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HomeMy WebLinkAboutBOCC Staff Report 11.01.1999BOCC 11/1/99 PROJECT INFORMATION AND STAFF COMMENTS REQUEST: APPLICANT: I. Description of the Proposal Review of the Town of Parachute Site Application for expansion of a sewage treatment works Town of Parachute The Town of Parachute is proposing to build a new 330,000 gpd wastewater treatment facility to replace a series of lift stations and sewer lines going to the Battlement Mesa Metropolitan District wastewater treatment facilities. The new facility is being designed to meet current water quality discharge standards and to accommodate additional development within the Town of Parachute. (See enclosed application) The proposed method of treatment is a Dual Power Multi -Cellular treatment facility, which is a lagoon based wastewater treatment facility. The facility size is based upon a single family equivalent (SFE) of 1070 by the year 2018. The Town is proposing the new facility to eliminate their reliance upon Battlement Mesa Metropolitan District wastewater treatment facility, which is on the south side of the Colorado River. The Town is concerned about the escalating cost of treatment for the residents of Town and possible damage to the transmission lines under the river that would cause additional economic hardship on the Town. II. Issues and Concerns A. Legal Process: To construct a new sewage treatment facility, an applicant is required to submit an Application for Site Approval for Waste Water Treatment Facilities to the Colorado Department of Public Health and Environment (CDPHE). The site application is required to be reviewed by the County and Local Health Authority. These entities are given three recommendation options; approval, disapproval and no comment. The recommendation is to address the following questions: "Are the proposed facilities consistent with the comprehensive plan and any other plans for the area, including the 201 Facility Plan or 208 Water Quality Management Plan, as they affect water quality?" 1 The recommendations made by local governments are considered by the CDPHE in their approval or denial of the site application. If the CDPHE recommends denial of the proposed site application, it can be appealed to the Colorado Water Quality Control Commission. B. Comprehensive Plan & 208 Water Quality Management Plan 1. Garfield County Comprehensive Plan: The following are some relevant Comprehensive Plan goals, objectives and policies. Water and Sewer Services Goal: To ensure the provision of legal, adequate, dependable, cost effective and environmentally sound sewer and water service for new developments. Objective 7.5: Garfield County will strongly discourage the unnecessary proliferation of private water and sewer systems. Policy 7.2: Where logical, legal and economic extension of service lines from an existing water and/or sewage system can occur, the will require development adjacent to or within a reasonable distance to enter into the appropriate agreement to receive service. The burden of proof regarding logical, legal and economic constraints will be on the developer. Comment: The 1984 Comprehensive Plan does not speak directly to consolidation of sewer and water systems. The intent of the objective directed toward "unnecessary proliferation" was to discourage the development of multiple systems in the same area. This language is in staffs opinion, the equivalent to encouraging the consolidation of systems. 2. 208 Water Quality Management Plan: In 1985, the Water Quality Management Plan for Region 11 was prepared by the Colorado Department of Health, Water Quality Control Management Division for the Associated Governments of Northwest Colorado. The Plan recommended that the Operating Agency for municipal and non -municipal point source discharges of sewage in the Parachute area is Battlement Mesa Inc.. As an Operating Agency, Battlement Mesa Inc. or what is now the Battlement Mesa Metropolitan District, is recognized as the local point source discharge into the Colorado River in this area. 2 C. Other Continents 1 Battlement Mesa Metropolitan District (BMMD) : Enclosed is a letter from the BMMD District Manager, Bruce Smith, questioning the validity of a number of the assumptions in the report and the potential degradation of the water quality due to two systems in close proximity of each other. (See letter pgs. 4^ 7 ) 2 Consolidated Metropolitan District (CMD) : CMD contracts with BMMD for waste water treatment services. CMD and the Town of Parachute are the only customers of BMMD. The CMD Board of Directors also questions the assumptions made in the report based upon their experience in dealing with BMMD. They feel the Town is underestimating their own costs to operate a separate system and that if the new system was approved it would result in higher service charges for the CMD residents. (See letter pgs. R- 3. -3. Wright Water Engineering: The County hired WWE to review the proposed site application and provide an independent evaluation of the proposed site plan. WWE recommends that the Board recommend disapproval of the proposed site application for a number of reasons cited in the attached letter. (See letter pgs. _. 41- 4. Colorado Department of Public Health and Environment: CDPHE does not review site applications until all of the local entities have made their recommendations. The CDPHE has in the past required a demonstration that the consolidation of facilities was considered as a part of the application. The consolidation issue has changed informally at this time to only show that efforts have been made to consider consolidation. This application does not appear to be consistent with the State's consolidation policy, since this would represent a deconsolidation of an existing regional facility. III. CONCLUSION Based upon the input provided by the Battlement Mesa Metropolitan District, Consolidated Metropolitan District, Wright Water Engineers and the inconsistency of the proposed site application with the Garfield County Comprehensive Plan and Region 11 208 Water Quality Management Plan, staff cannot support the need for a new system. It is staff's recommendation that the Board recommend denial of the proposed site application as both the Board of County Commissioners and the Board of Health. 3 /3 B Itle MesaMe por olifan DissricC October 28, 1999 Mr. Mark Bean Director of Regulatory Offices Garfield County Planning Dept. 109 8th Street, Suite 303 Glenwood Springs, CO 81601 Re: Town of Parachute, Application for Site Approval Dear Mark, At its regular meeting this morning, the Board of Directors of the Battlement Mesa Metropolitan District (BMMD) reviewed and issued this letter in response to the pending Application for Site Approval submitted by the Town of Parachute for future construction of its own wastewater treatment plant. As the owner and operator of the existing regional treatment plant, BMMD provides wastewater treatment services to the Consolidated Metropolitan District (residential and commercial accounts within the Battlement Mesa PUD), and also to the Town of Parachute under the Agreement dated February 1, 1981. During the 1990's, attempts to renegotiate the Agreement between BMMD and Parachute have not been successful. From 1985 until 1995, the BMMD wastewater treatment plant operated as a .4 MGD "aerated lagoon" system based upon then -current hydraulic and organic loads. Based upon modest growth within both Battlement Mesa and Parachute during the early -1990's, the BMMD wastewater treatment plant was retrofitted to an "activated sludge" treatment process with a permitted capacity of .8 MGD; it is currently receiving hydraulic and organic loads of about 50% of said capacity and is providing extremely high quality effluent to the Colorado River receiving waters. RECEIVED NOV 0 i 1{i09 1 ,ottvoto b' P.O. BOX 6116, BATTLEMENT MESA, CO 81636 • (970)285-9050 Furthermore, the BMMD wastewater treatment plant has a constructed design capacity of 2.4 MGD (in accordance with the 1981 Agreement) to serve as the "regional" facility based upon projected ultimate build -out of Battlement Mesa and the Town of Parachute. The BMMD Board of Directors has noted the following observations and questions regarding Parachute's Application for Site Approval and its Wastewater Treatment Evaluation Study prepared RG Consulting Engineers: It appears the RG Study dated Sept., 1999, does not accurately reflect the current flows, inflow/infiltration conditions and growth trends within Parachute as evidenced by their total influent flows delivered to the BMMD plant. Understating design parameters could make it appear financially viable for Parachute to finance, construct and operate its own small and efficient wastewater plant. Higher flow rates, as evident by current influent flows, would typically require a larger, more advanced treatment system, that may affect the financial feasibility evaluation. During the previous fifteen -months, influent wastewater flows from Parachute delivered to the BMMD plant have significantly exceeded the flows forecast in the RG Study. All parties seem to concur that a portion of Parachute's current flows are attributable to Inflow/Infiltration to their collection system, but are uncertain how much is I/I and how much is recent growth -related. The RG Study states "... Previous infiltration and inflow problems in the Town's collection system were rectified in 1995." However, during 1999 Parachute applied for and received full grant funding for an Inflow/Infiltration Engineering Study to determine the extent of I/I contributions to the current total influent flows, and also help ascertain both their current baseline flows and recent growth trends. Whether these I/I flows are eliminated from the system, or treated, there should be an associated cost reflected in the Study and Application. The RG Study (pp.1-2) indicates a 46 -year annual growth rate of 2.9% between years 1950-1996 "... will be the basis of growth projections for this report". However, the RG Study (p.10) further states "... This would indicate a very robust annual growth rate of 8.94% between 1990 and 1996." Also, Table 6 does not match data reported by Parachute to BMMD. The RG Study further acknowledges that three major parcels were annexed to Parachute in recent years, which would further suggest anticipation of future escalated growth beyond that of the prior 46 -year period. 2 With recent -years strong growth throughout western Colorado, it seems logical to utilize more recent growth trends for accurate forecasting of required plant size. The financial evaluation portion of the RG Study assumes the BMMD Treatment Fees will escalate at a forecast 3.2% CPI annual inflation rate (which may or may not be a reasonable assumption), yet the RG Study forecasts Parachute Treatment Fees holding relatively flat without the appearance of annual CPI inflation. This seems to be contradicting assumptions and parameters for the "comparative" evaluation. Based upon other public and private projects, the estimated unit price construction costs in the RG Study may appear questionably low. Understating construction costs could lead to an erroneously favorable financial evaluation. A secondary engineering opinion may clarify this issue for Parachute, the County and the State. While it is not BMMD's role to complete a detailed engineering review, several items in the RG Study may be worthy of a secondary engineering opinion. More importantly, we believe these issues belong in Parachute's report and Application. For instance, the proposed 8 -inch force main appears to be of considerable length and volume compared to Parachute's forecast influent flows of the RG Study. Lengthy detention times in the wet -well holding tank and force main would result in the creation of septic wastewater, which is more difficult and costly to treat. The force main will carry wastewater to an elevation higher and greater length distance to the proposed Parachute plant site (than the existing BMMD plant). Obviously, that will create greater, not less, operating expense than present. The additional length of force main significantly increases Parachute's sewer collection system and will accordingly increase their system maintenance costs. We see no reference to these increased system operating and maintenance costs in the RG Study financial evaluation. and they will have an impact upon the end -result Treatment Fees which Parachute would bill its customers. We also see no reference or cost estimate in the RG Study addressing abandonment and removal of Parachute's existing force main under the Colorado River to the BMMD plant. This issue and cost belongs in the report and Application. It should also be noted that if the Site Application were to be approved, Parachute and BMMD would need to negotiate an effective termination of the 1981 Agreement. 3 The current BMMD 0.8 MGD regional plant has demonstrated performance with high quality effluent and low pollutant level return to the Colorado River receiving waters, which is of paramount concern to the jurisdictional regulatory agencies. The proposed Parachute plant is requesting higher discharge pollutant levels in its effluent (than the BMMD plant). These increased pollutant levels would reduce water quality in the Colorado River receiving waters. If higher pollutant levels were approved for a Parachute plant, would the regulatory agencies then require the BMMD plant to be further upgraded to provide even lower pollutant levels in its effluent such that there would be no net effect impact (of the two separate plants) upon the Colorado River receiving water quality ? That scenario could impose a tremendous financial burden (for upgraded treatment) upon remaining Consolidated Metropolitan District customers of BMMD. * While the BMMD activated sludge plant is now producing high quality effluent at its current 50% of hydraulic and organic load capacities, eliminating Parachute's influent (through construction of its separate plant) may likely create an "under - loaded" BMMD plant condition which is difficult and more expensive to process. If Parachute's influent were eliminated (through construction of its separate plant) from the BMMD plant, we would anticipate a minimum 10% increase in Treatment Fees to the remaining Consolidated Metropolitan District customers of BMMD. Bottom line, it appears the most optimistic scenario for Parachute would be a near break-even proposition for Sewer Treatment Fees to its customers, while the reduced loading on the BMMD plant would result in increased treatment fees to the remaining Consolidated Metropolitan District customers. We believe a Site Application decision must consider the impact upon all the customers of the existing BMMD regional facility, rather than solely a single sub -group. Based upon the incomplete and perhaps erroneous information of the RG Study, the Board of Directors of the Battlement Mesa Metropolitan District recommends that the Garfield County Commissioners deny the Application for Site Approval submitted by Parachute. Perhaps in the future when Parachute has resolved its present Inflow/Infiltration conditions and better established its recent growth trends, and when growth within Battlement Mesa could provide a sufficient and proper loading alone to the BMMD plant for efficient operation, maybe that would be a better time for Parachute to perform a more comprehensive and accurate evaluation of financing, constructing and operating its own sewer treatment plant. 4 Sincerely, Ai:€1,-:_attdeet_ William W. Wilde, President Battlement Mesa Metropolitan District cc: Board of Directors, CMD Mayor John Loschke, Town of Parachute CDPH&E a:\siteappli.ltr 5 Ba ie Wfens Mesa Me porho1 awn Disarica- October 11, 1999 Mr. Mark Bean Director of Regulatory Offices Garfield County Planning Dept. 109 8th Street, Suite 303 Glenwood Springs, Colorado 81601 Re: Town of Parachute Application for Site Approval Dear Mr. Bean: Thank you for giving the Battlement Mesa Metropolitan District (BMMD) the opportunity of review comments on the Application for Site Approval submitted by the Town of Parachute. Due to the time constraints for reviewing and submitting comments, I have limited my comments to technical observations and questions. I have not had the opportunity to solicit additional input from the BMMD Board of Directors. The Board of Directors has neither adopted a position of being in support nor in opposition to the Town of Parachute proposed treatment plant. The Metro District continues to provide wastewater treatment services to the Town of Parachute under the Agreement dated February 1, 1981. During the 1990's attempts to renegotiate the agreement, have not been successful. The following observations and questions are offered on the Application: The BMMD wastewater treatment plant is currently receiving hydraulic and organic loads of less than 50% of currently permitted capacity of .8 MGD. Discharges from the plant are typically 3mg/I of BOD and TSS. The plant has a design capacity of 2.4 MGD. For that reason it was established as a regional wastewater treatment facility in 1981. The listed six driving factors discussed on pages 5 & 6 have little bearing on the need to construct a wastewater treatment plant. For instance "factor 1" alludes to growth u creating the need for a new plant, yet growth is estimated at 2.9%. "Factor 2" seems to claim that sewer lines crossing rivers are a huge problem. However, most plants have one or more river -crossing pipelines. The third "factor" indicates that rates are too high, yet Parachute bills its own customers for more wastewater than the report indicates that they discharge. The fourth "factor" worries about "rapidly escalating rates" but later claims that rates charged by Blain would be tied to inflation. The fifth "factor" apparently has something to do with Parachute being capable of running a plant. None of these factors are relevant in approval of a site application. That leaves factor the sixth "factor", which speaks for itself. P.O. BOX 6116, BATTLEMENT MESA, CO 81636 • (970)285-9050 Page 2 There are three areas in which the report is especially deficient. First, there is no agreement that BMMD rates would be tied to inflation. I understand that suggestion has been made by the Town's representatives; however, it has not been presented to the BMMD Board. Based on the last three years experience, a rate tied to the CPI would have result in higher rates than those that were actually charged.. In short the rates included in the Alternative One analysis are false, and therefore the conclusions drawn front that analysis are invalid. A second significant deficiency in the report is that alternatives 2 through 7 fail to include a cost to settle the existing Agreement between Parachute and BMMD. That contract does not include a termination clause but does provide that BMMD will be the exclusive wastewater treatment service provider. The Town was paid $100,000 to enter into the 1981 agreement. It is presumptuous to believe that the Town can simply terminate the agreement unilaterally, and without compensation, A third significant deficiency is that Alternatives 2 through 7 include annual operations and maintenance costs are not supported with data. In some scenarios the O&M cost per 1,000 gallons is shown is declining through time. It appears the Wastewater Treatment Evaluation Study prepared by RG Consulting, dated September, 1999, does not accurately reflect the current flows, inflow/infiltration conditions, and growth trends within the Town of Parachute as evidenced by their total influent flows delivered to the BMMD WWTP. Understating design parameters could make it appear financially viable for the Town to construct its own small and efficient WWTP. Higher flow rates, as evident by current influent flows, would typically require a larger, more advanced system, that may affect the financial feasibility evaluation. During the previous fifteen months, influent wastewater flows from the Town of Parachute delivered to the Metro District's WWTP have significantly exceeded the flows forecast in the RG study. All parties seem to concur that a portion of the Town's current flows are attributable to inflow & infiltration to their collection system, but are uncertain how much is 1/1 and how much is current growth -related. Whether these flows are eliminated from the system, or treated, there is an associated cost which should be reflected in the Application. The RG study states 'Previous infiltration and inflow problems in the Town's collection system were rectified in 1995." However, Parachute recently applied for and received full grant funding for an Inflow/Infiltration Engineering Study to determine the extent of 1/1 contributions to their current total influent flows. The RG study (pp.1-2) indicates a 46 -year annual growth rate of 2.9% between years 1950-1996 "... will be the basis of growth projections for this report". However, the RG study (p,10) further states "...This would indicate a very robust annual growth rate of 8.94 % between 1990 and 1996." Also, Table 6 does not match data reported by the Town to BMMD. The RG study (p.7) further acknowledges that three major parcels were annexed to the Town of Parachute in recent years, which would suggest anticipation of future escalated growth beyond that of the prior 46 -year period. Page 3 With recent -years strong growth throughout western Colorado, it seems logical to utilize more recent growth trends for accurate forecasting of required plant sizing. The Metro District's WWTP was originally designed, permitted and constructed as the "regional plant" serving the wastewater treatment needs of both the Town of Parachute and the Battlement Mesa community. While the District's WWTP is currently permitted as a 0.8 MGD facility, it can be retrofitted to a 1.6 MGD facility with nominal additional investment and has an ultimate capacity of 2.4 MGD. The Metro District's WWTP has demonstrated performance with high quality effluent and low pollutant level return to the Colorado River receiving waters, which is of paramount concern to the jurisdictional regulatory agencies. The proposed Parachute WWTP would discharge higher pollutant levels (than the BMMD plant). The pollutants increase would reduce water quality in the Colorado River. If this is approved for Parachute, would the regulatory agencies then require the Metro District's WWTP to be further upgraded to provide even lower pollutant levels in its effluent such that there would be no net effect impact (of the two separate plants) upon the receiving waters of the Colorado River? That scenario could impose a tremendous financial burden upon the remaining BMMD customers. The financial feasibility analysis must consider the impact on all the customers of the regional facility, rather than a single sub -group. While BMMD has not had the time to complete a detailed engineering review, several items in the report need professional evaluation. For instance, the proposed 8 inch force main appears to be about 3 miles in length, holding about 55,000 gallons per mile. Lengthy detention time in force mains (plus detention time in the holding tank) results in the creation of septic wastewater, which is more difficult and costly to treat. Consideration should also be given to the protocol on damage to the force main, including clean-up, and overflow from the broken main and holding tank while repairs are being completed. It is possible that spilling raw sewage into the Colorado River is more likely to occur with the Alternatives 2 through 7, than #1. Also, the force main will carry wastewater to an elevation higher than the current pumping level and push sewage a greater distance. Obviously, that will be more, not less, costly. Another difficulty is that the force main roughly doubles the length of the Town's sewer system and accordingly will more double the maintenance costs. I suspect an engineer would find all these problems and much more in the report. More importantly, all these issues belongs in the report. In summary, the RG Report is deficient in a number areas. Most notably the cost analysis was based on incorrect data, influent flows are not accurate, growth estimates are inappropriate, estimated construction costs are questionable, and the logic of an additional wastewater treatment facility is suspect. When considered in the aggregate, these considerations, plus the degradation of the water quality in the Colorado River and the unnecessary proliferation of wastewater treatment plants seems to lead to the conclusion that the Application should be denied. Page 4 At the next meeting I will ask the Boards to take a formal position on the application, I will recommend that the BMMD and CMD Boards both recommend disapproval. On behalf of the Battlement Mesa Metropolitan District I appreciate the opportunity to provide questions, and comments. I would appreciate being afforded that opportunity regarding any future submittals regarding this matter. Very truly yours, It. Bruce Sau District Manager cc: Board of Directors, BMMD Board of Directors, CMD CDPH&E Associated Govts of NW Colorado Consolfcff FerMee oli an Dis i — October 22, 1999 Garfield County Commissioners 109 8th Street, Suite 300 Glenwood Springs, CO 81601-3363 RE: Town of Parachute WWTP Site Application Dear Commissioners: On October 20, the Board of Directors of the Consolidated Metropolitan District (CMD) unanimously approved the submission of the following statement regarding the site application of the Town of Parachute to construct a wastewater treatment plant. Battlement Mesa Metropolitan District (BMMD) has only two customers for its wastewater treatment plant; the Town of Parachute and CMD. Both entities effectively resell wastewater treatment services to residents and businesses located within their respective jurisdictional limits. Rates charged by BMMD are essentially the same for both the Town of Parachute and CMD, with sewer charges being assessed in direct proportion to flows received at the plant. Presently the Town, excluding infiltration/inflow, represents approximately 20% of total flow to the plant. In 1999, had the Town's proposed plant been in service, and flow ceased to BMMD's plant, it is estimated that the rate charged to CMD would have had to be increased by at least 10%, even after taking cost reduction measures at the BMMD plant. CMD would then have been forced to increase its rates to residents and businesses in Battlement Mesa by a similar amount. This economic impact has not been considered in the Site Application Report. Based on BMMD preliminary staff analysis of the Town's plan, there appears to be a number of errors, some technical and others administrative. These errors lead us to believe that rather than reducing the Town's residents sewer expense, construction of the proposed plant may well cost the Town more! Surely this is an unintended consequence the Town does not want. One obvious example is that the Town's computed cost savings are largely predicated on taking 1999 rates charged by BMMD and incrementing them annually by an assumed cost of living increase. To date no such rate plan has been approved, and if it were approved it would have increased Parachute's rates above those authorized by the existing contact. RECEl VED OCT 7 :i99 P.O. BOX 6116, BATTLEMENT MESA, CO 81636 • (970)285-9050 8 The Town justifies the need for its own wastewater plant on just two factors; inaccurately projected escalating costs to be paid to BMMD, and the Town's desire to control its own destiny. BMMD's most recent rate increase occurred in 1998. It was necessitated by growth, in both Battlement Mesa and the Town. Growth resulted in the need to reactivate the BMMD activated sludge plant. This upgrade was required by federal law due to the volume of flow to the plant. With the plant changeover completed, and no large projects anticipated for the near future, operating costs are stable and projected capital costs are relatively minor. Thus, we anticipate that BMMD has no presently envisioned need for a large rate increase. As mentioned, the CMD Board of Directors is elected from the resident/users of water and sewer service that CMD purchases from BMMD and resells. We strongly believe that we must understand BMMD operations and rate -making in order to fulfill our responsibilities as elected officials. Our suggestion is that the Town do the same. We, unlike the Town of Parachute, believe that the rates paid currently are reasonable and justifiable, and that our involvement with BMMD assures us of continuing that confidence into the future. As observers, we further believe that the Town has made little effort to become involved with BMMD to understand its operations and rate -setting policies and practice, thus feeding fear and uncertainty. Instead, the Town has attempted to negotiate with BMMD to replace the present agreement put in place in 1981. The negotiations have not proven fruitful to date. To protect the interests of our constituents, should the Town's proposal be approved, we will strongly recommend that BMMD litigate its present contractual right to be the Town of Parachutes only wastewater processor. For all these reasons we, the Board of Directors of the Consolidated Metropolitan District implores you to disapprove the plan proposed by the Town of Parachute. Very truly yours, Welton Francis President cc: Board of Directors, CMD Board of Directors, BMMD Mark Bean, County Planning CDPH&E Wright Water Engineers, Inc. 818 Colorado Ave. P.O. Box 219 Glenwood Springs, Colorado 81602 (970) 945-7755 TEL (970) 945-9210 FAX (303) 893-1608 DENVER DIRECT LINE October 28, 1999 Garfield County Board of County Commissioners Garfield County Board of County Health 109 Eighth Street Glenwood Springs, Colorado 81601-3303 RE: Town of Parachute Site Application for New Wastewater Treatment Facilities Dear Board Members: At your request, Wright Water Engineers, Inc. (WWE) has reviewed the Site Application submittal for a proposed new wastewater treatment facility (WWTF) in the Town of Parachute. Wastewater from the Town of Parachute's sewer collection system is currently treated at the Battlement Mesa Metropolitan District (BMMD) regional wastewater treatment facility. The Town proposes to stop pumping sewage to the BMMD regional facility and pump it to a new facility to be constructed at the west end of town. We are familiar with the BMMD facility because WWE staff members served as the original utility engineers for Exxon in 1981-1982. SUMMARY Based on our review of the Site Application, we recommend that the Board of County Commissioners and the Board of County Health provide a recommendation of DISAPPROVAL to the State. Our recommendation is based on the following findings. 1. The proposed WWTF is in conflict with the Colorado Department of Public Health and Environment (CDPHE) Site Application Regulation 22.3(1)(C) policy that encourages the consolidation of wastewater treatment works. In fact, this proposal is for de- consolidation of facilities that were originally consolidated in 1981. 2. The proposed action is not consistent with Garfield County wastewater treatment policy formulated by the 208 Plan Committee and is inconsistent with sound regional wastewater utility planning. DENVER (303) 480-1700 /0 DURANGO (970) 259-7411 BOULDER - (303) 473-9500 Garfield County Board of County Commissioners Garfield County Board of County Health October 28, 1999 Page 2 3. The primary evidence for de -consolidation is an economic evaluation that shows wastewater treatment is less expensive for the Town of Parachute if the Town constructs and operates a new treatment facility. We disagree with this analysis and believe several significant costs were omitted. 4. The engineering report does not demonstrate the need for a new wastewater treatment facility to serve the demand created by growth in the area. The BMMD facility has the capacity to serve future growth in the area. 5. The engineering report does not address many of the required site application criteria. BACKGROUND WWE reviewed the following information provided to us. • Wastewater Treatment Evaluation Study for the Town of Parachute dated September 1999 prepared by RG Consulting Engineers, Inc. of Denver, Colorado. • Letter from Battlement Mesa Metropolitan District to Mark Bean dated October 11, 1999. • Letter from the Consolidated Metropolitan District to the Garfield County Commissioners dated October 22, 1999. The concept of de -consolidation is in conflict with the CDPHE policy which encourages consolidation of wastewater treatment facilities. The Town of Parachute consolidated wastewater treatment with the Battlement Mesa Water and Sanitation District in 1981-1982. The BMMD was formed in 1986 with the approved Service Plan designating the BMMD facility for treatment of wastewater from the Town of Parachute. The basis for de -consolidation in the RG Consulting Engineers report is an economic analysis that shows it is less expensive for the Town of Parachute if they construct and operate a new treatment facility. We disagree with this analysis for the following reasons: A. The comparison of Alternative 1 to Alternatives 2 through 7 is not a reasonable one. B. The basis for the costs in Alternative 1 is not sound. C. We believe the capital costs and 0 & M costs for Alternatives 2 through 7 are estimated too low. // Garfield County Board of County Commissioners Garfield County Board of County Health October 28, 1999 Page 3 D. The cost analysis does not include costs for the site application process, loan/grant process, and resolving legal issues with BMMD; land costs; erosion and sediment control measures; or economic impact to other area residents served by the BMMD facility. There is no economic basis for a treatment cost per 1,000 gallons to increase by the CPI index of 3.2 percent each year. It is not reasonable to compare the costs estimated for Alternative 1 to the costs for Alternatives 2 through 7. The back calculation of treatment cost per 1,000 gallons in Alternatives 2 through 7 show that although 0 & M costs increase each year, these costs are spread out over more users, and the cost per 1,000 gallons does not significantly change. There is no recognition of this concept in the estimated costs for Alternative 1. A complete economic analysis for a 20 -year period for the BMMD facility is needed to estimate the costs for Alternative 1. The estimated capital and 0 & M costs for Alternatives 2 through 7 appear to be low by 10 to 20 percent. In addition, the cost estimate does not include land costs and erosion/sediment control in the dry wash. Other costs such as legal and engineering fees for the site application process, loan/grant process, and resolving legal contractual issues with the BMMD are not included. Furthermore, the analysis does not include in the economic impact to the other area residents that are served by the BMMD facility. We believe that the invalid assumption for costs in Alternative 1 and the omission of additional costs associated with de -consolidation lead to an unsubstantiated conclusion regarding economics of the proposed facility. The existing BMMD facility was constructed in 1982 with a design capacity of 2.4 million gallons per day (MGD) and a site layout to allow for doubling of the facility to 4.8 MGD. The BMMD facility is a good plant, well operated by a reliable agency, and with capacity potential available. The engineering report does not demonstrate that there is a need for an additional wastewater treatment facility to meet the future needs of the Parachute/Battlement Mesa area. Based on the above discussion, we recommend that the County Commissioners and the Board of County Health recommend DISAPPROVAL of the Town of Parachute Site Application for Construction of New Wastewater Facilities. In addition, we believe the Site Application does not address several of the required site application criteria including: A. Evidence that the proposed site and facility operations will not be adversely effected by natural hazards. B. Evidence from a geologist and geotechnical engineer stating that the site will support the proposed facility. Garfield County Board of County Commissioners Garfield County Board of County Health October 28, 1999 Page 4 C. Evidence that the Town has or can obtain the necessary capital to pay for the project. D. Preliminary effluent limits from the State have not been obtained for the project. The effluent limits listed in the report for direct discharge to the Colorado River are not applicable for discharge to a dry wash. E. The engineering report does not address growth of the surrounding area and the relationship to other wastewater treatment plants in the area. Please call if you have any questions or need additional information. Very truly yours, WRIGHT WATER ENGINEERS, INC. L,i/ Micha=11 Eon, P. Project M. ager MJE/dlf 921-047.070 cc: Mark Bean, Garfield County Don DeFord, Esq., Garfield County Ricardo Goncalves, RG Consulting Engineers, Inc. 0