A Special Report to the Governor And the State Legislature of Colorado

/

COLORADO WATER CONGRESS

WORLD SAVINGS BUILDING • 1111 SO. COLORADO BLVD. #401 • DENVER. COLORADO 80222 • PHON'E (303) 759-9805 Suwey Swrrma:ry

A SPECIAL REPORT

TO THE

GOVERNOR ANO THE STATE LEGISLATURE OF COLORADO

ON KEY WATER QUALITY ISSUES

1. Cost-Benefit Factors Must Apply to Water Quality.

November 1977

Most Colorado Water Congress members--over 93% of them--believe that

cost-benefit factors must be applied to water quality considerations, according to a.

survey of CWC newsletter subscribers conducted during July, August and September of

this year (1977).

Of the questionnaires received, 93.4% said, "Yes, cost-benefit factors MUST BE

taken into account when considering water quality issues." Only 4. 1% said, "No,

cost-benefit should not be considered," while 2.4% were uncommitted.

Prom tin the uestion, which was one of three circulated throu

gh the CWC

Newsletter circulation of about 1,700 agricultural~ indus

trial and

munic

i

pal water

users), were conments made

by

members of the Colorado Wa

te

r Quality Control

Com-mission who believe cost-benefit factors should not be considered. The rationale,

in their words, is "When cost-benefit factors are taken

in

to account, the

environ-ment always loses." While this is not the "official" pos

i

tion of the Commission,

the statements were presented in formal arguments by influential Commission members,

presumably to influence the official decision-making process, thus raising the

concerns of water users.

More than half of the questionnaire respondents offered comments on the

ques-tion. Here are just a few:

"Costs aannot be ignoz>ed •.. Ouz> environment must be protected, but with aarefuZ study crnd aautious aost ••. If we fail to aonsider the economia impact, it could become so ridiaulous as to have a pez>fect environment crnd no people to live in it ... The only instance in whiah aost-benefit should not be taken into account is when the puhlia health would be adversely affected ... Without cost-benefits, I doubt that we would have the wheel today ... " ·

2. The Matter of

11

Widespread Economic Impact.

1 '

The matter of

11

Widespread Economic Impact

11

was the subject of a second

ques-t

i

on, which used the City of Ft. Collins and its appeal for Class C designation for

a

portion of the Lower Cache la Poudre River to eliminate the need for aT11110nia

removal. A strong argument against granting the exception, which had been

recomend-ed by a hearing officer, was that there was "no widespread economic impact,

11

and

therefore the request should be denied. The cost of ammonia removal, for which there

could be established NO NET BENEFIT, was about $250,000 to $350,000 per mile of

stream, with costs shared by municipal, industrial and agricultural interests.

(Continued Other Side ....• )

..

Survey Swrmary Page 2

Eighty-five

per cent considered the example to represent

11

Widespread Economic

Impact,

11

while 6.6% said,

11

No

.

, it does not represent widespread economic impact,"

and

8.4% said they were not sure. Here are a few corrments:

"· .. Costs to any degree should not be inaurred unless identifiable benefits wilZ resuit ... The example given probably does not represent "wid.espread eaonomic . impact" in the sense of Zoss of jobs, di,sZoeation, eta. However, the referenced aosts aertainly do represent a measurable impaat on the area resid.ents and consumers. It is worth oonsid.ering, perhaps, that the sum of many of these smaUer indirect costs, such as those related to increased utility charges for air and water clean up do, in fact, represent a burd.en to businesses and consumers 1.uhich amounts to a significant eaonomia impact ... The Fort CoUins aase is only a smaZ.Z example of the beginning circle of wid.espread eaonmic impact which can be brought about by n on-essential classification of streams ...

"Maybe by federal budget standards this is not widespread economic impact, but by Zoeal government and business standaY'ds, it certainly is ..• The amount of nrmey represented in the example is only the ground floor of costs. The repeP-aussions to the area accelerote the oosts by 2 to 3 times that nruoh •.• 11

3. The

Matter

of

State vs. Local Control

in

Water Quality Planning~

A

third question dealt with the matter of state vs. local control in water

quality

planning. Readers were asked~ "Should '208' Water Quality Management Plans

developed

by

local 208 agencies in cooperation with local citizens, and under the

guidelines set forth

by

the State 208 agency and the EPA, be accepted by the

state (Water Quality Control Commission) even

if

the local and CWQCC views differ?

_-

_{- -}

--About

85%

felt the local view should prevail. Only 3.6% felt the state view

should prevail, while 12% remained uncommitted. Nearly 60% offered comments on the

subject. Here are a few:

"· .. When a Zoaal entit;y and the area Council of Goverrrrments agree, that

position should prevail ... The Zocal Vieu) should prevail for two major reasons: (1) The time and energy put into the development of an aaoeptable 208 Plan certainly leads the Zoaal residents to a better knowledge of their area than a control

aormrission in Denver that may never have been in the area to be controlled. These persons are aware both of the environmental, need and economic decisions u)hiah must be made to keep their own ZoeaZ area vital, and (2) The Water Quality Control

Corrmission is too often Zed by the opinion of persons or smaZZ groups who have their own axes to grind, rather than'by oorrum..nity needs u)hiah are developed in a u)OrkabZe

208 plan. The Commission should always remember that their powers were given by the people of the State of Co Zorudo to protect al Z the people and not some person's or small groups' ideas. They should also remember that their powers are sufficient to overrule or change any 208 plan i f it does not work out even after it has been approved .•. Neither side should prevail,. Reasonable agreement should be reached in a set time period (of reasonable Zimits or an arbitration board should be empaneZled . . . . Unless soma overriding public interest or policy is involved, the local view and policy sho.uld prevail ..•

For Survey Details See: Question #1 ..•....•.•....•... Page 1

Detailed

Report

Question #2

•..•.•••..•...•...••

Page 7

•

Question #3 ...

Page

12

11 # # # # # # # #

Detailed

Report

on

THE

COLORADO WATER

CONGRESS SURVEY

QUESTIONAIRE

Ju1~ 1977 Newsletter

The following is a complete report of questions and responses to those questions, as they were presented in the July 1977 issue of the

ewe

News-letter. Responses were received at the

ewe

offices during the months of July, August and September 1977:

/I////I/I//II//II//I/I/II//I/I//II///I/II/////////I//I/I//II///III///////II/// I

Question #1: Should cost-benefit factors be applied to

water

quality con-/

I

siderations?

Explanation: Some members of the Colorado Water Quality / / Control Commission believe strongly that economic factors must not be taken/ / into account when considering "environmental" or water quality factors. / / When economics are taken into account, they say, the-environment always / I loses. Others feel, however, that there is a limit to how much should be / I spent for questionable results. What do you think? (please check one) /

I

I

I

1

,-1 Cost-benefit factors MUST BE taken into account when considering

/

I __J

water quality issues.

I

I r- -, I

I / __ _J

Cost-benefit factors

SHOULD

NOT be taken into account.

/

I I

I

Comment:

I I I II I// I /._,...//.,--,.//...,.../,_,_//~/..,...I /,...,..//...,....,/..,...//~//~/~//.,...,.//_,...l,...,..l l..,..,./...,...I /,....,../ l...,....,!..,...l /.,..,,.//_,....,/,....,..//~l_,...//,-.,..//-,-,/-,-I I""'"'"!/..,,...,/,_,...! l.,...,.l_,...//,....,..//..,....,./...,....I /,....,..I l..,...,/-=-1 /-:-,-I !~I I

SUMMARY OF RESPONSE TO QUESTION #1,: Number

Total Number of Responses ..•••••••••••.•.••••••.•••••.• 16 7

Yes, Cost-benefit factors MUST BE taken

into account when considering water quality ••• , ••••• 156

No, Cost-benefit factors SHOULD NOT be

taken into account.... • . . . • • . • . • . • . . • • • . • • • • • • • • • • . • 7

Uncoinin.i tted . ... .,. ... , . • . . .. . .. .. .. .. • . . • . . • . 4 Total Number of Comments ••••••••.•.••••••••••••••••• 93

Percent 100.0% 93.4% 4.2% 2.4% 56.0% COMMENTS: "Yes, but only to a "reasonable" extent. Any costs increasing

project by more than 2% should be reevaulated •.• Benefits should include those indeterminate factors which improve human life by ha:ving higher quality

water .•. Economic factors must be taken into aonsideration as some goals set by enviornmentaZists are unattainable and unrealistic and prohi.bitive to the

consumer ..•

"If cost benefit factor,s are not taken into account, eventually, there 1,Ji,ll be no economic base for people to live in a dry area Zike Colora.do •.•

There is a Zimit as to what the ta:x;payer (gove:rr(IJ71ental supporter) can afford

in governmental oontrol .•. Total costs and total benefits must be considered •.•

Cost cannot be ignored ...

"GeneraUy speaking, there are certain minimum 'level,s of watet> quality · which should be maintained. In oases where advan.ced treatment at high costs

might be suggested, those benefits such as recreation and/or aesthetics should

be evaluated even though difficult to quantify. Existing uses of streams

should also be considered. If existing uses dictate othePWise, laT'ge swns

of money should not be spent upgrading streams - completely irrespective of

benefits which will be realized ..•

"If you do not consider cost-benefit faetor•s in evaluating water quality issues then there are no limits or constraints on the solutions. I consider

this approach to be completely irrational and unacceptable ... We need to pro-tect the enviornment, however, if

we

fail to consider the eaonomia impact it could become so ridiaulous as to have perfeat environment and no people to

Zive in it ...

"It is a total necessity that cost-benefit facto:rs be taken into acaount when considering environmental or water quality faators. This is protection for the environment as well as for the customers who must be served unth the desired water product. We must keep a strong economic ability to perform any

environmental and eaological tasks. If we destroy this ability through waste, the environment uYiZZ suffer more since aZZ effort wiZZ be made to bring

about a vital economic base, forgetting the environment ...

"Our environment must be protected, but unth careful study and cautious cost ... Free enterprise demands this. A society which neglects this certainlu

dearades to one which dissolves free enterorise ... There must be some

trade-offs. Economics mu.st be considered if plans are to be workable ... The public

has a right to know the cost-benefit 1~atio of aZZ environmental plans to "pro-tect the public interest" ...

"If water projeat must meet economia standards, so should water quality

.projects ... The only instance in which cost-benefit factors should not be

taken into account is when the public health would be adversily effected ... Environment should be taken into consideration but not to the exclusion of cost-benefit factors.

"Both guidelines and the law call for the most cost effective solutions

to problems. This is equivalant to cost-benefi . The '-6-olvrado--Water Qrm.ti1:g Control, Commission does consider cost effective and cost benefit; the ques-tion is, perhaps, to what extent should the costs of treatment be 1,Jeighed in the decision making process .•.

"One of the best examples is the Northern Colorado Water Conservation

Districts - without this district, the area of Northern Colorado, east of Loveland, many miles would now be a desert. If you read the records of the

early 30's, you unll see there were people in those days that said the pro-ject was not economically sound, we will always need more water ...

"Some way there ha,s to be recognition of costs. T'ne decision should be based on both sides. Just how rrruch does it cost for a definable criteria on

stream quality •.. We could easily identify so many "Sacred Cows" in our

enviornment in the United States that we could divert to many economic re-sources for protection and restoration and "go broke" or stari,e ...

"Cost-benefit should not neaessarily be Zess than l to aUow action, but when it beaomes lo, lOO, lOOO or more, the public should know about it ... A simple yes or no probably won't cut it, a rabid-purist would put a very high economic value on unecessarily clean water and then where are we. A realistic criteria for benefits and costs would be a must too ...

"What is the trne value of environment if we price our•se lves out of existence? ... The tazpayers all should insist that this be done, since they are the people who have to pay the bills ... I believe that there is a finite limit of economics that the public is willing to spend on water quality and the decision should be theirs ...

"If we want to maintain the standard of Ziving we n()u) have, we mi.A.st

consider cost-benefit factors. All costs eventually are cha:i~ged to cost of

living, cost of living is going up and up. If cost-benefit is no·t considered we are decreasing our standards of living ..• The environment does not lose, even if cost is considered ...

"If cost is not considered, it gives too mcray 1_{'edueated idiots" a chance}

to "boon dogel". We don 1_{t want our farms and livestock growers destroyed by}

guess and higher costs . .. If cost-benefit factors ar•e not taken into account, we will not have to have the Colorado Water Quality Control Commission or any-one else, because the costs will destroy the area ...

"If economics are not taken into account the local community loses. I don't kn()u) of any entity that can spend vast swns for projects of little or

no return and service ... How can you determine the value of swimming in the

South Platte verses swimming in a pool unless you know how much its going to aost. Perhaps we eould build everybody a s-wirnming poo.l cheaper than making some streams swirronable ...

"What benefit is anything if the costs place it beyond the use of the

people? We can all dream of living in a "utopia11

, but as yet very few can

afford it, and they afford it at the expense of others ... Economic factors are a part of the total picture and most must be taken into account ... It is

ridiculous to think ·that unlimited a.mounts can be spent. Quality of life (overall) should be the goal ...

"Cost-benefit factors "should" be one of several factors used in the evaluation. It should also be required of other Federal Projects as well

-no exceptions .•. Our envio!'Ylment should be protected if at all possible. If

there is a great difference in the cost-benefit,then our environment must suffer. The total benefit to most the people must be considered ...

"The whole subject is over-done - water will purify itself ever 200

feet. "One pZanner" remarked that it was aU r-ight for his children to SuJim in the running stream after he profoundly argued against a C()u) drinking out

of the same stream ... Without cost-benefit, I doubt that we would have the wheel today . ..

"Cost-benefits should be taken into account, but only to a certain point. There are many benefits to local economy and public service that are not

taken into consideration under cost-benefits ... Cost-benefit factors will always

be subjective and still subject to much debate, however, they will serve

to esta.blish comparative pr~orties - i.e. fishery vs. agriculture vs.

recrea-tion ·vs municipal, supply ...

"Certainly eceonomics must enter into the picture of determining realistic

water quality goals. However, ther>e is also ·the question of parity in costs for achieving the water quality goaZs that would differ substantially through-out the state if each exception to the '83 goals is considered on a case by case basis. A statewide evaluation of water quality goals must address the inequality in costs between the East Slope and West Slope water users to meet

these goals if wholesale exceptions are to be given to East Slope, rrrunicipalities, industries and other water users ...

"Our economy cannot afford to squander funds on water quality improvement which has no economic value. OtheI'Wise we should take on some of the big jobs

such as removing sodium chloride from the oceans (our largest bodies of polluted water. J •••

'~ minority on the comission have fought for economic considerations. They need all the help they can get ... Pollution has been caused over a long period of time by a lot of different people. It cannot be cleaned up over-night and the cost should not be bore by one segment unless that segment was the sole cause .••

"Native intelligence and corronon sence demand that environmental

decisions eonsider economie benefits; one without the other is irresponsible ... Values get distroted out of reason when eost faetors are not considered ... Any businessman knows that eost-benefit faetors must be used when consider-ing all qualities, water or any other thinq ...

"It would seem that cost-benefit factors should be taken into eonsidera-tion in water quality decisions. The problem here seems to be that lines are being drawn without a eomplete recognition and understanding of the problems and impacts that PL 92-500 is eausing. Sinee there is this gap in understanding the problems in their totality the solutions wiU be far from being what they might have been if more was known and priorities were more clear cut. We have yet to really be able to put eost and benefit in a truer perspective and deal with them in an equitahle fashion. If there is to be no benefit from a large eost we may as well be flushing money dawn the john. On the other hand if benefits are to be derived then costs should be incurred. The environment suffers not simply beeause of an unfavorahle cost-benefit relationship, but beeause of an inahility to see the problem in its totality and to make the most logical deeision. We think we are being fair by simply creating then following a regulation. In this effort to treat individuals fairly by treat-ing them aU with ·the scone regulations, we lose sight of the faet that diversity in a system is what increases its viahility and vitality. In doing this, we tPeat t-he sys-iem upon --whi-ch we -all depend

the most unfairly of all~ What we really need is someone whose judgements ean be relied upon and acaepted and that sad~y is what we are lacking. We are still trying to find an honest man . ..

"It is just as ridiculous to ignore eeonomia factors in the resolution of environmental problems as it is to ignore em)ironmental factors in the resolution of economic problems ... In any responsible government program this is a must. Only an irresponsible government would not consider cost-benefit .•. We better spend the money now on the environment, because the next generation will have troulbe re-creating the conditions we have. It's expensive for us

to do so with our lO-eent dollars, but the next generation will find it even tougher with their 5-cent dollars ...

"If only short term economic factor's are considered, results can be misleading. We mu.st develop the expertise to determine long term (range) environmental costs and eeonomie eosts ..• Cost-benefit factors, while being considered, should not be the controlling factors. There are times when certain other factors (health pY'Oblems, eta.) may over-ride costs ...

"Everyone seems to have something special that he wants to "protect'' under the term "environment" and it would be impossible to find any project which would not offend someone. Under these conditions, the general publie rrm.st be protect itself from endless expenditures. The questions: Who

would be harmed, a:nd how much, should be balaneed against the expense in each case. If it is true that the envior1'!1Tlent always loses, perhaps there is a reason ...

"The aosts must not significantly e:r:aeed the benefits to downstream users - particularly if the result is the total loss of the water to down-stream users in the ?Jest - reasonably clean wateP is better' than none at all even from an "environmentaZis·t" v-leuYpoint ... Does down stream usage require proposed water quality, i.e., some feel incoming water is too clean for agricultural uses ...

"The use of good common sense points out the necessity of considering the economic factors involved ... These factors should be considered by both the Colorado Water Quality Control Commission and project proponents, but the decision to go ahead or to abandon should rest with proponents. This is the essence of free enterprise ...

"Some good common sense could be displayed ·in consideration of aZot of this DPA work. The EPA wi U find "reports II _{ha:r>d to chew one of these da:ys}

-and if things keep going like they ar•e now, that will be all there is left ... It would be almost impossible to assess the factors in water quality and charge them to the users on an equitable basis... ·

"flithout consideration of economie factors the cost to serve the environ-ment aan be high, with engineers knCfl.i)ledge and technical advancement of this society a happy solution can be achieved and we eng·ineers must try to get the best results with. t~ least cost ...

"If cost-benefit factors are not taken int; acco~t., .-..

and

this philosophy beeomes widespread, then one of two things must result, either the products or services affected will become unavailable, or will cost so much that many people cannot afford them •.. Money is al7;)0,ys a factor ... Cost-benefit foY'mula is seldom "honest" in evaluating action for protection of Colorado water. The cost-benefit formula is usually "loaded" ...

"With every operation., any cost-benefit factor should be analized to the complete extent to justify the operation ... Every mernber of the public is paying a rising price for water quality; each member has a right and a duty to decide if the benefits are worth the costs in dollars. This, because aativities of government have gone far beyond the basia needs to protect life and property . ..

,,This can be argued either way, depending upon what costs and benefits are to be included ... In a nation born and successful with free enterprise philosophy, we are turning away from this if we do not consider economia factors in those type of decisions ...

'~ll issues must be settled on their own merit. This society cannot afford to practice descrimination in dispensing its resources to solve its problems. Water quality -issues should not receive a:ny special treatment ... Economic faators rrrust be considered in connection with environmental problems to insure the adequate production of food ..•

"All water projects since Reclamation started hcwe been computed on cost-benefit basis. Water quality control should have the same requirements ... Naturally, there is a limit as to how much money rrrunicipalities can spend to meet water quality controls ... If the benefit isn't worth it, it just isn't worth it ...

-s-"I think there are too many things being done that don't consider

cost-benefits ... Economic costs as weZZ as enviro~.mentaZ benefits should both be con-sidered in 1iX1ter quality issues. A balance between economic easts and

environ-mental benefits should be atterrrpted .•• The Zack of consideration of economic

factors comes from the fact that the "Declaration of Goals and P0Zicy11 _{of PL 92-500}

speaks of "attainability" but !!:EVer once mentions economic considerations. We

must overcome this flC!l,) ...

''Production of food wiU be more necessary tfian the dollar spent in the

future ... The farms a:t>e making so much money they sure can't stand it ... The

ta:r:payer-conswner has to know what his cost is - what he is paying for - and

what the benefit is going to be ..• Economics is hlhat our agricultural base

d.epends on . ..

"Cuy,rently, PL 92-500 does not permit a practical cost-benefit analysis

because the mandatory meeting of goals is a ,,given", ther·efore, a less, or "do-nothing" alternative cannot be measured . •. Without east-benefit factors taken into account, comrnon sense and proper perspective can be lost and quite

frequently a:t>e lost in complex envirorunen-tal issues .•.

"This is not to say that cost-benefit should be the deciding factor, but

it must be considered or we go way ofj the inflationary scale (especially when government is involved with ta:c money) ..• What good is enviornmental "pu:Pity"

if the nation goes bankr'U.pt in order to attain it? • • •

"What, and at 1.uho 's expense would t'he consideration incZ-ude if not the

overaZ.Z public taxpayer? •.. "Must" is the key word" other>Wise z.ue 'r•e headed for

total bcmkr:uptcy ... It wou?,d be rather ridiculous to_ clean _ p a smaU drainage

at several million dollars that is sufficiently diluted as it meets the main stream to hfTJe no detrimutal eff eat . ..

"PL 25-500 states that the national goal of swimming and fishing shall be the goat ''wherever attainable" (sec. ioz ( a) (2)). EPA attempted to define "wherever attainable" in an early EPA "Water Q-uaZity Strateg,.J Paper" (second edition) - see page 28 which reads that exceptions to goals may be granted for three Peason" (a) present technology cannot restor~ the water quality - (b) the cost of meeting these standards is economically prohibitive compared to the

expected benefits" or, (a) the natural qualities of the water a:t>e less than recommended minimum criteria. Congress obviously intended that cost-benefit be

ll/l//ll//////ll//ll/////////l///////////l///ll////lll/////l///l/ll//l//l//l///lll/1 I

question #2: What do y~u consider

11

widespread economic impact

11

?

How do you

I

I

interpret the

Ft.

Col11ns case?

Explanation: The city of Ft. Collins rec- I

I ently requested that the Lower Cache la Poudre River flowing through· and below /

/ the city be reclassified under the "C" classification to eliminate the necessity I

/ for ammonia removal from sewage effluent. The subject stream was completely I

I

diverted in several locations for agricultural uses---summer and winter---and

I

/ it was apparent that there would be no "net effect" to removing the ammonia. I

I None-the-less, the Colorado Water Quality Control Commission took several I

/ months to reach a reluctant decision to give a limited conditional reclass- I

/ ification. /

I I

/ One of the arguments for not granting the request was that there was "no wide- - I

/ spread economic impact" as an essential ingredient to justify the need for I

/ reclassification. At stake on the 10-mile stretch of river was a $100,000 /

/ initial investment and $50,000 annual cost for the City of Ft. Collins; $600,000 /

/ initial and $65,000 annual cost for Kodak of Colorado; ·$250,000 initial and /

I undetennined annual cost for the City of Windsor; and a $1,500,000 to $2,500,000 I

/ initial cost for Great Western Sugar for a total of $2,450,000 to $3,500,000 I

I initial investment plus annual costs for NO NET BENEFIT. A cost of about /

I $250,000 to $350,000 per mile! In your opinion, does the previous example I

I represent "widespread·. economic impact"? Please check the most appropriate I

I response and make your comments. I

j

.

[

:_

-.J

Yes, I

would consider

it

"widespread economic impact.

11

~

~

[-

1

No,

it is

not.

~

I

D

I I

Not

sure. I I I I

Comments:

I ////I////////////////////I///I/////////////////////////I///I////////I/I//I//I/I/////

SUMMARY OF RESPONSE TO QUESTION #2: Number

Total Number of Responses ••.•..•.•••.•••••••.•.••.••••••••• 167

Yes, I would consider it "widespread economic impact." •• 142

No, it is not ••...••.•..•••.•••• ~ ••.•••..•.••.•.••...•.. 11

Not sure. . . • • • • . . • • • • • . . • • . • . . . . • . • . • • • • • • • . • . . . • • • • • • • • 14

Total Number of Comments. • • • . . • . . . • • • . • • • • . • • . . • . • • • • • 63

Percent 100.0% 85.0% 6.6% 8.4% 37.7%

COMMENTS: "Burdensome costs to entities and users ..• As the stream is aom-pletely

diverted to agriaultUI'e and ammonia is benefiaial to agriaulture,. the neaessity of removing the ammonia is nil •.. Costs to any degree should not be inaurred

unless identifiahle benefits will result .•. From your desaription of the situation it appears that there would be significant economic im-pact - I have no personal kn(JI,) ledge ...

"You failed to mention that the City of Greeley is im-pacted to a great degree with the new Delta Sur Plant that is in the planning stage. Actually, the ammonia in the water is a benefit to the agriculture that is using the

water, so why take out something that is an eaonomia advantage to the irrigators who use the water? The only objection is that ammonia is bad for fish, but,

there are no fish ...

"The examp'le given probabZ.y does not rep;r>esent ''widespread eaonomia impaat" in the sense of loss of jobs, disZoaation, eta. However, the referenced costs certainly do represent a measurabte irrrpaat on the area residents and consumers. It is worth aonside1-.ing, per-haps. that the ?WI]_ _{of ma:ay of these sl11QUer} in-direat costs suah as those related to inareased utility charges for ai~ and water cleanup do, in fact, represent a bu::t.>den to businesses and consumers which amounts to a significant eaonomia impact. Ce:r•tainly the cost-benefit questions disaussed earlier is worthy of notice in this Ft. Collins type case •••

"The Ft. Collins case is only a smaZZ example of the beginning circle of widespread economic impact which can be brought about by non-essential class-ifications of streams. The amount of money spent at no benefit at $250,000 to $350,000 per mile aZong the Cache Za Poud.Pe River wiZZ spread like the

Pipples of a rock thrOIJ)YI. in a pond. Other• wor,k whiah the cities and industPies· must do for quality of life, growth, safety, recrea-tion, eta., wiU be left undone. These undone things then ?.Jill affect the lives of residents, visitors, old and young. Waste of money resou::t.>ces never aan be measured totally •.•

"$250,00 to $300,000 aost per mile of river seems to be a considerable cost impaat e1>en to our fedePal goverwnent. If the federal goverwnent paid the entire bill, the cost would be paid by evey,y citizen of the U.S. and· I'd say that's widespread economia impaat ..• In addition to affecting a sizeable number of people, a Zarge nurnber of Zand acres and individual eaonomies are affected •.•

"Money of this amount should not be spent unless public health is in danger, or it is determined in court that it is unlG.1Jful to delay action ... A lot of people are affected ..• Widespread economic impact wiU vary with the situation. While this case. may weU oe and have wui.espread impact, I don't

know enought of the specifics to comment ...

"Maybe, by federa.Z. budget standa:r•ds this is not widespread economic impact, but by local goveT'Yl111ents and business standards, it cer,tainly is .•. If the "no growth" people on the Water Quality Control had ·to pay the aost of their decision - I am sure their decision would be considerably different .•• I would consider, the decision irresponsible, there is no way to control costs

and still live with such decisions •.•

"Eaonomie impact to those paying the bills ••. Again, we would be adding to the cost of living at ou::t.> present standards. We need to proteat our envioronment, but do we want to lower our living standards to l??6 level. I don't. We have to use our resources to the best advantages ..• All of those aosts wiU surly be passed onto the publia,ultimatel,y, another example of insensetive bu::t.>eacrats in aation •••

11_{There is no doubt but what the cost to those returning water to the}

stream is significant. You fail to state who would benefit from ammonia, free water, or is there an economic benefit for- water in ammonia? .•• "Boon Dogles" of this nature make one wonder what ever happened to the "hard headed business man11 _{particulairtu when ou::t.> country is practicaZ.Zy bankrupt and ta:r:es and} inflation is going high and higher ...

"It aertain'ly invo'lves a 'lot of money and a 'lot of people. I wiU adrnit that it does not invo'lve people on the west s'lope or> in other states; but, they neither have to pay for it'or add ammonia to their irrigation water .•. I feel, it is a great waste of money to forae regulations on an area where there is no gain either enviornmentally or economically, a waste of money is a big a waste as a loss of envio'17Ylment ...

"I wou'ld question the assumption that there is no net-benefit in this excunple. Simply because a stream is 11_dried-up11 _at

one point along its cour,se shou'ld not imply that beneficial in-stream uses do not exist (i.e. fishing recreation). The Cache La Poudre could be compared to the Colorado River or Shoshone where the rit1er is dried up for a distanee of some five miles, both summer and winter. Yet no one would assert that the entiPe length of the Colo~.

rado River should be re-classified ...

''Those costs represent continuing inflation and could be extremely damaging to the local economic:s •.. The greater benefit to the most peopZe. The cost of Pemoving the ammonia, at this time, is prohibitive, a cheaper process may be developed later ••. The widespread, economic impact is enhanced by "pZanning comm-ittees", who are not elected, do not represent, do not know or want to know that property r>ight are as fundamental to a man as his life or his libe.i'ty. Free enterprise built this nation... ·

"Based on no net benefit, question: what adverse effect does the ammonia have in the irronediate and long term? ... Let the local people handle their problems, outsiders do not or will not look at the local problems as they should ... I

consider this a:n example of an attempt to squander resources whic:h otheI"l»ise could be used for constructive purposes to improve our economy and society ... The

commissions Peluatanee to t•eclassifying this strecon section is unbelievable and irresponsible ...

"I'm not sure, I would need to know and understand the whole situation, to make any intelligent decision, we have

far

too much wild guessing now ... These costs are certainly not negligible and they affect aU of the people resident in the cities concerned, as well as the agricultural users of the water who must put these elements back into the soil-water. This is nearly ZOO% of all people in the area--about as widespread as one can get ...

"If there is to be no net benefit from a multi-miUion doUar investment, it seems that this would be not only widespread but also needless and iPrationaZ economic impact. If this is viewed, however, within the context of our Alice in Wonderland approach to solving some of the current issues of the day, then it seems wonderfully logical. I guess widespread economic impact is not measured in multi-millions of dollars. In defense of the CWQCC commission, h01.Jever, it may be that they do not wish to set precedents too easily as could become the case ...

"Any waste of money by government would have i.n:despread economic impact •. . Your slanted, biased question makes a "yes" answer the only answer. I wish you would have given both sides ... Maybe it is "potentiaUy" widespr•ead economic: impact that is in quest-ion, rather than actual ... A limited reclassification was given ••. Anybody 1.Jho considers these amounts of money negligible should not be in a posi-tion to make such decisions ...

"Since nearly aU of this water is diverted to agriiau.lturaZ use, and ammonia

is used as fertilizer, it seems rather ridiculous to require its removaZ ... I feel the example has large doZZ.m• wrpact on a reZitiveZy small effected area. Also on basis of infonnation given - is not necessary anyway ... It doesn't make senee to spend great amounts of money to remove ammonia from the 1,,ater, then have the farmers spend more to put it back on the Zand •••

"Some of these people ser'Ving on these comissions had better use some good common horse sense and realize where their food is coming from and what it takes to carry on a successful business ... It appears quite clear that those entities required to expend forge sums to meet dubious goals wiZZ. ha.veto recoup the doU-ars from someone - the most likely victim being John Q. 'Pub Zic . .. '1.'he engineers

and scientist cannot take chances on life, safety or health of the general public

even if it means spending a fet,) dollars... ,

"While the example definitely represents "widespread economic: impact", to me that is not the main point. The impaat in an individuq.l case may be unfa·ir• and

not justified ... I question the magnitude of the dollars stated in your statement above. I do not know h01.,) valid they a.re ... Eve-ry and any decision, especially with water has an extensive economic impact .. .

'~rmnonia removal imposes a heavy dollar burden upon the people by forcing them to pay for costly sewage treatment as weU as requring the farrne.rs to pur-ahase fertilizer (CIJmlonia) which they could receive at no cost in the i-Prigation

·water ... It appears to be a "widespread economic impact" when compared to area involved, the usage of the water, and the benefit to be derived from the expen-diture of the funds ..•

"Bureaucrats don't have t;-o work to pay the biZ ts for the expenses they cause ... Ammonia removal for the L()u)er Poudre River is a good example of Federal Bureau-erats requirements based on total ignorance of western water problems. A dry river is a dead river. I cannot see how you can raise fish in a dry river ... All the facts are not knou..'f/1. to me, but my impression is the class "C" change shoul,d be granted ...

'~nother excurrpte of government meddling, ereating excessive expenses with no apparent benefits to be derived ..• In my viewpoint, the figures mentioned above indeed qualify it as widespread economic impaot ... When you talk of tha.t amount of money, its bound to have quite an economic 1"..mpact ... Although I agree that the economias justified the exception, according to EPA 's definition of "ividespread economic impact" a depressipn would not quality ...

"As shown in this case, stringent stream standards, although they may be justifiable under some conditions should not be adopted unifonnZy for an entire region. As stated previously this sh()u)s that both costs and benefits involved in water quality issues should be evaZuated ••. Just pushing r,..p terrific unnecessary cost to the area ... 1'his certainly represents widespread economic impact, l'espect-ing those who live and work in this area of Colorado an initial cost of' some 3.5 million and probably a lO year operating cost of alike amount .••

"While I do not disagree with the idea that "widespread economic impact" is a probable certainty, I am dubious as to the nwnbers that agencies develop in presenting their cases for relief ..• This is a local problem and not widespread as looking at the state of Colorado overaZZ ... It is a limited economic impact on a localized group of governmental and industrial users •. .

"There is one economic impact not mentioned. If the iFI'igators did not

receive the armionia they would need more fertiz.izer ... This is an example of being rigid (silly) in adherence· to concepts or regulations •.. This economic cost spread over only ZO miles of river but affecting appro. l50, 000 people must be cons1:dered widespread ..• This needs a set of criteria - but who would have the guts to try to define it - it would end up in court ..•

"I would want more information regarding the armionia issue as weU as the othero impacts associated with reclassifying the river "C11

• • • Water quality has to be tempered by good judgement ...

QUESTION #3 begins top of next page.

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Question #3: Should

11

208

11

.

Water Qua1ity Management Plans developed

by

local

I

I

208 agencies in cooperation with local citizens, and under the guidelines set

_I

I

forth

by

the State 208 agency and the EPA, be accepted by the state (Water

I

I

Quality Control Commission) even

if

the local and CWQCC views differ?

Explana- I / tion: Even though several "208" plans have been developed by local councils of / / Governments with the guidance of the state and EPA and under their guidelines, / · / with the imput and approval of local committees, members of the CWQCC have chal-/ / lenged the plans and urged disapproval. Should the local view previal? What do/

I you think? I

I i----! I

1 !__J

Yes, the local view should prevail.

I

I · I

I ,___J

No, the Water Quality Control Commission opinion should prevail.

I

I I

I

Comments:

/

l//////l//////l////ll//ll////l////ll////l//ll////////l//!/I//I//I///I////////////I! SUMMARY OF RESPONSE TO QUESTION #3:

Total Number of Responses •••.•.•.•.•..••..••••...•.... 16 7

Yes, the local view should prevail. ..•...••.• · •••..•..•.. 141 No, the Water Quality Control Con:unission opinion .

should prevail. . • . . . • . . . • • . . • . . • • . . . • . . • . • . • . . . 6

No Answer. . . • . . . • . . . • . . • . . • • . . • • . . . . • . . . • • • . . • . . . . . . . 20

Total Number of Comments ...•.•...•.•...•.•.•... 101

100.0% 84.4% 3.6% 12.0%

60.4%

"When a Z.Oeal entity and the area Council of Gover>ranen-ts -agree"' that position

should prevail ..• The 208 local committee have to go through a thorough local

residents of a large area do approve the plan of controlling the water within

their area, then the Colorado Water Quality Control Commission should not have serious changes allowed ...

'~s a worker with 208 in my area, I believe in loeal imput and local control.

This is the only way that our country can operate ... I have no opinions on this ... Ne·ither should prevail -reasonable agreement shnuld be reached in a "set time period (of reasonable limits)" or an arbitration board should be empaneled .•. The greatest environmental impact on wester>n slope water is the diversion of the virgin-pure water by Denver and eastern slope interests. There should be an end put to this rape ...

"The local view should prevail for two major reasons: (l) The time and energy

put into the development of an acceptable 208 Plan certainly leads the local resi-dents to a better knowledge of their area than a control commission sitting in Denver that may never have been in the area to be controlled. These persons cn>e aware both of the environmental need and the economic decisions which must be made

to keep their own local area vital. (2) The Water Qual-ity Control Commission is

too often led by the opinion of persons or small groups who have their own axes

to grind rather than by community needs which are developed in a workable 208 Plan. The Commission should always remember that their pawers were given by the people, not some persons or small groups' ideas. They also should remember that

their powers are sufficient to overrule and change any 208 Plan if it does not

?.,)Ork out even after it has been approved. It behooves all commissions to think

more about the people they are to serve and all their needs rather than fulfilling demands of special groups who continue to lobby them with thoughts and half-truths ...

"This is not a question which can simply be answe:r•ed in a yes or no fash-ion. It is probably t:r>ue, at times, that representation on the 208 progrcon eommittees is not complete. -- i.e. ther•e were no industrial or agricultural representatives on the Citizens Advisory Council for the DRCOG 208 Study. Thus, in certain cases, a final review procedure may be advisable. In a&lition, the Corronission may have a better overall broad prespective of the State classifica-tion system and funding availability than would the individual 208 progrcon per-sonnel. However, the various strecon classifications for a particular r•egion should be reasonable or "down to earth" and cost effective. They must also, of eourse, be consistent with Federal law -- a balance which is not always easy to attain. Thus, it is reasonable to assume that input at both levels is ad-visable and compromise will at times be required .•.

"Subject to review and comment at Colorado Tiater Quality Control Corrunission ... Until challenged issues are resolved, water quality plans should be delayed .•. ContPol should be as close to use as possible ••. Unless some qverrid'f!lg_ public interest or policy is involved, the local view and policy should prevail ... Local view should take into account stream classifications. Another qualifyer should be in appr-oval of State 208 agency and EPA befo1•e CWQCC views can be dismissed •..

"'J.'he people appointed to the CWQCC are in majority "no gro1t)th" people and housewives of no experience business or otherwise •.. Local control of water supply has to be maintained to have any control over cost-benefits ... Yes, as long as guidelines are followed ... Effect of local plans on do~m-strecon or adjacent areas rrrust be taken into account, compromise may be necessary ...

11Yes., as long as the dourastrecon users ai"e protected as related to health, crop production and normal or established fishe1"ies, I asswne that this is

pro-vided in 208 guidelines ... We cannot let such things r-un wild .•. If technical rea-sons or long-range planning problems are a problem, then CWQCC should make re-corrunendations - the Governor luis right of final veto ...

"AU plans differ - there are not "typical" conditions of circumstances, local plan., when guidelines are right, can be the only answer. Proper guidelines are the key .•. The Councils of Governments did not utilize all the input from local .jurisdiction that was supplied to them ... Who better understands and kno1t)s the ZoaaZ problems than those involved ...

"Yes, de-centralize and localize ..• The local couneils could have local ob-jectives that would be deteY'f11ental to an entire river basin. For example., a 208 plan for Brighton could have local support, but be completely out of phase with a river basin ob.jective of ihe CWQCC ... I do not believe in rule by committee. No oorrunittee helped me acquire what I have - no eommittee should be e1J7Powered to

take it away. Russia is ruled by corronittee, isn't it, not by the ballot and

demoeratic process ...

"Too many times local corrunittees have been Zed down the wrong road by gov-err.ment agencies. For exconple, Zook how little or no local imput was accepted

by the goverr1ment agencies. Their so called local meetings were a fa:r>ce .•. Why have local imput if we are to be governed and controlled by diatators? •.. I would Zike., for a change, to have the people involved in both cost 'and effect . considered in these matters., not just the bureacrats or congressmen from other states with other problems •..

-13-"The 'local people are much better aquainted with the prob'lems and best plans for improvement. Also the economic effect and costs must be considered

as to how it affects the local residents .•. The 208 plan developed by the local

208 agenay should control local problems .•. It is a very basic issue as to who has

the responsibility for "local" Zand use decisions ...

"Yes, unless there is a aonfliat between upper r>iver and lower river

dis-tricts and the local aommittees cannot agree ... There is entirely too much

"butting in", petty and unsound opinions, aommittes and Zeaguers in the normal

goverrunental set up in this state •.. I don't believe a straight yes or no aan

be stated. In some cases I guess a small confined group could be self serving

without regard for the majority . ..

"Yes, provided overall state oriented goals and objectives are not aompro-·

mised to the point where an adverse impact results on others outside the "local"

area ... Environment should be the first consideration but should not be enforced

beyond the consumers ability to PE:1i. for it ... In those ~ases where local plans

meet required standards I believe local desires should be aaaepted ...

"The Water Quality Control Commissions view should prevail only if there

is a clearly defined benefit of statewide benefit which would not injure local

interests. In the event of local injury to local goverrunent or industry, then

the local view should prevail ... LoaaZ commissions generally are in a better

position to judge their needs than outsiders ...

"There will be oases where it will be necessary for CWQCC to make changes

beaause not all local 208 plans are going to aome up to the standards they

should ... I don't believe a flat yes or no can be given to this question to cover

every situation .•. Muah of PL 92-500 goes beyond reason a-ad practicality. Also

the CWQCC has been unduly influenced towards enviornmental factors and considera-tions in several past deaisions ... This is a very serious question - it will be

many years before its finally anS'l,)ered, if ever •.•

"The burden of proof should be on CWQCC that ZoaaUy developed plans pro-duce an unacceptable burden on other corrorrunities water quality plans and/or

requirements before any disapproval should be considered. When this does occur,

the CWQCC should seek the equitable compromise ... Yes, that is what good balanced govePnment is all about ...

"My observation has been that the Zoaal view aan be as biased and

irra-tional as that of the WQCC. The answers should be somewhere between the two

extremes of opinion and in the area of common sense but since this commodity seems in short supply and the two groups eye each other with suspicion it does

not seem that the two will easily get together. Neither group is unbiased

although they would like to have the other believe this to be the case. I do

feel, however, that the ZoaaZ view would have a more rational basis since it

is

closer to the problem and less prone to official agency response to official

agency regulation which is not aonduaive to a commons sense approach •.•

"Locally elected and locally appointed officials are easier for the ZoaaZ

folks to throw out, if they screw up. It's tougher for them to get their hands

on bigwigs in Denver, such as the CWQCC ... I will not answer this to give blanket

approval to either side ... Too bad you didn't offer a compromise position. I

like local control, but realize that drainage basins do not follow the rigid

"Neither. They should be able to come to a reasonable aqreement, and i.f not, the courts should mak~ the final decision, or a knowledgeable referee panel should be set up for this purpose ... Not on a blanket basis - there should be room for reasonable compromise. The EPA and Army Engineers can be overzealous in their activies - reasonable protection for do-wnstream users should be the prevailing consideration ...

"The closer to the problem that the decision to rectify that problem can be made - the more just and viable the decision ... The local view should be used because the local view is more informed ... If it had not been possible for local people to use their Ow"rl. good sound judgement, the development of

agriculture and industry in these United States would be far behind what it is today ... A system of WQCC r•eviei.J should prevail, but without arbitrary veto power .. .

"No, but should consider the local imput and revise their opinion if re-quired ... 1'he Governor is the referee and the one who certifies the 208 plan. He must take the "heat" if the plan is not acceptable to the local public ... Neither, there should be a point of compromise ..• The Zoeal point of view seldom considers the total picture and the downstream consequences of the local deci-sions Since water is not "local", we eventually must adopt statewide impact considerations ...

"The 1.,)ay the local "208" meetings are going -is a farce. The state is just giving service to the Federal GoveT'Yllnent ..• If the CWQCC opinion is to pr•evail, there is no need for developing 208 plans. The basic problem appears to be

too much goveT'YllT1ent and eommon sense suggest that some of it should be el-iminated ... Where is the federal goverrnment's decree for swimming and fishing by l983? No

water right... ·

"I am chairman of a group of soil conservation districts that are involved in a 208 study and its irrrparative that our plans be accepted, we a:r>e •.. Yes, after-all it is prima:r>ily local peoples business ... Local people understand their local problems best. They are also better equipped to plan their own destiny. How long is this garbage of others planning my life going to continue? Maybe a revolt against groups such as CWQCC is not too much out of line ...

"Unless the views of local communities are ex-pressed, soon we 1.,)ilZ have no local communities ... The local citizens certainly know what is best for their own community and the prevailing conditions ... Local authorship and evaluations of economic and environmental impacts should prevail ... This is the only way to bring into view and administer any decision in favor of special problems, etc. that need to be considered ...

"If the CWQCC might reject a 208 plan., then they should develop the plan in the first place without local imput ... Local citizens have practical knowledge not available to theoretical planners, we must be pr•actical ... I feel that local people should be heard, as they should know what would be right for their area ..• '1.'he WQCC must be convinced that their role in 208 is to coordinate the Va:r>ious 208 programs, not to judge and overrule individual local decisions ...

"This points to a need for more coordination between local agencies and the CWQCC. Perhaps there should be a more definable State of Colorado water quality policy with consideration given to local needs, i.e., costs, benefits, water quality (right) issues. Perhaps with suchapolicy the local view eould prevail with minimal oversight by the CWQCC ...

-"GeneraUy, the Zoaal councils should know more about the conditions by being in closer aontact ... Provided the 208 plans are consistent with the latJ

and logical from an enviornmental standpoint, the CWQCC should defex to the faat finding of the local group •.• It is my experienae that 1:n all matters relating to the enviorrunent, pubZia hearings are heZd and then the input is ignored un-Zess it corresponds to the views o.f the-qovernmentaZ agena'l/.,.

"Not alwyas a yes - no alternative. The CWQCC should be balanced u)ith pro

and aon environmental membership and persuasion. Many local governments u)ill reaat understandably when their "ox is being gored", but that reaction is not always the best solution on a regional scaZe ... Loaal view and imput is

necess-ary if appZiaation of the final 208 plan is to beaome a reality ... Uniform state

wide management is necessary ..•

"The 208 planning in Pueblo received much more baZanaed imput than would

ever be possible by the CWQCC. Local planning, when done in a professional (vs politiaal) manner is muah preferTed ... The entire aonoept of 208 as sold by the Federal Government and bought by Zocal government @as that it ?Jas "ZoaaZ" in nature - both planning and management ... The problems and needs of the citizens varies u){th loaal areas. Absolute uniformity betu)een loaaZ areas, regions, or states is impossible ..•

"There would be no benefits to the river or the area, as no domestia use of water is in this ZO miles involved. The flow of water as now is benefically used as is ... No, or do away u){th the CWQCC as its effeativeness u){Zl degenerate and be subjeat to all the other bureaucratia state and federal agenaies ... Yes, but only if the local plan meets- the requirements of the latJ and federal regulations -that is "aatch 22" beaause the locals and the state have different

inter•pta-tions .•.

"There needs to be opi.n1.,.ons from both sides. The loaal view may not have the same view for the state overall. At the same ti~e, however, the CWQCC must be made atJare of serious loaaZ issues •.. Loaal people know better how to resolve their problems than bureaucrats."