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':.a. ,FILE I_HY COLOR/10O 130631
COLORADO
September 29, 1977
Water Quality Control Commission
Colorado Department of Health
4210 East 11th Avenue
Denver, Colorado 80202
Dear Commission Members:
RE: PUBLIC HEARING ON THE PROPOSED FUNDING LIST FOR FEDERAL
SEWAGE TREATMENT WORKS CONSTRUCTION GRANTS, October 4, 1977
The Board of Weld County Commissioners wish to make the following
comment regarding the proposed funding list for federal sewage
treatment works construction grants. The Board has a vital interest
in the allocation of available, though limited, federal funds as nine
communities in Weld County are in immediate need of funding assistance
to upgrade and/or expand wastewater treatment facilities. According
to our understanding of the proposed funding list, none of these
aforementioned communities are eligible to receive either Step I , II,
or III funding assistance in Fiscal Year 1978. Additionally, funding
needs exceeding $120 million stand between the City of Greeley, who
is highest on the list of Weld County communities , and their complying
with July 1, 1977, secondary treatment requirements. This points to a
number of deficiencies in the priority formula and its application.
First, while the priority formula apparently adopted by the Commission
on September 6, 1977, appears to be a substantial improvement over the
May 31 version, the net effect is to give funding preference to
advanced waste treatment and/or reuse systems rather than to meet
health standards achieved through secondary treatment. We would like
to see more weight given to funding communities who cannot meet minimum
secondary treatment requirements and the establishment of a dual priority
point system as recommended by the 208 Citizen 's Advisory Committee of
the Larimer-Weld Regional Council of Governments.
Secondly, while reuse is commendable, we question the validity of
awarding points to communities who can achieve reuse while penalizing
in a relative sense other communities who cannot do so because of legal
or physical impediments or high costs. Further, we believe that the
Commission should not approve the use of construction grant funds for
reuse systems where they are either proven not to be cost effective or
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Water Quality Control Comm : 9/29/77 Page Two
are not an integral part of the treatment process required to meet
water quality standards. We take this point of view in light of the
needs in Weld County and elsewhere in the State of Colorado to meet
health standards through minimum secondary treatment.
Finally, we believe that the Commission should award 50 special points
to those communities who have an equivalent 201 Facility Plan regardless
of whether or not a 208 Plan has been completed and approved. It
would seem sufficient that the 208 Planning agency and the Division
could evaluate an equivalent 201 Plan covering a specific facility in
coordination with interim outputs of 208 Plans. This approach would
allow such communities to proceed to design and construction (possibly
with construction grant assistance) without unnecessary delays, as
well as rewarding them for taking the planning initiative.
In the case of Weld County, five communities have a completed equivalent
201 Facility Plan. They are Fort Lupton, Milliken, Pierce, Platteville,
and Severance.
We thank you for the opportunity to comment on the proposed priority
list for construction grant funds.
S' erely,
tune K. Steinmark, Chairperson
Board of Weld County Commissioners
JKS/clb
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