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Home My WebLink About980112.tiff WEST GREELEY SOIL CONSERVATION DISTRICT VIELD 'TY T ""i l`\ \ l i"A 4302 WEST 9' STREET ROAD GREELEY, COLORADO 80634 h7 ,Y! i �I ,•I 9: 21 (970) 356-6506 CLERK January 7, 1998 Connie Harbert, Chair Weld County Commissioners 915 10th St. Greeley, CO 80631 Ms. Harbert: The Board of Supervisors of the West Greeley Soil Conservation District would like to express concern about the application of biosolids (sewage sludge) in Weld County. The board supports the use of biosolids as a soil treatment but is concerned about site selection and monitoring. Several counties in the state have been experiencing problems with improper application of biosolids on farmland. Specific problems included application on steep, shallow soils, and rates exceeding crop nutrient needs resulting in excess nutrients being washed into adjacent riparian areas and water courses. These occurrences have caused some counties to begin placing restrictions on the application of biosolids. The district is concerned that as these restrictions are implemented by neighboring counties more applicators will apply for permits in Weld County. The district receives letters of intent to apply biosolids from the Colorado Department of Health soliciting our comments. Recently we commented on a site west of Greeley which we felt had shallow soils on steep slopes, and was adjacent to riparian areas and the Missile Park. After several weeks we received notice the permit to apply was approved. The district sees a need for county regulations to ensure local entities have a voice in site selection and application rates. Counties and soil conservation districts in some areas of the state have cooperated to institute a soil testing program for biosolids applications. The entities charge a fee per unit of biosolids applied and use the proceeds to pay the salary of a technician to monitor the applications. The district would be interested in assisting Weld County to monitor the applications. In our opinion this is an effective way to ensure proper application methods and rates. Sincerely,XtrilLe,17 Richard Foose, President West Greeley Soil Conservation District / /Y1 /i4/98 CG ?Li f/� CEo� . �A 980112 6 4 0 41%. „ OFFICE OF BOARD OF COMMISSIONERS PHONE (970) 356-4000, EXT. 4200 IDFAX: (970) 352-0242 915 10TH STREET P.O. BOX 758 C. GREELEY, COLORADO 80632 COLORADO March 24, 1998 Richard Foose, President West Greeley Soil Conservation District 4302 West 9th Street Road Greeley, Colorado 80634 Dear Mr. Foose: I received your letter of January 7, 1998, and forwarded your concerns to our Health Department for follow-up action. I understand that your staff has recently contacted Commissioner Kirkmeyer again on this matter. Consequently, I have spoken directly with our Health Department Director, John Pickle. According to John, Pam Smith of the Environmental Health Division prepares these site applications for consideration by our Advisory Board of Health. Our county ordinances concerning biosolids stipulate this board as the approval authority for these applications. The board meetings are open to the public, and all referral comments that we receive are included in the testimony. When Ms. Smith received your letter of the 7th, she talked to Mike Shay of your staff According to Mr. Shay, your District was not opposed to biosolids applications in general, only that the application is in agronomically appropriate rates and that there is adequate soil analysis. Ms. Smith explained that our local health department does not do soil analysis. Pursuant to the ordinances, it is the applicant's responsibility to not only provide soils analysis to ensure application at agronomically appropriate rates, but also to analyze the biosolids themselves to ensure that they meet minimum standards for application. Mr. Shay suggested that the District could perhaps assist us by collecting and testing soils. Ms. Smith indicated that the department might very well be interested in your help in this regard. Mr. Shay also suggested that the department send copies of these applications to your office for review by your staff. Ms. Smith agreed and has sent a copy of each application filed since that date (29 of them to be exact)to your office for review and comment. To date, the department has received no comment from you or your staff on any of these applications, including the application you referenced in your letter of January 7, 1998. Richard Foose Page 2 March 25, 1998 It could very well be that the confusion on this matter is your response on the referral to the Colorado Department of Public Health and the Environment rather than to our own local health department. The state health department does authorize the application of domestic sewage sludge. Before applicants can apply in Weld County, though, they are required to have a county permit. Our ordinance does require that these sites have authorization from the state before we will entertain a permit application. However, we do not receive copies of any comments that the state has received in their review process. Comments directed to our own local health department are entered into the record at the Board of Health hearings and consequently are ensured adequate consideration. Should the District feel strongly enough about a particular application, it would also be very appropriate to present your concerns to the Advisory Board of Health in person. Opportunity for pro and con testimony is provided at these hearings. John assures me that the health department will continue to send these referrals to your District. Further, he would be more than willing to discuss with you and the Advisory Board of Health any other involvement on the part of the District. If you wish to pursue the matter further, I would recommend that you contact John directly at 353-0586, extension 2204. I appreciate your concern and willingness to bring this issue to our attention. I am confident that the health department will work with you in this regard. Please feel free to call me should you have further questions. Sincerely, BOARD OF COUNTY COMMISSIONE¢RSS e,e---( —Witt 4'17 Constance Harbert, Chair cc: Barbara Kirkmeyer, Commissioner John Pickle, Health Jeff Stoll, Environmental Health Monica Daniels-Mika, Planning Bruce Barker, County Attorney WEST GREELEY r SOIL CONSERVATION DISTRICTS cry rI"\ 4302 WEST 9T" STREET ROAD ' GREELEY, COLORADO 80634 - I n, (970) 356-6506 April 16, 1998 Constance Harbert, Chair Weld County Board of County Commissioners 915 10t St. Greeley, CO 80632 Ms. Harbert: Thank you for your letter dated March 24, 1998. We reviewed it at our monthly board meeting on April 13. I need to answer several of your statements. We did receive several sludge applications in our office, however we did not receive 29, or even close to that number (6 on one application and 1 on another to be exact). I do not question they were mailed to us, but we did not receive them. Furthermore we had previously reviewed one and sent our comments to the state. Quite frankly I was waiting for a return letter from you before proceeding on the reviews on the other. I waited from January 7 until your letter on March 24, and I believe I would still be waiting if I had not mentioned it to Commissioner Kirkmeyer. I will contact John Pickle of the Health Department and discuss biosolids applications in length. Our district has many programs that we administer funded by our own monies but our staff is limited. If we enter into a biosolids management program with the county there will need to be revenue from the biosolids applicators to provide additional personnel. The county provides no support to our district at present. Sincerely, Michael Shay District Manager f ,3tv t t a . r ' 9{ ik 4 ?. L ✓ i 8Lt rQs�2,.,c1p� tJerb�l( y — �/S • inoe/ OFFICE OF BOARD OF COMMISSIONERS PHONE (970)356-4000,EXT.4200 W�ik FAX: 0242 915 970) STREET P.O. BOX 758 GREELEY,COLORADO 80632 COLORADO March 24, 1998 Richard Foose,President West Greeley Soil Conservation District 4302 West 9th Street Road Greeley,Colorado 80634 Dear Mr.Foose: I received your letter of January 7, 1998,and forwarded your concerns to our Health Department for follow-up action. I understand that your staff has recently contacted Commissioner Kirkmeyer again on this matter. Consequently,I have spoken directly with our Health Department Director,John Pickle. According to John,Pam Smith of the Environmental Health Division prepares these site applications for consideration by our Advisory Board of Health. Our county ordinances concerning biosolids stipulate this board as the approval authority for these applications. The board meetings are open to the public,and all referral comments that we receive are included in the testimony. When Ms.Smith received your letter of the 7th,she talked to Mike Shay of your staff. According to Mr. Shay,your District was not opposed to biosolids applications in general,only that the application is in agronomically appropriate rates and that there is adequate soil analysis. Ms.Smith explained that our local health department does not do soil analysis. Pursuant to the ordinances,it is the applicant's responsibility to not only provide soils analysis to ensure application at agronomically appropriate rates,but also to analyze the biosolids themselves to ensure that they meet minimum standards for application. Mr.Shay suggested that the District could perhaps assist us by collecting and testing soils. Ms.Smith indicated that the department might very well be interested in your help in this regard. Mr. Shay also suggested that the department send copies of these applications to your office for review by your staff. Ms.Smith agreed and has sent a copy of each application filed since that date(29 of them to be exact)to your office for review and comment. To date,the department has received no comment from you or your staff on any of these applications,including the application you referenced in your letter of January 7, 1998. Richard Foose Page 2 March 25, 1998 It could very well be that the confusion on this matter is your response on the referral to the Colorado Department of Public Health and the Environment rather than to our own local health department. The state health department does authorize the application of domestic sewage sludge. Before applicants can apply in Weld County,though,they are required to have a county permit. Our ordinance does require that these sites have authorization from the state before we will entertain a permit application. However,we do not receive copies of any comments that the state has received in their review process. Comments directed to our own local health department are entered into the record at the Board of Health hearings and consequently are ensured adequate consideration. Should the District feel strongly enough about a particular application,it would also be very appropriate to present your concerns to the Advisory Board of Health in person. Opportunity for pro and con testimony is provided at these hearings. John assures me that the health department will continue to send these referrals to your District. Further,he would be more than willing to discuss with you and the Advisory Board of Health any other involvement on the part of the District. If you wish to pursue the matter further,I would recommend that you contact John directly at 353-0586,extension 2204. I appreciate your concern and willingness to bring this issue to our attention. I am confident that the health department will work with you in this regard. Please feel free to call me should you have further questions. Sincerely, BOARD OF COUNTY COMMISSIONERS P e/dic ( Wel—, Constance Harbert,Chair cc: Barbara Kirkmeyer,Commissioner John Pickle,Health Jeff Stoll,Environmental Health Monica Daniels-Mika,Planning Bruce Barker,County Attorney WEST GREELEY SOIL CONSERVATION DISTRICT WELD Col.i: Y 4302 WEST 9Th STREET ROAD GREELEY,COLORADO 80634 I9 7 .r, l I y !'ti 9: 2 I (970)356-6506 CLERK January 7, 1998 Connie Harbert, Chair Weld County Commissioners 915 101'St. Greeley, CO 80631 Ms. Harbert: The Board of Supervisors of the West Greeley Soil Conservation District would like to express concern about the application of biosolids(sewage sludge)in Weld County. The board supports the use of biosolids as a soil treatment but is concerned about site selection and monitoring. Several counties in the state have been experiencing problems with improper application of biosolids on farmland. Specific problems included application on steep, shallow soils, and rates exceeding crop nutrient needs resulting in excess nutrients being washed into adjacent riparian areas and water courses. These occurrences have caused some counties to begin placing restrictions on the application of biosolids. The district is concerned that as these restrictions are implemented by neighboring counties more applicators will apply for permits in Weld County. The district receives letters of intent to apply biosolids from the Colorado Department of Health soliciting our comments. Recently we commented on a site west of Greeley which we felt had shallow soils on steep slopes, and was adjacent to riparian areas and the Missile Park. After several weeks we received notice the permit to apply was approved. The district sees a need for county regulations to ensure local entities have a voice in site selection and application rates. Counties and soil conservation districts in some areas of the state have cooperated to institute a soil testing program for biosolids applications. The entities charge a fee per unit of biosolids applied and use the proceeds to pay the salary of a technician to monitor the applications. The district would be interested in assisting Weld County to monitor the applications. In our opinion this is an effective way to ensure proper application methods and rates. Sincerely,y, 2 ora Richard Foose, President West Greeley Soil Conservation District /Y 1/i4/98 CG. mil- N<<Ev/ lA 9801f2 Hello