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April 18, 2007
Via Hand Delivery
Kent Kuster and Jennifer Miller, P.E.
Water Quality Control Division
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Re: Town of Mead Wastewater Treatment Plant Site Application
Dear Kent and Jennifer:
On behalf of the proposed East I-25 Sanitation District, and Gary Woods, Bill Woods and
Merle Maass, as the organizers of the East I-25 Sanitation District (collectively "East I-25"), we
submit this letter to the Water Quality Control Division ("Division"). We incorporate herein the
comments contained in the Letter to the Division from East I-25 dated March 5, 2007. In this
letter we specifically respond to the Town of Mead's ("Mead") letter of March 27, 2007, in
particular noting the deficiencies that remain in Mead's site application and refute Mead's
misrepresentations and misstatements of fact and law.'
I. EAST I-25 DOES NOT LACK STANDING TO PROVIDE COMMENTS TO THE
DIVISION
Based upon misrepresentations and misstatements of the law, Mead contends that East I-
25 cannot provide any comments or objections to Mead's application to the Division because it
is still in the process of becoming a legally formed entity. See Letter from Ed Bendelow to Kent
Kuster and Jennifer Miller, page 1-2 (March 27, 2007) ("Bendelow Letter"). Colorado law
expressly allows any member of the public to provide comment for the Division's consideration
in making its determination whether to approve or deny a site application. 5 CCR 1002-22.9(f).
The Regulation does not require that the commenting party be a legal entity in order to provide
such comment, rather, the Division is required to consider "any public comment." Id. As
individual members of the public, and as the organizers of the East I-25 Sanitation District, East
' We thank the Division for providing us a copy of Mead's March 27,2007 letter in accordance with our continuing
open records request.
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Water Quality Control Division f//
April 18, 2007
Page 2
[-25 has the right to provide comments for the Division's consideration. In truth, nothing in the
Colorado Site Approval Regulations precludes East I-25 or its organizers from providing
comment to the Division.
Moreover, it is solely Mead's actions interfering with the official formation of the East I-
25 District that have prevented it from becoming fully authorized. Mead now attempts to use
that interference not only to prevent East 1-25 from becoming legally formed, but also to prevent
East I-25 and its organizers from exercising their legal right to provide comment in a public
forum. The organizers of the East I-25 District are owners of approximately 3,000 acres of
property east of 1-25. None of this property is within the municipal boundaries of Mead but will
be significantly affected by the Division's decision regarding the application. As property
owners and citizens of the State of Colorado, East I-25 and its organizers clearly have a right to
submit comments to the Division regarding a wastewater project that will affect them.
II. MEAD'S APPLICATION IS INCOMPLETE BECAUSE THE MANAGEMENT
AGENCY,WELD COUNTY, HAS NOT APPROVED IT
A. Mead Is Not the 208 Management Agency For Properties In Unincorporated
Weld County
Mead represents that it is the designated management agency over all parcels east of 1-25
merely because those properties are within Mead's 208 service area. Bendelow Letter, page 3.
This is not true. Mead has not been designated as the 208 management agency for properties
beyond its municipal boundaries because it has not been granted land use jurisdiction over lands
beyond the Town's incorporated area. However, when property is located in unincorporated
Weld County, the County is the management agency, not Mead. Neither the North Front Range
Water Quality Planning Association ("NFRWQPA") nor the State designated Mead as the 208
management agency for lands that are not within Mead's municipal boundaries.
Any attempts to designate Mead as land use management agency for properties beyond
its municipal boundaries would legally fail. The Clean Water Act requires that a designated
management agency have authority to implement the regional water quality management plan
through regulations. 33 U.S.C. § 1288(c)(2), incorporating by reference the requirements of 33
U.S.C. § 1288(b). Furthermore, federal regulations require that "[m]agement agencies must
demonstrate the legal, institutional managerial and financial capability and specific activities
necessary to carry out their responsibilities in accordance with section 208(c)(2)(A)" (statutory
provision requiring a water quality management plan). 40 CFR § 130.6(c)(5). The federal law
requires management agencies to have land use jurisdiction over the properties — Mead cannot
meet this criteria for properties outside the Town's boundaries. "Municipal corporations have no
extraterritorial powers, but their jurisdiction ends at the municipal boundaries and cannot,
without specific legislative authority, extend beyond their geographical limits." See City of
Pueblo v. Flanders, 225 P.2d 832 (Colo. 1950), (Hays, J., dissenting) (citing 37 American
(D0447939.3)
Water Quality Control Division f,,
April 18, 2007
Page 3
Jurisprudence, section 122, page 736). Mead cannot implement the NFRWQPA Areawide
Water Quality Management Plan beyond its municipal boundaries, accordingly, Mead cannot be
a management agency over property outside its municipal boundaries. Therefore Weld County's
approval of the site application was necessary.
Mead fails to distinguish between a management agency (with land use controls) and an
operating agency. Mead was designated as a land use management agency for areas within
Mead in 1993. Mead erroneously contends that NFRWQPA "subsequently extended the
boundary into areas located east of I-25." See Bendelow Letter, page 3. The NFRWQPA 2003
Update clearly distinguishes Mead's roles as to the properties within its service area — Mead is
the land use management agency and operating agency for properties within its jurisdiction and
only the operating agency for lands not within its jurisdiction. "As in previous plan updates, a
land-use management agency is defined as a . . . county, city and county, city or town. These
land-use management agencies are responsible for oversight of all water quality concerns related
to land use within their jurisdiction including point and non-point sources of pollutants and
activities which can degrade receiving waters." NFRWQPA Areawide Water Quality
Management Plan 2003 Update, page I-1 (emphasis added). Weld County is also designated as a
land-use management agency in the Areawide Water Quality Management Plan, and serves as
such for properties over which it retains land-use jurisdiction. The language in the Areawide
Water Quality Management Plan limits the extent of Mead's management agency authority.
The Areawide Water Quality Management Plan, however, recognizes Mead as an
operating agency—which is responsible for collection, treatment and discharge of sewage within
their service area. Id. If Mead has any designation as to unincorporated properties in East I-25
Properties (an assumption disputed in our letter of March 5, 2007 and herein), it would be as an
operating agency, not a management agency.
In support of its alleged designation as the 208 Management Agency for all properties
within its service area, Mead contends the map "illustrates Mead's 208 Boundary." However,
the NFRWQPA Areawide Water Quality Management Plan 2003 Update (with the same map)
does not depict the 208 management agency boundaries for Mead, but rather states that the map
depicts the service area boundaries of the operating agency. NFRWQPA Areawide Water
Quality Management Plan 2003 Update, page II-1. The Areawide Water Quality Management
Plan states: "The service area maps outline the boundaries of the areas for which the operating
entity will be responsible to provide wastewater service in the foreseeable future." Id. By the
terms of the Areawide Water Quality Management Plan 2003 Update, Mead does not have land-
use management agency designation for the East 1-25 Properties.
2"East 1-25 Properties" is meant to include only those properties within the proposed East 1-25 Sanitation District.
{130447939.3}
Water Quality Control Division
April 18, 2007
Page 4
B. Mead Cannot Force Annexation
Mead wants to leverage its designation as a 208 operating agency for East I-25 into a
requirement for the property owners to annex. Mead asserts that it has a statutory right to require
any consumer requesting sewer service to apply for annexation "before the sewer service is
provided," citing Coto. Rev. STAT. § 31-12-121 as support. Bendelow Letter, page 6. An
agreement to annex can be a condition precedent to the supply of sewer service. Coto. REV.
STAT. §31-12-121. According to Mead, they are the sole source for wastewater service and can
require annexation as a condition for that service, which is fundamentally opposite of the
statutory mandate for voluntary annexations. While the statute allows municipalities to make
annexation a condition precedent to service, it does not allow a municipality to force annexation
merely because property is within the municipality's 208 Boundary. Here, Mead uses the fact
that the East I-25 Properties are within Mead's 208 Boundary as a basis for claiming that such
properties must utilize Mead's sewer service and further, that in order to obtain such wastewater
services the property owners must agree to annexation. Mead's Resolution No. 5-R-2004, which
requires annexation is governing and it provides no exceptions. Mead is using the 208 Boundary
as a hook to require annexation, rather than operating under the permissible structure of the
statute.
III. THE DIVISION CANNOT AUTHORIZE CONSTRUCTION OF MEAD'S
WASTEWATER TREATMENT FACILITY ("WWTF") BECAUSE THE
AMMONIA DISCHARGES WOULD ADVERSELY AFFECT WATER
QUALITY,VIOLATE AN APPROVED TMDL,AND BE PROHIBITED BY LAW
A. Ammonia TMDL Background and Requirements
Mead erroneously contends that their new discharges are not subject to the ammonia
TMDL because they are not within the same watershed. Bendelow Letter, page 9. Mead
mischaracterizes the effect of a TMDL, contending that it would affect Mead only if the TMDL
were revised. See Bendelow Letter, page 10. The ammonia TMDL covers, among other waters,
St. Vrain Creek Segment 3. See Tri-Basin TMDL — Ammonia (May 2003). Mead proposes to
discharge into Segment 6 of the St. Vrain Creek, a tributary to St. Vrain Creek. 5 CCR 1002-38
(Table). Because discharges to tributaries can adversely affect downstream water quality, the
TMDL specifically requires that the TMDL "should be reviewed when. . . new wastewater
treatment plants are proposed on the main stem or tributaries. . . ." Tri-Basin TMDL—Ammonia
(May 2003) (emphasis added). The ammonia TMDL must be reviewed to evaluate Mead's
proposed new wastewater treatment plant. This has not occurred.
W0447939 31
Water Quality Control Division
April 18, 2007
Page 5
B. Legal Effect of the Ammonia TMDL -- Mead's Site Application Cannot Be
Approved
Mead's site application is incomplete because it fails to adequately address that Mead's
WWTF will "minimize the potential adverse impacts on water quality" especially ammonia.
The Division cannot issue a discharge permit for Mead unless it meets the TMDL — and,
certainly should not grant site approval to construct a discharging WWTF that would not comply
with the TMDL. Absent such a re-evaluation of the TMDL to show how, if at all, Mead can
comply with the TMDL, the conclusion must be reached that Mead has failed to demonstrate that
its discharges will minimize adverse affects on water quality. These defects are fatal and the site
application must be denied.
In evaluating the suitability of the proposed site application, the Division must consider
"any approved regional wastewater management plan for the area." COLD. REV. STAT. § 25-8-
702 (2)(a). Mead's site application is not consistent with the NFRWQPA Areawide Water
Quality Management Plan, therefore, it must be denied. Once the ammonia TMDL was
approved by EPA it was automatically incorporated into the applicable Water Quality
Management Plan. See 40 CFR §§ 130.7 (a) and (d)(2); 50 Fed. Reg. 1774, 1777 (January 11,
1985). Mead's site application is not consistent with the TMDL or the Water Quality
Management Plan. Approval of Mead's site application would be arbitrary, capricious, and
contrary to federal and state laws.
Mead has not demonstrated that its proposed discharge complies with the TMDL, so no
discharge permit could be issued. "No permit may be issued to a new source or a new
discharger, if the discharge from its construction or operation will cause or contribute to the
violation of water quality standards. The owner or operator of a new source or new discharger
proposing to discharge into a water segment which does not meet applicable water quality
standards. . ., and for which the State or interstate agency has performed a pollutants load
allocation for the pollutant to be discharged, must demonstrate, before the close of the public
comment period, that: (1) There are sufficient remaining pollutant load allocations to allow for
the discharge; and (2) The existing dischargers into that segment are subject to compliance
schedules designed to bring the segment into compliance with applicable water quality
standards." 40 C.F.R. § I22.4(i). According to this federal regulation, "when a new discharge is
proposed and a TMDL has been established, the proponent must demonstrate that the discharge
complies with the TMDL." In re: Cities of Annandale and Maple Lake NPDES/SDS Permit
Issuance, 702 N.W.2d 768, 772 (Minn. Ct. App. 2005). Failure to determine whether Mead's
wastewater treatment discharges can occur within the confines of the TMDL violates the law and
COLO. REV.SrAT. §25-8-702(2)(b).
(D0447939.3)
Water Quality Control Division f,,
April 18, 2007
Page 6
could result in wasting public monies if it is later determined that the Mead WWTF cannot meet
the TMDL.4
Erroneously, Mead contends that compliance with an ammonia effluent limit can be
addressed at the NPDES permitting stage, and that if its discharge would exceed the ammonia
limitation, the Division could (and Mead seems to presume the Division would) issue a permit
with a compliance schedule. However, federal regulations generally prohibit compliance
schedules for new sources. 40 CFR 122.47(a)(2). EPA regulations only allow compliance
schedules for new sources, if "requirements were issued or revised after commencement of
construction but less than three years before commencement of the relevant discharge." Id. The
TMDL was issued nearly four years before Mead's proposed site application, so a compliance
schedule would not be authorized under federal law. Mead has not commenced construction; its
site application must demonstrate that the WWTF will comply with all water quality
requirements, including the TMDL, now. Mead should not be allowed to contend that they
detrimentally relied on the site approval as a basis for post-construction compliance schedule to
meet the ammonia limits and the ammonia TMDL.
IV. THE STATUTE OF LIMITATIONS DOES NOT BAR EAST I-25'S COMMENTS
Mead ignores the fact that the regulations provide a broad opportunity for the public to
comment on site applications pending before the Division. See generally 5 CCR 1002-22.9(f).
Instead, Mead purports that East I-25's comments are barred by the statute of limitations.
Bendelow Letter, page 7. Any member of the public can provide comment, and there are no
restrictions on the nature or substance of those comments. 5 CCR 1002-22.9(f). Accordingly,
Mead's contention that only Weld County could comment upon or argue against the
NFRWQPA's expansion of Mead's 208 service area is incorrect. Not making any provision for
adequate wastewater services to properties purportedly within Mead's 208 service area is a key
defect in Mead's site application. East I-25 is the owner of those properties, and actually has the
right to comment and such comments must be considered by the Division.
Moreover, Mead incorrectly argues that East I-25's comments are barred by the statute of
limitations because more than two years have passed since NFRWQPA's designation of Mead's
extended service area East I-25 is disputing the NFRWQPA's recent decision regarding Mead's
site application. Such action was taken in November 2006, clearly within any application period
of limitation.
4 Mead contends that the site approval decision must be rendered now because of a$500K state grant—so local and
state monies will be wasted if Mead constructs a WWTF that cannot comply with the TMDL.
{D0447939.3)
Water Quality Control Division 1 1
April 18, 2007
Page 7
V. INACCURATE COMPARISON AND WASTEWATER FACILITY SIZING
RESULTS IN ERRONEOUS COSTS AND CONSOLIDATION ANALYSIS
A. The Costs of Mead's Replacement WWTF are Inaccurate and Do Not Meet
Proiected Need.
Through obvious errors and omissions in its cost analysis, Mead has misrepresented the
comparative treatment costs for a new Mead WWTF versus treatment at the St. Vrain Sanitation
District's ("SVSD") existing WWTF. Mead proposes construction of a 0.5 mgd sequencing
batch reactor facility by 2009. The proposed Mead WWTF is inadequately sized and does not
meet the projected need. Before this treatment facility is even constructed it will be outdated and
not meet hydraulic capacity requirements. Unfortunately, Mead has not accurately interpreted
growth rates and averages provided by the State, nor has it included the wastewater flows that
will be generated from the proponents of the East I-25 Sanitation District, if Mead were to
succeed in preventing its formation.
Mead asserts that State growth projections demonstrate only a 3.2% growth being
achieved in the Mead area. That is the average for the State; a State average of all Colorado
counties. A 3.2% growth rate is not reflective of Mead's growth. Basing development,
infrastructure, or sizing of a WWTF on that number is incorrect. An evaluation of the growth
rate for the specific county or municipal area would more accurately project its growth.
Although the State's overall growth rate is less than 4%, Weld County averaged 5.1% from
2004-2005 (in just one year) and 26.6% from April 2000 to July 2005 according to the U.S.
Census Bureau and the State Demographers Office. Within Weld County, which is one of the
largest and fastest growing in the nation, 32 communities, including the Town of Mead, have
provided population census data. The 2004-2005 growth rate for Mead is nearly five times that
of the state average, or 15.1%. U.S. Census Bureau http://censtats.census.gov Weld County
General Profile.
A 3.26 mgd facility is needed to address near term wastewater needs. The cost of this
facility is approximately $21,000,000 (see Table 1 from March 5, 2007 letter).
B. Consolidation With SVSD Is the Most Cost Effective and Environmentally
Responsible Solution.
The consolidation analysis provided by Mead is inaccurate. Consolidation with the
SVSD is the most economically feasible and environmentally responsible alternative.
Notwithstanding our contentions that a 3.26 mgd is necessary, we prepared a consolidation
analysis that highlights a one to one comparison of costs for a 0.5 mgd wastewater facility at
Mead ($8.1 million) versus treatment of 0.5 mgd at the SVSD ($4.4 million). Table 1, attached
hereto and incorporated herein by reference. As shown, consolidation with the SVSD is the most
D0447939.3�
Water Quality Control Division f,,
April 18, 2007
Page 8
economically feasible, as it is approximately 50% less costly than the cost of a separate facility
for Mead. Cost estimates and logic used by Mead in its consolidation analysis are flawed in the
following areas:
i. Tap Fees
Tap fees should not factor into the consolidation analysis. Water Quality Site
Application Policy Number 5 directs that cost comparisons for consolidation analyses should be
based upon cost per 1,000 gallons treated, as well as net present worth. If Mead were conducting
an expanding economic analysis it would be useful to compare the plant investment fees paid to
SVSD versus the tap fees assessed by the Town. Mead's tap fees are higher than SVSD's tap
fees, which could be a detriment for properties within Mead's 208 service area.
ii. Mead's Assumptions on SVSD's Ability to Serve East I-25
The SVSD has a history of water quality compliance, protection of the environment, a
firm understanding of biological processes, wastewater process savvy and deliberate operation
and maintenance of infrastructure. Consolidation with the SVSD will result in a higher level of
wastewater treatment and improvement to water quality. Discharges from SVSD are authorized
in the ammonia TMDL and SVSD has the capability to meet the ammonia requirements.
Mead asserts that a "siphon" like the one proposed by East I-25 to convey wastewater
flows to the SVSD will lead to "disastrous results." Bendelow Letter, page 13. Mead has
confused wastewater terminology, as East I-25 proposes use of a depressed sewer; the sewer is
not actually acting as a siphon but a depressed sewer pipe that flows under pressure. Depressed
sewers like that used in Estes Park (approximate length of 5,280 feet) have proven effective for
the past 30 years. Regardless of terminology, Mead asserts that the "siphon" length proposed by
East I-25 does not meet the State of Colorado Wastewater Design Criteria. Policy 96-1 does not
describe limitations to inverted siphon length. More importantly in the design of an inverted
siphon is maintaining adequate head and velocity. An appropriately designed, operated, and
maintained depressed sewer (or inverted siphon) proposed by East I-25 will function reliably in
the SVSD.
iii. Operation and Maintenance Costs
It is absurd to contend that Mead's O&M costs would be higher if all of Mead's
wastewater is treated by SVSD than if Mead operated a WWTF. Mead inaccurately reflects
higher costs to Mead for O&M costs on the interceptor lines and a lift station under a
consolidation scenario with SVSD than the O&M costs if Mead were responsible for interceptor
lines, a lift station and the new Mead WWTF.
D0447939.3}
Water Quality Control Division 1//
April 18, 2007
Page 9
iv. Not Inclusive of All Costs
Mead does not factor in the cost to decommission the existing Mead WWTF. Although
Mead continues to be indecisive about its Lake Thomas WWTF, it now reports that the Lake
Thomas Facility will be decommissioned. Neither the flows from properties served by Lake
Thomas WWTF, nor the decommissioning costs are included in the cost comparison.
Mead does not include the costs of converting Individual Sewage Disposal Systems
("ISDS") to conventional treatment. It is not reasonable to assume a sustained 36% of the
existing and future residents of Mead will be served by on-site ISDS. This is a poor approach to
ensuring regional water quality objectives will be met now and into the future. On-site ISDS is
not an appropriate solution for urban scale development, which is the predominant form of
development in and around Mead.
A 10-acre site is not sufficient to develop a mechanical treatment plant capable of treating
3.0 mgd. For perspective, SVSD's regional treatment plant currently treats 1.0 mgd using a
combination of lagoon and mechanical treatment systems on a 40-acre site. The plant currently
has a 3.0 mgd capacity with room to expand to a 5.0 mgd capacity in the future.
VI. CONCLUSION
Mead's site application must be denied because it is incomplete:
(i) Mead's application is premised upon misleading, inaccurate information on
the feasibility of consolidating with SVSD. By conducting a cost comparison
with different factors for each WWTF, no true comparison can be made.
(ii) Weld County's approval of Mead's site application is required. Because Mead
cannot implement the regional water quality plan in areas beyond its
municipal jurisdiction, such as the East 1-25 Properties, Mead is at best the
operating agency while Weld County remains the management agency.
(iii) The Mead site application fails to contain the signature of Weld County, the
208 management agency for a significant portion of the 208 area.
The Division must deny Mead's site application because it will adversely affect water
quality.
(i) Mead has not demonstrated that the proposed WWTF will meet the ammonia
TMDL.
(ii) Mead's proposed WWTF has a reasonable potential to cause an exceedence of
water quality standards, particularly by ammonia.
(D0447939.3}
Water Quality Control Division f,
April 18, 2007
Page 10
(iii) Mead's operational record and blatant disregard of the ammonia TMDL are clear
signs that Mead will not construct or operate the WWTF to minimize water
quality impacts.
Mead's application must be denied because it fails to meet the requirement for
consolidation.
(i) Mead's proposed facility will not be sufficient to serve future projected growth
— a significantly larger facility is needed to treat wastewater flows from
Mead's projected growth, the Lake Thomas Facility, and septic systems.
(ii) Consolidation with SVSD is a more cost-effective solution. The Division
policy mandates that in such cases, the Division must encourage the
consolidation.
Mead's site application and supporting information are not credible because of their
misstatements of fact and law. For all of these reasons, the Division should deny Mead's
application for site approval.
lrespe fully submitted,
Ronda Sandquist
RS/tic
cc: Gary Woods
Stephanie Stewart
Julie Vlier
David Long, Commissioner
Douglas Rademacher, Commissioner
Rob Masden, Commissioner
Bruce Barker, Esq., Weld County Attorney
Eric Doering, St. Vrain Sanitation District
Richard Lyons, Esq.
Connie O'Neill,NFRWQPA
Michael Friesen, Mead Town Manager
(D0447939.3}
Consolidation Analysis
for
Town of Mead (0.5 mgd facility)
Weld County, Colorado
Consolidation Analysis Summary
New Mead VWVTF SVSD WWTF
Accurate 03/23/2007 Accurate 03/23/2007
Item Description Values Estimate' Values Estimate'
1 Interceptor Sewers from Mead
1A 10"Interceptor Sewer from Feather Ridge Pump Station $117,600 $109,000 $117,600 $109,000
1B 15" Interceptor Sewer from existing Mead WWTF to new WWTF $487,000 $487,000 -
15" Interceptor Sewer from existing WW I i-to Lift Station
1C located near CR 34 and CR 19 - $1,252,000 $1,252,000
2 Force Main from Lift Station located near OR 34 and CR 19'
12"Force Main from Lift Station located near CR 34 and CR 19 to
2A new WWTF $816,000 $816,000 -
18"Force Main from Lift Station located near CR 34 and CR19 to
2B high point $650,000 $650,000
3 Interceptor Sewers from 18'Force Main to SVSD Connection Point
3A 24"Gravity Sewer from 18"Force Main to SVSD Siphon 1 $1,391,0001 $1,391,000
4 Lift Station located near CR and CR 13
4A 1 MGD ultimate $588,000 $486,000
Regional Lift Station (Wet well/Dry well)0.5 MUD initial-1./MGD
4B Ultimate - $588,000 $1,546,000
5 Mead Wastewater Treatment Facility
5A 0 5 MGD Mead WWTF(SBR cost estimate) 1 $5,687,1361 $3,717,000 1 1-
58 Decommission existing Mead VWVTF $428,000 $428,000
6 Intergovernmental Agreement Development
6A Legal and Administrative Fees for IGA Development 1 1- I I $100,000
7 SVSD P/ant Investment Fees(0.5 MOD capacity)
7A Existing Taps(Fee waived-612 SFE) - $0
78 Future Residential Taps(1,578 SFE)5 - $8,718,000
7C Future Commercial Taps(150 CT)3 - $1,579,000
Total Project Cost $8,123,736 $5,615,000 $4,426,600 $15,345,000
Operation and Maintenance
1 'Operation and Maintenance(set annual cost starting 2008) $185,000 $200,000
Total 20-Year O&M Costs(2008 PW) $3,703,000 $3,820,000
Total Project Cost and 20-Year O&M Cost(2008 dollars) $9,318,000 $19,165,000
Cost per 1000 gallons(Project Cost and 20-Year O&M $20,473 $35,093
General Notes:
1. All cost values are rounded to nearest$1,000.
2. Assumed interest rate if 4.5%.
3. Estimated by JVA,Incorporated
4 The costs for the interceptors are carried forward as there is not enough information to
refute distances used to calculate these costs.
5 Future tap fees are not factored in the analysis,as this is not a cost incurred by Town.
C'.\Documents and Setbngsylkosman\Local Settings\Temporary Internet Files\OLK59\Consolidation Cost Analysis_041707 xis
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