library
Denver Public Library
Denver, Colorado
Jefferson County Open Space
Golden, Colorado
PLAN CD Newsletter
Bureau of Community Services
Denver, Colorado
Community Design Center
University of Colorado at Denver
Denver, Colorado
Mr. Belmont Evans
Community Noise Control Association
State Health Department
Denver, Colorado
Ms. Carol Carl in
Lakewood, Colorado
Mr. Mike Moore
Evergreen, Colorado
Mr. Dwight Filley
Denver, Colorado
Ms. less McNulty
Boulder, Colorado
Ms. Mikki Lofft
Denver, Colorado
Ms. Susan Thornton
Littleton, Colorado
Ms. Vim K. Wright
Denver, Colorado
Mr. Dick Morrow
Wheat Ridge, Colorado
462
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Additions to List Since Draft EIS
Federal Energy Administration
Lakewood, Colorado
Mr. Al Meiklejohn
State Senator
District 16
Arvada, Colorado
Mr. J. Zohn, P.E., Director
Wastewater Management Division
Denver Department of Public Works
Mr. Richard L. Gerstberger, P.E.
Director of Utility Operations
City of Thornton
Mr. Philip A. Overeynder
208 Coordinator
Northwest Colorado Council of
Governments
Mr. Capp F. Shanks, Or.
Governmental Liaison
Jefferson County Board of Realtors
Mrs. N. J. Besch
Arvada, Colorado
Mr. David R. Cogley
Wilmington, Maryland
Mr. Cal Harvey
Denver, Colorado
Mr. Harry Parmenter and
Mrs. Betty Parmenter
Arvada, Colorado
Mr. Clarence Paquet
Denver, Colorado
Mr. George R. Hilt
Denver, Colorado
Mr. Tony Seese-bieda
The Brighton Blade
Brighton, Colorado
Mr. Kenneth Balcomb
Delaney & Balcomb
Attorneys at Law
Glenwood Springs, Colorado
Dr. Val Veirs
The Colorado College
Colorado Springs, Colorado
Mr. Donald F. Allard
Arvada Deputy City Manager
Arvada, Colorado
Mr. Richard P. Lundahl
Director of Public Works
City of Northglenn
Mr. C. W. Reitler, Chairman
Lakewood Board of Water and
Sewer Commissioners
Mr. Rik Toren
Chairman
GOP Denver Water
Task Force
Mr. Harris Sherman
Chairman, Water Quality Control
Commission
Mr. Robert A. Close
Arvada, Colorado
Mr. Dan Chiras
Lakewood, Colorado
Mr. L. J. Hart
Denver, Colorado
Mr. Byron L. Johnson
Denver, Colorado
Mr. David A. Wicks
Denver, Colorado
Mr. Rich Ferdinandsen
Broomfield, Colorado
Mr. Andy Andrews
Littleton, Colorado
Ms. Denise Dragoo
St. Louis, Missouri
Mr. Richard D. Cunningham
Lexington, Maine
463
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Mr. Rob Williams
CH2M Hill
Denver, Colorado
Mr. William A. Luce, P.E.
Nielsen, Maxwell & Wangsgard
Salt Lake City, Utah
Mr. Jim Chamie
South Dakota State University
Brookings, South Dakota
Mr. Frank J. Rozich, Director
Colorado Water Quality Control
Division
Ms. Diane Hammond
Industrial Economics
University of Denver
Ms. Ruth Wright
Colorado Water Quality Control
Commission
Mr. Leroy Tobler
Denver, Colorado
Mr. Paul R. Cockrel
Robinson - Robinson
Attorneys at Law
Ms. Martha B. Taylor
Calkins, Kramer, Grimshaw &
Marring
Attorneys at Law
Denver, Colorado
Wright-McLaughlin Engineers
Denver, Colorado
Colorado Wildlife Federation
Denver, Colorado
Mr. Lloyd Gronning
City of Thornton
Thornton, Colorado
Ms. Micki Barnes
Colorado Department of Health
Denver, Colorado
Mr. Roland C. Fischer
Colorado River Water Conservation
District
Glenwood Springs, Colorado
Mr. John Colt
Adams County Planning Department
Brighton, Colorado
Mr. Evan Oildine
Colorado Water Quality Control
Commission
Denver, Colorado
Mr. David Greenland
Associate Professor of Geography
University of Colorado at Boulder
Mr. William M. Auberle, Director
Air Pollution Control Division
464
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
REPORT NO.
EPA-905/5-77-QQ1B
3. RECIPIENT'S ACCESSION NO.
TITLE AND SUBTITLE
Denver Regional Environmental Impact Statement for
Wastewater Facilities and the Clean Water Program,
Volume 2; Analysis. Comments and Resnonse
5. REPORT DATE
April 1978
6. PERFORMING ORGANIZATION CODE
AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
PERFORMING ORGANIZATION NAME AND ADDRESS
Engineering Science, Inc.
600 Bancroft Way
Berkeley, California 94710
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
Task Order No. 68-01-3441
BOA No. 68-01-2860
2. 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
Final EIS
14. SPONSORING AGENCY CODE
5. SUPPLEMENTARY NOTES
16. ABSTRACT
This is the final 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.
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (This Report)
Unclassified
Unlimited
20. SECURITY CLASS (Thispage)
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION is OBSOLETE
* U.S. Government Printing Off ice: 1978-782-969/273 Regions
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