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Sewer service on the urban fringe of Colorado municipalities

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Title:
Sewer service on the urban fringe of Colorado municipalities
Creator:
Teas, Martha
Publication Date:
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English
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124 leaves : ; 28 cm

Subjects

Subjects / Keywords:
Sewerage -- Colorado ( lcsh )
Sewerage ( fast )
Colorado ( fast )
Genre:
bibliography ( marcgt )
theses ( marcgt )
non-fiction ( marcgt )

Notes

Bibliography:
Includes bibliographical references.
General Note:
Submitted in partial fulfillment of the requirements for the degree, Master of Urban and Regional Planning, School of Architecture and Planning.
Statement of Responsibility:
by Martha Teas.

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Source Institution:
University of Colorado Denver
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Auraria Library
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Resource Identifier:
28175891 ( OCLC )
ocm28175891
Classification:
LD1190.A78 1989m .T428 ( lcc )

Full Text
Hit, later Table
Poor Soils for Development
Vacant Ground Zoned Cannierci al

Seasonally High Water Table Low Density Residential Uses
Interspersed with Agricultural Uses
Single Family Residential Uses Within Dotted Line; Served by Onsite Systems
Single Family Residential Uses With Older Onsite Systems High Water Table High Failure Rate of Systems


"Developer" formed Special District
v S.
Jr
MAP 3-2
MAP DEPICTING SPECIAL DISTRICT APPROACH
Low Density Residential Uses Interspersed with Orchards Farmland "under siege"
l
Single Family Residential Uses Special District formed by Neighborhood Locks in Municipal Boundaries


Poor Soils
High Water Table
Estate Development Only
Grand Junction/Mesa County Greater Urban Area Growth More Consolidated Contiguous to Municipal borders
MAP 3-3
DEPICTING REGIONAL APPROACH
Orchard and Grazing Land Future Growth Potential
Orchards
Future Growth Potential


MAP
EXISTING SERVICE AREAS AND PLANT LOCATIONS
LEGEND
GRAND JUNCTION CITY LIMITS GRAND JUNCTION FACILITY PLANNING AREA BOUNDARY
SSOCIATION
FIGURE 2
SdtfSET terrace SEjWER | ASSDilATiON
GALAXY-FAIRWAY PARK BELLA VISTA ^ SEWER ASSOCIATiONv
CLIF-TON NO. I SANITATION OtST-RiCT v ,
PAN ORA VAT..-; IMPROVEMENT
A-SANETATii
rrmsTPicT

irn0.c^^^Ty
D2=5rRUnv£tE f i i,= SANITAT40N1: :'DI'^T R |[CTi j-

-A
£&£. 20,oob GRD''
^£??monument
}^p, -MEADOWS "
[N&iR3Er TO
RIOT
LCAPACIJY 1 \ 700,000 GPD_j%_
CLIFT0N/LA60
approach
jt:
I/ FAIRWAY SEW-2 DISTRICT^
CITY ISYsVtM
MONUMENT
R PARK
SANTO
DISTRt
CD 2 CELL LA60C SYSTEM
14,000 Gf D
YIN SUBDiyiSKfr
PACKAGE PLAF
000 O 1000 2000
2 STAGE TRICKLING FILTER PLANT


UNIVERSITY OF COLORADO AT DENVER
SEWER SERVICE ON THE URBAN FRINGE OF COLORADO MUNICIPALITIES
A THESIS SUBMITTED TO THE SCHOOL OF ARCHITECTURE AND PLANNING IN PARTIAL FULFILLMENT OF A MASTER IN URBAN REGIONAL
PLANNING DEGREE
THESIS ADVISOR: DR. DAVID R HILL
BY
Martha Teas
DENVER, COLORADO
JANUARY, 1989


TABLE OF CONTENTS
CHAPTER
I. INTRODUCTION.......................................1
Problem Statement Purpose Background Major Themes
Organization and Methodology Scope and Limits of Study Notes
II. SEWER SERVICE ON THE URBAN FRINGE:
THE CONTEXT........................................16
Sewer Service, Health, and Water Quality:
Key Issues
Sewer Service, Growth Management and Land Use Controls: Key Issues
Financial Aspects of Sewer Service On the Fringe: Key Issues
Mesa County: A Case Study
Notes
III. ALTERNATIVES FOR SEWER SERVICE IN
THE URBAN FRINGE...................................5 4
Decentralized Approach
Special District Approach
Regional Approach
Mixed Approach
Notes


IV. CRITERIA FOR EVALUATION ...........................7 4
Harmony with the Natural Environment Promotes Coordinated Provision of Urban Services Equitable and Affordable Distribution of Costs Administrative Efficiency
Integration with Planning and Land Use Controls
V. EVALUATION OF ALTERNATIVE
APPROACHES TO SEWER ............................. 84
VI. SUMMARY AND RECOMMENDATIONS......................Ill
Findings
Recommendations
Suggestions for Further Research SOURCES CONSULTED......................................123


LIST OF ILLUSTRATIONS
Title
1. Map of Grand Valiev; Mesa County, Colorado
2. Map of Sewer Service Configuration;
Mesa County, Colorado
3. Map Depicting Decentralized Approach
4. Map Depicting Special District Approach
5. Map Depicting Regional Approach
6. Map Depicting Mixed Approach
7. Table Depicting Summary Findings in Evaluation


CHAPTER I
INTRODUCTION
Problem Statement
During the past forty to fifty years, many areas in Colorado and other states have witnessed a growing phenomenon of urban development on the unincorporated fringe of municipalities. The urban fringe has since become an entrenched part of the American landscape, and the terms associated with such fringe development, urban sprawl and leap frog growth, have become part of the common nomenclature of American society. Among the wide range of concerns about the urban fringe, sewer service is one of the most important. The way sewer service is provided, both physically and administratively, impacts land use patterns, public finance, and political relationships among governmental entities and their constituents. Despite this importance, most counties in Colorado have not directly involved themselves with strategic questions of sewer service, even though they exercise great discretionary authority in the approval of development, special district service plans, and the use of individual sewage disposal systems under their jurisdiction.
This lack of involvement on one level can be regarded as a manifestation of the general disinterest in managing urban
areas by several county governments. In Colorado, most
1


counties are quite large, encompassing vast rural or unpopulated areas, and the urban fringe represents a very-small porportion of the jurisdiction geographically. It is difficult for any governmental entity to maintain two levels of governing practices, one for rural areas and another for urban. The other option, contracting with central municipalities has not been commonly exercised in Colorado. Yet counties must pay greater attention to sewer service on the fringe than they have in the past. The way sewer service is currently provided and managed on the urban fringe has caused problems. Foremost among these are potential health hazards and water pollution. The Colorado Department of Health in 1988 noted in their annual report forty-one nonmunicipal areas throughout the state with potential health hazards.fi] This does not necessarily mean that counties should themselves provide sewer service, but develop a greater understanding, and consequently greater ability to make informed decisions through the mandated powers counties exercise in the approval of development and special districts.
The State of Colorado also has responsibilities to its County subdivisions, by providing enabling legislation and requirements regarding sewer service. By defining appropriate standards for types of sewer service throughout Colorado, the State Health Department, Water Quality Control Division, is deeply involved with sewer service issues on the


urban fringe. In like manner, the Special District Control
Act and its subsequent amendments, administered by the Division of Local Government, Department of Local Affairs, significantly influence the manner in which counties consider the role of special districts involving sanitation as they are formed. The existing legislation and level of staffing in these state arenas may be questioned as to their sufficiency in providing effective guidance for counties regarding urban fringe areas.
Background
Many experts consider the end of World War II as the beginning of urban sprawl in unincorporated areas. At that time, federal financial incentives for new housing coupled with economic upward mobility triggered a massive exodus beyond municipal centers.[2] As this trend continued through the 1950s and 1960s, increased awareness of the implications followed. In 1974, the extensively documented Study, Costs of Sprawl was published on behalf of the U.S. Department of Housing and Urban Development and the Environmental Protection Agency. The Report quantified the negative aspects of unrestrained growth, as well as confirmed the emerging national concern about urban sprawl and its specific consequences.[3]In 1975, the Urban Land Institute published a four volume series of articles concerning
management of growth, with the following statement
3


identifying its theme: "There can be little doubt that much of the American public has been experiencing at least a dawning awareness of the side-effects of inadequate control of growth and urban sprawl." [4J
In Colorado during the 1970's, control of growth was the subject of intense discussions in the State Assembly. Out of the highly publicized state wide debate attending the issue of land use control emerged a theme having direct effects on the way sewer service is handled on the urban fringe. It was decided through legislative action that local government should be unimpeded by the state in their control over land use and services.[5] Despite a great deal of educational and political effort to involve State government directly in land use and growth managment, the decision was made that municipalities and counties were the best judges of how to cope with their own destinies. House Bills 1034 and 1041 of 1974 enabled counties to adopt a wide scope of regulations and policies, but included few mandates to do so.[6]
In subsequent years, county government and special districts became coequals with municipalities in accepting growth within their jurisdictions. Population figures for the State in past decades demonstrated the extent to which unincorporated parts of the counties have shared the degree of growth and development in Colorado.
4


Total
Table 1-1
Colorado Population Unincorporated
(n) %
1960 534,617 30.4 1,753,947
1970 553,048 25 2,209,596
1980 769,472 26 2,889,735
[7 J
In the national arena as well as in Colorado, sewer service has been acknowledged as one of the most important issues associated with growth and land use. Increased awareness of the impacts caused by sewage treatment led to the Environmental Protection Agencys (EPA) amendment to the Water Quality Act of 1972, referred to as the 201 Program.
By 1975, the EPA announced that 36.6 billion federal tax dollars were needed for secondary wastewater treatment and collection systems.[8] By 1980, the 201 Program had become one of the largest public improvement subsidies in the nations history.[9] To a great extent, developed lands under County jurisdictions were the subjects of this program, simply because it was at the urban fringe where water quality problems were most frequently found.[10] The basic reason for
this was synopsized well by Tabors et al in their book,
5


Interceptor Sewers and Urban Sprawl:
In recent years, rising public concern has led to strict new water quality regulations. Ad hoc solutions to the pollution problems of new residential development have been severely restricted through the enforcement of zoning restrictons on septic tank use, bans on new connections to existng collection sewer systems, and requirements for advanced wastewater treatment."[11]
Despite such national attention over the years, County
governments in Colorado have thus far not involved themselves
with sewer service outside of supporting the minimal
guidance offered by State Statutes. Such guidance has
included basic standards for individual disposal systems,
formation of special districts and acceptance of subdivisions
that propose private plants.[12] More recently, Counties
have sponsored grants for sewer systems managed by other
entities, or acted as silent partners in regional systems
initiated by municipalities.[13]
These prevailing methods of dealing with wastewater in unincorporated areas has led to a variety of current problems in Colorado as noted earlier. The source of problems have ranged from treatment plant violations in special districts to massive failures of individual sewage disposal systems. [14] Concern for health risks and water pollution in turn set in motion other problems. These include funding proper sewer systems, limiting choices in growth and development and triggering conflict in the political arena. Less measurable,
but equally disruptive, is the lack of policy regarding
6


counties real and potential involvement with sewer service. There is no evident comprehensive position on preferred methods or management of sewer service on the urban fringe. Colorado Counties Inc., the sister organization to Colorado Municipal League, has not adopted a position towards traditional means of treating wastewater on the urban fringe.[15] Proposed House Bill 1012 in 1984 would have increased county powers for providing urban services. While the Colorado Municipal League advocated its adoption, counties were unresponsive, leading to its failure in the state legislature.[16]
Purpose
The intent of this thesis is to explore, analyze and make recommendations regarding the subject of sewer service on the urban fringe areas of Colorados municipalities from a planning perspective. By doing so, it is hoped that those involved with sewer service in these areas may gain some insights to the implications of different approaches to sewer service, and the forces influencing decision made about the urban fringe.
The concept of this Thesis arose from the authors involvement from 1983 to 1987 in a policy making effort for the Grand Valley of Mesa County, Colorado. At the direction of local elected officials, staff from a variety of
disciplines developed a comprehensive strategy for the
7


management of regional sewer service. This was no simple task. The majority of housing in the Grand Valley was located outside of the City of Grand Junction, served by several sanitation districts, package plants and over 2000 individual sewage disposal systems. Impetus for developing a policy came from an EPA 201 water quality grant of 24.5 million dollars, funding 75% of a waste water treatment plant and 25 miles of interceptors. With the plant at only 40 per cent capacity, and a debt retirement schedule anticipating regional connections, the County as partner in the Grant confronted a costly dilemma that continues to be a source of local controversy.
Themes
In order to accomplish the purpose of this thesis, a number of general themes were identified. It first needed to be established what trends from the federal and state levels influenced the development of certain types of sewer service on the urban fringe, and what role planning played in relation to this development. In order to gain a more clear picture of how these different influences worked, it was appropriate to consider an actual situation in Colorado, Mesa County. By conducting a case study, and observing how different approaches to sewer service evolve, I could then identify selected alternatives that represented the status
quo of sewer service on Colorados urban fringe. At this
8


point, criteria to evaluate the different sewer alternatives could be introduced; this in turn would allow a judgement to be made on how the different alternatives perform in a practical way. Finally, the research of state and national trends, case study, and evaluation could provide the basis for suggesting specific short term recommendations to improve the effectiveness of the different alternatives, as well as lead to speculative discussion of long term policy changes.
Organization and Method
The study was organized into four major elements:
-Chapter II presents background information concerning sewer service on the urban fringe of Colorado municipalities, grouped into key issues associated with water quality standards, land use planning, and financial issues. The chapter then turns to a case study of Mesa County and its experience with sewer service and the urban fringe encircling Grand Junction.
-Chapters III, IV and V describe alternative methods of dealing with sewer service on the urban fringe, identify criteria for evaluating their performance, and conducts the evaluation..
9


-Chapter VI makes findings and conclusions about the study, and offers recommendations toward changing current legislation and state administration regarding sewer service on the unincorporated urban fringe. A discussion is then held regarding long term changes considered appropriate for the long term disposition of urban fringe areas in Colorado.
The study methodology consisted of three major elements:
-The first step was to describe the context of sewer service on the urban fringe. A textual analysis was conducted of relevant factors influencing different approaches toward sewer service on the urban fringe of municipalities in Colorado. This analysis used books and articles dealing with the EPA 201 Water Quality Program, the relationship between land use and sewer infrastructure, and sewer service management. Information about sewer service in Colorados urban fringe areas, including methods and standards of wastewater treatment, relevant legislation, and historical information concerning planning issues associated with the urban fringe was also taken into account. Sources for this information included documents generated by Colorado Department of Health, Land Use Commission, and Department of Local Affairs.
-Extensive interviews were then conducted with State Health
10


local government.[17] Mesa County and its experience with sewer service on the urban fringe is treated as a further focal point. The result of this experience helped define the parameters and concerns of the Study. Mesa County also works well as a case study, because of its involvement with a regional sewer system, a host of special districts, private package plants and individual sewage treatment systems. Like most counties in Colorado, Mesa County has not exercised its potential for home rule status, nor has it restricted urban fringe development to municipal stewardship. Although the urban area of the grand valley is larger than most outside o the Denver Metropolitan Area, it is not an aberration from dynamics at work in other counties.
Limitations of this Thesis were determined by a number of factors. To the best knowledge of this author there have been no previous similar studies conducted about the urban fringe areas and sewer service. Works that were useful also tended to be either out of date because of federal policy changes, or ignored the importance of individual sewage disposal systems on the urban fringe and concentrated on infrastructure controls to growth. The other major limitation was the lack of usable data from other counties in Colorado. It was beyond the scope of the requirements of a master's thesis to collect and analyze data to that extent Finally, information concerning this issue from other states
tended to be extremely specific, and related to different
12


Department staff,the Deputy Director of the Colorado Municipal League, and investment bankers involved with local improvement district financing and other forms of bonded indeptedness for sewer systems in unincorporated areas.
Other persons contacted were from Department of Local Affairs and the Land Use Commission as noted in the text. Efforts to contact staff from Colorado Counties Inc., the counterpart to Colorado Municipal League were unsuccessful.
-A case study in Mesa County was then conducted. This information was comprised of professional observations over a four year period in working with sewer policy development and implementation, interviews with County and City staff, attendance at over 40 meetings and hearings, and documentation about sewer service and general information related to the Grand Valley.
-By applying this information, a selected list of typical approaches to handling sewer service on the urban fringe and a list of criteria to be used in an evaluative matrix was prepared, to judge their performance.
Scope of Study
This Thesis, while acknowledging that the questions raised may be considered national in scope, focuses on the State of Colorado. Obviously, each state has its own legislation
regarding counties, and in fact, has variant traditions in
11


state legislation. In consequence, the thesis is limited to considering urban fringe areas of Colorado only, based on information available from state sources, and the experience of Mesa County. General issues associated with water quality and urban fringe growth relied on master works as noted.
13


[1] Colorado Department of Health. January, 1988.
"Colorado Sewer Needs Categorization List"
[2] Hollman, Howard. 1976. Small and Large Together: Governing the Metropolis. Sage Library of Social Research.
p. 12
[3] Council of Environmental Quality. 1974. Costs of Sprawl, Washington D.C.
[4] Scott, Randall W., Editor. 1975. Management &. Control of Growth: Volume I. The Urban Land Institute; Washington
D.C. p.37
[5] DeGrove, John M.. 1984. Land, Growth and Politics. Planners Press, American Planning Association; Washington D.C. Chapter 7, "Colorado: A State-Local Puzzle", analyzes the formation of House Bills 1041 and 1034, and the changing role of the State Land Use Commission.
[6] Ibid.
[7] U.S. Department of Commerce, Bureau of the Census; Population summaries for Colorado; 1960, 1970, 1980
[8] Binkley, Clark, et al; 1975 Interceptor Sewers and Urban Sprawl.Lexington Books, D.C. Heath and Company. Chapter One, Interceptor Planning and Land Use Issues pp.1-26.
al. 1976. pp.xi, Preface.
[9] Ibid
[10] Ibid.
[11] Tabor Richard D., Micheal Shapiro and Peter Rogers.
Land Use and the Pipe. 1976. Lexington Books. DC Heath and Company. p.4
[12] Interview, Dick Bowman, district engineer, Colorado Department of Health. August 30, 1988.
[13] Interview, Peggy Galligan, Grants Coordinater,
Colorado Department of Health, Western Slope. March 31, 1988.
[14] Interview, Duane Watson, Sanitary Engineer, Colorado Department of Health. March 31, 1988.
[15] Colorado Department of Health. January, 1988.
"Colorado Sewer Needs Categorization List"
14


[16] Municipal Interview, Sam Mamet, Deputy Director, Colorado League. February 12, 1987.
[17] Ibid.
[18] Ibid.
[19] Hallman, Howard. 1977. P.21
15


CHAPTER II
SEWER SERVICE ON THE URBAN FRINGE: THE CONTEXT
In this chapter are discussed the major factors associated with sewer service on the urban fringe of Colorado municipalities, and a case study of Mesa County to consider how these factors are applied in a specific location. By doing so, we can understand how key national and state water quality and land use concerns and legislation, and general principles of public finance have been involved in the development of prevalant types of sewer service on the urban fringe, and how counties can interpret these actions.
Sewer Service, Health and Water Quality: Key Issues -In the mid 19th century, studies in London conclusively proved the link between cholera epidemics and contaminated drinking water as a result of untreated sewage entering water supplies.[1] Since that time, sewage disposal and treatment has become a prevalent public concern. With this concern, system technologies dealing with water and sewage have undergone extensive change over the past 100 years. Information has been refined and added to concerning water quality standards. The basic problems, however, remain the same, and are faced continuously by the public sector at all levels: improper sewage treatment creates health hazards of
water borne diseases and water pollution.
16


In the 1900s steps were taken in the United States to overcome serious health hazards. Central cities across the nation were retrofitted with central sewage systems and pipelines, and chlorination was added as a purifying agent to treatment plants by the 1930s. With this innovation, typhoid and cholera outbreaks were reduced, and by the 1960s, virtually eliminated.[2] By the 1960s as well, government sponsored studies were conducted to determine the way America treated sewage. A U.S. Department of Agriculture report in 1968 found 44,709 communities without public sewer facilities in the United States.f3] According to the 1970 Census, 89% of the year round housing units in urban areas had public piped sewer systems, only 19% of rural homes did. Cesspools and septic tanks were used by 10% of the urban housing and 66% of rural.[4] Thus there has emerged two basic methods of dealing with sewage, collection and treatment
involving pipes and central facility, and individual on site systems.
Significant regulations were enacted for sewer system construction and performance during the late 1960s and early 1970s, in response to growing concern for and knowledge about water quality.T51 In 1968, the Federal Water Pollution Control Act mandated standards for secondary waste water treatment facilities, and a target date for requiring all public facilities to meet the standards. Colorado quickly followed with state adoption of the Clean Water Act in the


same year.T6] The Colorado Department of Health, Water Quality Control Division was assigned direct responsibility
for review and enforcement of central treatment facilities. Major problems encountered from an environmental health perspective have been inadequate management of systems resulting in discharge of polluted wastewater, plants operating over their capacity to treat incoming effluent, and antiquated primary systems which have no treatment for fecal choliform, biochemical oxygen demand, oil and grease, and temperature. While these latter factors of treatment do not threaten public health, they do adversely effect aquatic life in surface waters. The deadline for public facility compliance with the states Water Pollution Control Act has been extended three times, to June of 1988. As of this date, the Department of Health can for the first time enforce the Secondary treatment standards.[71
In 1972, the State of Colorado adopted minimum standards for individual sewage disposal systems, and banned further use of cesspools. (CRS 25-1-507D; 25-10-106; 25-10-104(2).) The guidelines were to be used in lieu of more restrictive standards set by local jurisdictions, either through the Board of County Commissioners or by a County appointed health board. The standards were considered an overdue step by advocates of water quality. In many cases, authorized on site systems consisted of dumping effluent into buried car bodies,


or direct discharge into irrigation canals. [81 While the standards have eliminated the future use of such practices, pre existing systems persist in rural areas, including the urban fringe of municipalities. In the same vein, enforcement of these standards has not been consistant in many counties, and the state has not placed a priority on forcing compliance.[9]
More difficult to monitor are the problems resulting from inadequacies of the standards. Adverse soil conditions, seasonally high Kater tables in irrigated areas, and drainage patterns have not been adequately addressed in the regulations, and have led to ground water contamination or surfacing sewage.[10] Another major deficiency is the minimum size of lot allowed for I.S.D.S.s. of one third acre, restricting system replacement. Since all ieachfields fail over time, lack of space on a building site to construct a replacement field has caused serious problems. Some counties for these reasons have chosen to enact more restrictive regulations for I.S.D.S.s, including larger minimum lot sizes, detailed soils reports, and enforcement as a priority. The majority, however, use minimum guidelines offered by the state. [Ill
In the 1970s, the federal Environmental Protection Agency moved from establishing water quality guidelines to
assistance in meeting the new standards. Two major programs
1"


were initiated as amendments to the Federal Water Pollution
Control Act: Amendments 201 and 208. The 201 Program, administered by the Environmental Protection Agency was intended to fund up to 75% of the cost of design and construction for local wastewater treatment facilities and major interceptor lines. Funding requirements called for the definition of a regional sewer service area where urban growth was expected, or where fringe development had located without central treatment facilities. Also required were population and discharge projections over a twenty year period to ensure that adequate capacity was provided for in the facility and major infrastructure. [12]
The 201 Program made significant impacts on local jurisdictions in Colorado; over 200 million dollars were spent between 1978 and 1988 on design and construction. The incentive has proven great enough to involve over 20 Colorado local jurisdictions in regional wastewater collection and treatment. [13] From an environmental health perspective, the Program has accomplished a great deal more than what was feasible under simple regulation, and has brought wastewater treatment to an unequaled level of importance. Since 1981, the EPA has delegated 201 grant administration to the Colorado Department of Health, with mixed results. While there has been advantages of combining the identification of
water quality problems in the state with grant
20


prioritization, there has also been a tendency for the grant award process to become more politicized, since the Water Quality Control Board, representing different locations in the state, has power over funding decisions.[14]
There are other significant sources of funding central sewer
systems in Colorado. The Colo Government in cooperation with Health began in the 1970s the Program. This action was inte treatment problems for communi criteria of the 201 Programs.
The 208 Planning Program was e water quality management plans identify needed treatment work problems, and identify agencie recommendations of the plans." funding was offered to regiona prepare plans in the 1970s, o of Health, Water Quality Contr regions. Despite these efforts related problems are still cit unincorporated areas. The fo cases of treatment failures, 1 health hazards, or sever water
rado Division of Local the Colorado Department of Small Sewers Assistance nded to address wastewater ties failing to meet the [ 151
stablisned to develop "regional to assess water quality, s, prioritize rater quality s to implement the [16] Technical assistance 1 councils of government to r have the Colorado Department ol Division prepare plans for health and water quality ed in Colorado, primarily in llowing table shows confirmed eading to potential and actual quality degradation.
21


Table 2-1
Wastewater Treatment Problems in Unincorporated Areas of Colorado
_____Class "A" Needs* Class "B" Needs* Total
Massive I.S.D.S 6 36 42
failure
Plant failure/
or overcapacity 25 9 34
(special district or private)
l 171
It should be pointed out that these are cases where state Health Department staff have been able to investigate and make reports on problems. There are several instances, as admitted by the staff, where septic tanks and leachfields are creating water quality problems but for various reasons have not been evaluated yet.
Sewer Service, Growth Management and Landuse Controls- Key Issues.
Once it became acknowledged as public environmental health concern, sewer service quickly became a priority in the management of landuse and growth. There are numerous reasons for this, with innumerable tangents. The intent here is to identify major issues relevant to sewer service on the urban fringe of municipalities in Colorado.
>o


During the 1970s, the nation was reacting to the phenomenon
of urban sprawl and the rapid development of urban fringes
around incorporated towns and cities. The intensity of this
reaction triggered statements from government and
professional leaders such as the following from Russell
Train, former Administrater of the U.S. Environmental
Protection Agency: "The issue of growth with environmental
quality has vital implications for our nation and the world.
And yet is is important that we recognize the wide diversity
of values and concerns involved. We should avoid dogmatic,
categorical approaches. We are in a period of evolution of
values and we should respect and encourage wide diversity of
views."[18] Professional and academic institutions as well
as governmental agencies sought to define moderate and
practical approaches to growth management. Answers such as
exclusionary zoning and zero population growth were not
considered adequate. Uncontrolled growth on the other hand
had resulted in environmental degradation, poor distribution
of services and higher costs of providing services.
As stated by Hallman, in 1975:
...metropolitan areas as now governmentally constituted arent well equipped to cope with population growth, the development of vacant land by housing, commercial, and industrial uses, and the expansion of public facilities.
Even though metropolitan growth is slowing down in some areas, other areas, particularly in the South and West, continue to expand, and all around the country growth is occuring in counties outside metropolitan areas..." [19]
23


While metropolitan areas gained the most attention, the effects of urban sprawl had been experienced by midsize and small communities as well. And as these municipalities were having difficulties providing services in the face of growth, county governments were also confronted with urban development.
Initially, approaches to growth management relied to a large extent on the traditional land use controls such as zoning and master plans. The major contributions of these tools were to reduce the uncertainty of landuse decisions, and guide growth into patterns more easily served by public entities. On the obverse side, "the evidence is that in developing areas, zoning has appeared to act more as a method of legitimizing prevailing trends than as a concerted tool of public land use policy. " [20] Comprehensive plans alone
were also considered insufficient to manage growth. The crucial link of implementing plans was control over services. As stated by Tabors et al, "In many areas, location of major public facilities tends to be far more significant in determining actual land use patterns than local zoning." [21] With regard to the other major planning tool available,
Kelley in his article, "Piping Growth", stated: "..it will be the decisions as to how these services (water and sewer) are allocated that ultimately control the growth and
development patterns of communities. The master plan may be
24


pretty, but the utility plan is potent." [22]
Sewer service was proven to be one of the major determinants to growth and land use patterns. Because of water quality standards imposed during the 1970's by the Environmental Protection Agency and parrellel standards adopted in states, pressure was brought to bear on development to be provided with adequate sewer service. Frequently this meant connection to central sewer facilities of the neighboring municipality. "Today marginal uses of on-site systems are much less likely to be approved by state and local public health officials. Sewerage collection and disposal systems must be available from the beginning of the land conversion process." [23]
Municipalities have in general considered consolidated sewage collection and treatment necessary for development. In cases where strong intergovernmental cooperative agreements exist between "host" counties and municipalities, development on the urban fringe has also been subject to this same standard. By controlling the extension of sewer infrastructure at the beginning of the land conversion process, the central municipality is afforded the opportunity to evaluate landuse changes in light of other services such as water and access. Other considerations such as the pacing of development on the urban fringe and its contiguity with existing urban areas may
also be taken into account. There are certain legal
25


limitations to this method of control, as evidenced by the case The City of Boulder vs. Boulder County. In such cases, a municipality can not prohibit the connection of properties from its system, if capacity is available and the controlling authority of the county approves a development. [24] Despite such limitations, the importance of first assuming the need for central sewer, and then enabling the central municipality to control such service should not be underestimated. In many counties, however, such coordination has not been the case.
The 201 Grant Program, when first initiated made a significant impact on landuse planning and growth on the urban fringe, and by some accounts became a driving force in the further development of fringe areas. Because of the impetus for twenty year projections and the money involved with creating large sewage treatment facilities municipalities were compelled to accept engineer consultant projections for growth. [25] As will be seen in the case of Mesa County and Grand Junction, these projections and the regional boundaries helped encourage dispersed development patterns far from the central city boundaries.
It is appropriate to turn to Colorado at this point in the narrative. Legislation and experience varies from state to state, and as charac.terized by J. Degrove in his book, Land
"States occupy a leverage point in the
2o
Growth and Politics:


federal system that is of special importance in this policy area. If they choose to exercise it, states have the ultimate power over local governments in land- and growth-management matters." [26]
In 1974, tbo direction of land use planning in Colorado was defined by the two landmark House Bills of that year, 1041 and 1034, and the passage of senate bill 35, requiring subdivision regulations for all counties in Colorado. House bills 1041 and 1035 granted extensive authorities to local governments in the control of land use and growth, if local governments chose to adopt procedures under the enabling legislation. In sum, these bills represented some of the most substancial actions on the part of state government regarding land use in the country. [27]
In House Bill 1041 the intent was to identify areas and activities of state interest, and provide a permit procedure to mitigate impacts associated with such lands or actions. While frequently disputed as to its interpretation, the 1041 regulations have been used largely in the control of projects of major impact in localities, such as the proposed Homestake II Reservoir in Eagle County.[28] House Bill 1041 as written may be applied to consider growth in a comprehensive manner,
taking into account environmental features as well as
27


services, it has rarely been used in this way, except in Douglas and Pitkin Counties. In part this is due to the ambivelant relationship between the State and its subdivisions. The process of implementing 1041 regulations involves the State Land Use Commission, which tended to act as a deterrent, rather than an incentive for many counties. [29]
House Bill 1034 of 1974, was meant to clarify and broaden the realm of local government authority over land use and development. In many ways the consequences of this legislation was much more far reaching, in the sense that it enabled but did not supervise counties' enaction of landuse controls and the consideration of the various factors associated with development: services, environmental features, potential conflicts in landuses.
Senate Bill 35, intended solely for county governments, required the adoption of subdivision regulations, and a review process that included consideration of water, sewage, soil and geologic hazards, and dedication of money or land for public school and park sites. The Bill, taken at face value, could have effectively curbed the continuation of urban fringe problems with sewage disposal, and enabled counties to consider the spectrum of services when considering new development. Senate bill 35, however, did
not go far enough in defining appropriate levels of service
28


on the urban fringe. Counties in Colorado still exempt "land splits" from regulation, and to approve a variety of sewage disposal methods within general parameters set by the State Health Department. This in essence has made service controls by a central municipality ineffective to manage growth at their urban fringe. House Bill 1034 has also not been able to change this situation to any great extent. [31]
Studies sponsored by the Colorado Land Use Commission in the 1970's demonstrated the ongoing problems of growth at the urban fringe of central municipalities. In one report, "Citizens View of Land Use in Colorado" published in 1976, the question was raised, "Do land use changes in municipal fringe areas affect interjurisdictional relationships and local land use programs?" The response was as follows:
i. strained relationships between county and city
ii. developer playing county against municipality;
iii. confusion and complication in providing services
iv. complication of capital improvement planning of municipalities
v. competition for land through accelerated annexation;
vi. creation of urban sprawl, leapfrog development, agricultural land conversion, open space loss
vii. proliferation of special districts. [30]
These points summarize well the underlying issues associated with the urban fringe and, by implication, sewer service in the 1980s as well as the 1970s. In 1983, the Colorado Division of Local Government prepared an overview of landuse
29


planning in Colorado, and pointed to interjurisdictional cooperation as the premiere concern facing the state. "The need for interjurisdictional cooperation is becoming increasingly evident as areas on the urban fringe of municipalities continue to develop." While all counties in Colorado have adopted subdivision regulations, only 9 out of 63 counties have "an operational landuse management system in place, including adopted policies, plans, regulations and the administrative structure adequate to manage anticipated growth." [31]It is worth noting that this concern was articulated at a time when several laws were passed as inducements to municipalities for extraterritorial planning:
9 separate statutes authorize interjurisdictional planning and regulation, and empowers municipal control over planning beyond incorporated limits ( CRS 31-23-212,213; 31-15-401-601; 31-15-707 *,31-25-216,302,303;31-2 3-255; 30-28-136 ; 29-20-105; 30-28-105;29-1-203)
The reluctance indicated by the lack of cooperative management of the urban fringe is difficult to define. In many cases, competitiveness between municipal and county jurisdictions have formed barriers, as well as the perception that munipalities are more intrusive forms of government, and thus less desirable. As Hallman observed in his work, Governing the Metropolis, counties as they have historically evolved simply lack the administrative stucture or the
percieved responsibility for managing urban growth.
30


The proliferation of special districts, noted by the "Citizens View" Report certainly represents another reason municipalities have not been able to control the growth around their boundaries. Special districts have also created an impetus to bias development in areas otherwise inappropriate for growth. In a report distributed by the Colorado Municipal League, it was noted that over 900 independent special districts were in operation in the state, the majority providing sewer service as part of their functions. [32] In the complexity of legislation regulating special districts, one outstanding feature prevails in this discussion; service plans must be submitted and approved by the Board of County Commissioners in whose jurisdiction they are locating. In the course of development on the urban fringe when sewer service is considered necessary by a county government, the incremental solution has frequently been the formation of a special district.
In the ill fated "Human Settlement" Policies, developed by the State Division of Planning, the topic of the urban fringe was addressed obliquely. While the Policies in general encouraged consolidated, contiguous growth to municipalities because these entities are more capable of dealing with the needs of urban populations, they made a notable exception:
"..if growth is occurring adjacent to an incorporated
31


municipality and in compliance with the growth plans of that municipality, it is not necessary that the specific area be included within the incorporated boundary." [33] When we are reminded that very few counties in Colorado have intergovernmental agreements with central municipalities, this concept does not appear very workable.
These points lead to the outstanding theme of this thesis. Despite several efforts, most notably in the 1970s, to define a state wide approach to landuse, an evolutionary decision has been reached about growth and management of services on the urban fringe of municipalities in Colorado. The decision appears to be that counties, while not encouraged to accept urban growth on the fringe, have not been restricted from doing so; the effect has been a fragmented approach to managing services including sewer service. Areas besides the Grand Valley of Mesa County have shared this characteristic when contending with development pressures, including West Glenwood Springs, and areas outside of Durango, Montrose, Gunnison, Delta, Fort Collins, Greely, Pagosa Springs and Loveland. [34]
Financial Aspects of Sewer Service on the Fringe: Key Issues.
Besides being a matter of importance from the standpoints of water quality and planning,
sewer service has financial
32


ramifications for the individual and public entities. Ma.jor points for the purposes of this discussion include the relationship between costs and benefit or the question of equity, and the methods of financing.
The premise of distributing costs of a public good on the basis of benefit is one of the cornerstones of public finance policy.[35] Since the 1960s, it has been recognized that there are social and environmental benefits as well as monetary benefits (in the form of enhanced property values) as a result of sewer improvements. [36] These benefits in theory should define the distribution of costs of an improvement, and the scope of improvement itself. but it is difficult to accurately define to what extent such benefits are to be reflected in the assignment of costs. While courts generally favor a public entity if a reasonable relationship between cost assignment and benefit recieved is found to exist, [37] elected officials are hesitant to press such an issue if it is politically unpopular.
Given the regulatory parameters of sewer service, urban fringe areas have been granted a high degree of latitude for selecting forms of sewer service. If the decision is to be made by an individual wishing to build a home, the choice of sewer treatment will tend to be the least expensive. When
33


the real estate market of an area makes large lots financially viable, the the most financially exedient option for sewer service is typically a septic system and leachfield, rather than a sewer line extension, connection fees and the monthly charges associated with a central sewage system. Long term environmental costs as a result of degraded water quality from concentrations of on site systems are not generally the concern of the individual property owner, or developer.[38] The same holds true for developments involving higher densities than one unit per 1/2 acre. In this latter situation, the most affordable method of treatment is percieved as a package plant serving a subdivision or a sanitation district to serve a neighborhood.[39] This perspective is also translated into the collective attitudes of the county governments governing the fringe. Unless a recognized health hazard emerges from prevailing methods of sewer service, such as concentrations of on site systems, inadequate methods of service will continue. [40]
One interesting result of the EPAs 201 grant program has been an acknowledgement that the provision of secondary wastewater treatment through a central facility is a mixed benefit. There are in fact benefits derived by the American public at large because water quality will be improved when minimal treatment is eliminated. The financial incentives
offered by the grant program has induced local governments to
34


begin making a transition to regional systems in the fringe area. The problem then arises of financing connections to the central system, distributing those costs equitably, and in a manner that is affordable to homeowners. As will be seen in the case study of Mesa County and in the next chapter describing alternatives, financial aspects effect local governments decisions about sewer service to a great extent.
Mesa County, Colorado: A Case Study
In order to consider in detail the issues discussed, we now turn to a case study of Mesa County, and its experience with sewer service in the grand valley.
General Discription:
Mesa County encompasses approximately 2.133 million acres of land, of which 1.5 million acres (71.5%) fall under federal ownership, specifically the U.S. Forest Service, Bureau of Land Management, and the National Park Service. The remaining land is distributed under the following general purpose governments jurisdictions:


Table 2-2
Acreage in General Purpose Governments in Mesa County
Jurisdiction_________________________Acreage______%
City of Grand Junction 8,960 .42
City of Frui ta 2,017 . iO
Town of Palisade 300 .01
Town of Collbran 107 .01
Town of Debeque 191 01
Mesa County 1,450,000
f 42 ]
Maps 2-1 and 2-2 show Mesa County and location of general purpose jurisdictions.
The population for these jurisdictions in Mesa County were
as
follows in 1980:


Table 2-3
1980 Population in local governments of Mesa County
Jurisdiction___________________________Population
City of Grand Junction 28, 144
City of Fruita 2,810
Town of Palisade 1,551
Town of Collbran 341
Town of Debeque 278
Mesa County 48,406
Total 81,530
Mesa Countys increase from of population two-thirds of
population in 1980 represented a 39.4 %
1970, exceeding both state and national trends growth for the same period. Significantly, the population increase of that decade was


located in the unincorporated areas of Mesa County. Outside of estate development through exemptions in the orchard areas surrounding Palisade, the population centered in the area known as the central Grand Valley. [44] (Map 2-3).
History of Development in the Grand Valley:
This 15 mile corridor traversed by the Colorado River was the initial area of settlement in Mesa County during the 1800s and early 1900s. The Valley, being relatively flat and accessible to River fed irrigation and water supplies from the upper elevations of the Grand Mesa, became an agriciiltural oasis in the desert of the Colorado Plateau. By the 1940s, the entire valley was under irrigation, with the town of Grand Junction at its center, Palisade and Fruita as its anchors. [45]
As early as the 1950s, development outside of the municipality of Grand Junction was enough to warrent formation of special districts to provide urban services of water and sewer. Clifton, an unincorporated area 5 miles to the East of Grand Junction, became a separate community with water, sewer and fire protection provided by special districts. The residential area of Orchard Mesa, separated by the Colorado River from Grand Junction to the North, formed a sanitation district to relieve homeowners from failed septic systems on small platted lots. [46]
--Q
also


Development also occurred, using septic systems, in the floodways of the Colorado and Gunnison Rivers next to the City of Grand Junction, but separated by the River channels. Indeed, the Gunnison and Colorado Rivers acted as formidable barriers to a logical extension of utilities from Grand Junction; the Citys initial reluctance to make expensive service investments in turn helped set a pattern of urban development in unincorporated areas. By 1960, Mesa Countys total population was 50,175, with the City of Grand Junctions population only at 18,694. [47]
During the 1970s, massive inmigration as a result of oil and gas development changed the character of the Grand Valley.
The City, being land locked by other service entities did not experience substancial population increases. Areas to the East, West and South of the City, however, were developing at a fast rate. To the east, sanitation districts were formed and expanded to serve new developments; to the West, an area known as the Redlands converted from orchard lands to housing tracts at an astounding pace. Rather than create special districts, however, the new housing on the Redlands was served by septic systems or package plants installed by developers and transferred to homeowners associations. By 1979, the Valley was checkered with urban sprawl and leapfrog growth.


The Clifton Area, with a population of approximately 15,000 in a 15 square mile area reaching West to Grand Junctions municipal limits, had 50% of the land area vacant, the rest in scattered subdivisions of 4 or more units to the acre.
The Redlands had an estimated population of 8400 persons, or roughly 2500 homes served by either package plants or on site disposal systems. In total, 18 different managing entities of central sewer service, either collection or collection and treatment were located in the Grand Valley, excluding the City of Fruita and the Town of Palisade. [48]
The City of Grand Junction had, by 1976, managed to connect three outside sanitation districts to its treatment plant, adding 6417 residential taps, although the City had not annexed these areas. The connections in turn created a problem in treatment capacity; with an estimated 1240 new housing units approved for development in the connected unincorporated service area, the City was compelled to find funds for a greatly expanded treatment facility. In the meantime, five package plants in the Grand Valley u'ere cited for violations of water quality standards by the State Health Department, due to chronic operational problems and mechanical failures. Septic systems on lots of less than 1/2 acre were also failing, particularly on the Redlands, causing confrontations between homeowners and local health officials. [49]
40


a m i i
m \
i
VICINITY MAP
FIGURE I


The culmination of these factors was an effort by Grand Junction to obtain a 201 Grant from the EPA in 1977. Because the City had invested in other capital improvements, no further debt could be incurred for the 25% match required for the 201 Grant. This brought Grand Junction officials to Mesa County, asking for cooperation in the construction of a regional facility and key interceptors to outlying areas on the Redlands.
It is appropriate at this point to consider Mesa Countys role in the development of the Grand Valley. It is an excellent illustration of the inherent problems in the way county jurisdictions dealt with urban fringe growth. In order to understand how this is the case, it is important to
examine the interaction of planning and other considerations with the scenario outlined above.
Mesa County was ahead of most other county jurisdictions in establishing landuse controls in Colorado. In 1961, a county wide planning commission and zoning resolution had been created, and upheld in the Colorado Supreme Court when contested. The intent of the zoning at the time was to designate the central grand valley as suitable for urban development, and the remainder of the county for agricultural/forestry uses. The effect of this zoning pattern was to allow isolated development to occur beyond the
central municipality of Grand Junction, with little
41


little consideration given to contiguous growth. The zoning, in fact, tended to justify the manner in which Grand Junctions urban fringe was developing at the time. [50] With the existence of special districts to provide basic services, and health regulations allowing use of septic systems on small lots, growth boundaries were established by the road networks within the grand valley.
Domestic water supplies and distribution systems supported the dispersed nature of development in the grand valley. The City of Grand Junction owned sufficient water rights for its own jurisdiction, and for neighborhoods immediately east of its incorporated boundaries. Further east, the Clifton Water District -served a 15 square mile area for residential and farm users. In 1963, the Ute Water conservancy District formed by state statute and granted 9.3 million dollars by the Federal Housing and Home Finance Authority to relieve farm residences using cisterns. As a result, the entire grand valley, from the Utah state line to Palisade was blanketed with two inch water lines at 1/2 mile intervals, corresponding to the farm-to-market road network already in place. Conversion from agricultural users to urban fringe users was swift. Ute Water Conservancy District began with 1800 customers in 1965, and by 1983 estimated approximately 17,000 residential users. [51]


A Master plan had been jointly adopted by Grand Junction and Mesa County for the central grand valley, and a regional planning commission formed to oversee its drafting and implementation. the assumptions at work in this plan concur with the intent of the zoning; population projections supported the complete development of the central grand valley, and predicted services capable of supporting in excess of 130,000 people by 1994. The question of sewer service was not addressed, except to allude to the establishment of sanitation districts and expansion of the Grand Junction facility and infrastructure. Pacing of development was seen as less important than the assurance that at some point the valley would be an urban area. [52]
After the adoption of the central Grand Valley master plan, subdivision regulations were established in Mesa County, in 1972. the regulations did call for the requirement of central sewer service for all major subdivisions, although no mention was made of connection to the municipal system. Between 1972 and 1979, eight package plants were approved for subdivisions in the grand valley, primarily on the Redlands.
[53]
By 1975, it had become apparent that the prevailing wisdom regarding growth in the grand valley created certain joroblems. Demands for public services, including better roads and their maintenance, police protection, parks and


open space, schools, and water lines sized for fire flows far exceeded the abilities of local government to provide them. Capital improvements made by the various service entities were not coordinated between themselves, creating inconsistant levels of urban services to support the burgeoning scattered population outside of Grand Junction.
[54]
It should be stated that the joint city/county planning department as well as a Valley wide sewer Committee, formed by concerned citizens, forsaw these series of events, and sought correction. Mesa County in fact had adopted 1041 regulations, and signed cooperative planning agreements with the city of grand Junction in accordance with CRS 30-28-105 and 29-20-105. The "Mesa County Sanitation System: Master Plan Report", financed by the Four Corners Regional commission in 1974, recommended the following: "A county sanitation department appears to be essential to provide responsible representation for the entire community." [55]
The inherent conflicts however, between controlling growth due to percieved future service inadequacies, and the interest of other service entities to promote growth and thus add revenues, set planning at a disadvantage. The ineffectiveness of planning also reflects the conveatial wisdom of the time, that engineering prerogatives outweighed generalist planning priorities. The planning department
tended to be set apart from the basic service entities
44


including the county road department, creating long standing disputes between the various entities involved with development in the grand valley. [56] The Master Plan report for sanitation in Mesa County disappeared from county records, and left in the archives of the state health department.
In the 1970s, rather than take a dominant position in the needed coordination, Mesa county acted in its traditional role of providing better roads where the road supervisor felt they were needed, and relied on the actions of other entities to provide required services. With regard to sewer service, the county board of commissioners appointed a separate board of health to oversee the regulation of individual sewage disposal systems. No service plans of any special district created in Mesa County had ever been rejected or amended, despite evident conflicts between the ability' to provide sever service and levels of other services. This held true outside of the central grand valley; a sanitation district proposed next to Palisade, roughly three times the sice of that municipality was endorsed by the County, even though the area was zoned agricultural and intensively farmed in orchards. This action xvas followed by a blanket rezone of the area into multifamily housing (12 dwelling units per acre) [57]
In 1980, the City of Grand Junction solicited the help of
4 5


Mesa County in obtaining a 24.5 million 201 step III water quality grant. The local match of 6.7 million dollars had to be obtained by revenue bonds, exceeding the debt ceiling of the City. The county agreed to sponsor the financing under certain stipulations; the city utilities department would, manage the new system, including maintenance, design management, billing and preparing an annual budget. [58] The intent of the stipulations was clear: the County would continue to "stay out of the sewer business", as one Commissioner stated. [59] This perception represented the underlying philosophy that the urban fringe was not the responsibility of a traditionally rural county government, but of other service entities. Acceptance of development was a responsibility that could not be delegated to other entities, and was presumed positive.
By 1983, this perception was losing viability. Many of the septic systems installed during the 1970s were failing, forcing the board of health into a more assertive posture towards compliance with state regulations. With the installation of interceptor sewer lines as part of the 201 grant, connections were now being required by the City of Grand Junction, triggering appeals to the board of county commissioners. In 1983, the state legislature for the first time enabled local improvement districts to be formed by county governments to finance sewer or water lines,
attracting petitions for district formation in speculative
46


ventures. Finally, the expected rate of connections to the sewer facility was not occuring, causing serious concern for maintaining the debt payment schedule. [60] The cumulative effect of these circumstances was to change the scope and. definition of sewer service, from a necessary function for health and water quality, to a complex financial and land use problem involving county government.
Mesa County and Sewer Service Policy:
Mesa County administration in 1984 formed a taskforce made up of staff from engineering, finance, attorneys office, planning and road departments, and included Ci t y s ci ff to develop a policy for sewer service in the grand valley. The general problems were identified, and alternative recommendations set forth. The following major points were proposed:
-The county should acknowledge their participation in sewer service in the grand valley, and assign ongoing duties to the involved departments accordingly, with additional staff as needed, including a utilities engineer, and planner.
-Connections to the regional sewer facility were crucial, and should be enforced in all circumstances. A study should be commissioned to determine the drainage subbasins of the valley, and prepare engineered designs for lateral sewer


lines to connect with interceptors, to avoid poorly located inf rastructure.
-Because of the potential for burdoning an individual with the cost of an entire sewer line because of I.S.D.S. failure, the County would promote the formation of local improvement districts, distributing costs to all properties dei-iving benefit from the improvement.
-The zoning of the grand valley would be reviewed, and the County would pursue down zoning in areas where sewer could not be feasibly extended such as flood plains, and rezoning to higher densities where sewer and other services were available. [61]
While the policies were adopted in 1985, implementation has met with strong barriers. These include the unwillingness for individual property owners to participate in local improvement districts when their on site systems have not yet failed, and the inherent problems of leapfrog growth, where owners of undeveloped property resist financing line extensions of no immediate benefit. The County has not provided the staff necessary to implement rezoning proposals or pursue public education regarding the need for sewer connections. Finally, the management agreement passed by the city and county included an annexation clause for all connections, and this requirement has been vehemently opposed


by fringe area residents. [62]
Summary
As described in this chapter, sewer service has proven to be a major predeterminant to growth of urban fringe areas in Colorado, although there are different levels of service, each having implications peculiar to themselves. The types of sewer service allowed or encouraged under federal and state guidance, as well as the physical constraints of the service itself have effected the decisions made at local levels regarding growth and development. Other state actions regarding land use planning and general approaches to growth management have also exerted great influence at the local level in Colorado. The conscious combining of these two public concerns, planning and sewer service has, however, not been strongly enforced at any level. Other concerns besides public health, water quality, and land use planning have been considered important, including the way sewer service is financed, other environmental problems and the effectiveness of managing a service. By taking this information, we can establish the basis for conducting an evaluation of different sewer service on the urban fringe of Colorado municipalities.
49


Notes for Chapter II
[I] Warner, Dennis, and Da.jani Jarir S.. Water and Sewer Development Rural America. 1975. Lexington Books, D.C. Heath and co. Lexington Massachusetts. p. 23
[2] Ibid. p.23
[3] Ibid, p.6
[4] Ibid. p.5
[5] Tabors, Richard Lexington Books, D.C. D. etal. Land Use and The Pipe. 1974. Heath and Co. Lexington, Mass. p4
[6] October 18, 1988 . Interview with Duane Watson, Colorado
Department of Health.
[7] August 29, 1988. Interview with Dick Bowman, District
Engineer, Western Colorado Division, Colorado Department of Health.
[8] Ibid.
[9] Ibid.
[10] July 7, 1986. Interview with James Meiklejohn, Sanitarian, Mesa County Department of Health
[11] Binkley, Clark, etal.1975. Interceptor Sewers and Urban Sprawl Lexington books, D.C. Heath and Co. Lexington, Mass, p. xi. Preface. April 12, 1988. Interview with Peggy Galligan, Grants Administrater, Colorado Department of Health
[12] Galligan Interview. Ibid
[13] Ibid.
[14] Ibid
[15] Ibid
[16] Colorado Department of Health, Water Quality Control
Division Water Quality Plan For Region 11. . September, 1986.
p. 3
[17] Colorado Department of Health, Water Quality Control Division."Annual Report on Waste Water Treatment
Needs". January, 1988.
[18] Ed. Randall Scott. Management and Control of Growth:
Volume I 1975. Urban Land Institute, Washington D.C. p.42
50


[19] Hallman, Howard W. Large and Small Together: Governing
the Metropolis. 1977. p.12
[20] Land Use and the Pipe, p.2
[21] Ibid, p.3
[22] Kelly, Eric Damian. "Piping Growth: The Law, Economics and Equity of Sewer and Water Connection Policies." 1984. Land Use Law and Zoning Digest 36, no.7 p 3
[23] Land Use and the Pipe. p.4
[24] "Piping Growth: The Law, Economics and Equity of Sewer and Water Connection Policies."
[25] Interceptor Sewers and Urban Sprawl
[26] DeGrove, John. Land Growth and Politics. 1984. Planners Press, American Planning Association, Washington D.C. pp. 1-2
[27] September 15, 1988. Presentation by Gerald Dahl, "House Bill 1041: A Primer" 5th Annual Planners and Planning Commissioners Fall Conference, A.P.A. Colorado chapter.
[28] Ibid. Gerald Dahls Presentation
[29] "Land Use Planning in Colorado". 1983. Report prepared by the Colorado Division of Local Government.
[30] Land Growth and Politics. pp. 302-308
[31] Ibid.
[32] Colorado Land Use Commission. "A Citizens View of Land Use in Colorado". 1976. p.ix.
[33] "Land Use Planning in Colorado.
[34] "The Role Of Special Districts in Colorado" Report published by the Colorado Municipal League, Denver, Colorado. 1984.
[35] "Human Settlement Policies". The Division of Planning, Colorado Department of Local Affairs, Denver,
Colorado. July 20, 1979. pp.9-10.
[36] April 12, 1988. Interview, Duane Watson, Colorado Department of Health, Water Quality Control division.
[37] Aronson, J.Richard and Schwartz, Eli, Ed. Management Policies in Local Government Finance Internation City Management Association. 1981. Part two: Revenue sources, pp.121-209.
51


[38] Interceptor Sewers and Urban Sprawl
[39] Colorado Supreme Court ruled on the general question of benefit in the following case: (1941) Colorado Supreme Ct.
no. 128; "Gordon vs. Wheatridge Water District.".
[40] Several meetings were held with residents on the Redlands area, during the spring and summer of 1986, and in the spring of 1987, where virtually all property owners voiced these views. Interviews with state and local health officials as cited above confirm the sentiments expressed at these meetings.
[41] Ibid.
[42] Ibid.
[43] Mesa County Data Book. Prepared by the City of Grand Junction and Mesa County Planning Departments. 1985.
[44] Ibid.
[45] Ibid.
[46] Ibid.
[47] "Carrying Capacity Study for the Grand Junction Area". Prepared by Paragon Engineers, Grand Junction, Co. November, 1979. Funded by the Colorado Oil Shale Trust Fund.
[48] Mesa County Data Book
[49] U.S. Department of Commerce, Census Division, 8th Summary; 1980; also, housing studies conducted by Mesa County Planning Department, under Metropolitan Planning Organization funding. 1986 .
[50] "Carrying Capacity Study for the Grand Junction Area"; also, interview with Dick Bowman, District Engineer,
Colorado Department of Health, Water Quality Control Division.
[51] Minutes of the Board of County Commissioners, Mesa County, Co. February July, 1961. Mesa County Clerk and Recorders Office, Grand Junction, Colorado.
[52] November 17, 1988. Interview with Gary Matthews, engineer with Ute Water Conservancy District.
[53] Grand Junction 1980 ; Master Plan. 1970. Prepared by Small-Cooley and Associates, Denver, Co.
52


[54] Permit records of State Health Department, Water Quality Control Division, Grand Junction, Co.
[55] p.45
[56] Numerous interviews during spring and summer of 1988 with Robert Engelke, Cliff Davidson and John Ballagh, employed as planners with the Mesa County/Grand Junction Development Department during the years 1972-1981.
[57] Minutes of the Board of County Commissioners, Mesa County, Co. 1973. Mesa County Clerk and Recorders Office, Grand Junction, Colorado.
[58] " Mesa County/Grand Junction Sewerage Agreement." May 18, 1983.
[59] Meeting with Mesa County Commissioners, August of 1985.
[60] These concerns and matters were voiced in a series of taskforce meetings from September of 1984 to August of 1985.
[61] "Mesa County Sewer Policy Paper". 1985. Prepared by staff of Mesa County and Grand Junction.
[62] Meetings on Redlands as cited above.
j
53


CHAPTER III
ALTERNATIVES FOR SEWER SERVICE IN THE URBAN FRINGE
As described in the 2nd chapter, methods of sewarage are defined in fringe areas of Colorado by a number of parameters: regulatory, financial, environmental and
planning factors all contribute to this definition. Despite these limitations, however, there remains a vide range of approaches. Subsequently, in order to bring the number of alternatives to workable porportions, some generalization is necessary, as well as elimination. The four alternatives selected for evaluation represent feasible and likely methods sewerage is or will be handled on the urban fringe areas of Colorado communities. They are as follows:
-Decentralized approach, site disposal systems and,
Treatment of wastewater by on occasionally package plants.
-Special District Approach. Treatment and collection provided by independent Title 32 special districts.
-Regional approach. Treatment and collection provided by central municipality in cooperation with county, or by a regional authority.
-Mixed approach. A combination of special districts


interspersed with individual sewage disposal systems and
package plants, has evolved in the fringe areas. This has been followed by a regional system superimposed on the existing uses.
Decentralized approach:
Before the adoption of state and federal water quality regulations in the early 1970s, the installation of septic systems and other on site systems to serve homes on the urban fringe of municipalities was prevalent. This form of sewage disposal, however, is still commonly used in unincorporated areas, including those next to central cities and towns. There*are a number of reasons for the popularity of onsite disposal systems and package plants. One is the reliance placed on state regulations to provide adequate standards for health and water quality, coupled with a high priority placed on an individuals choice of services. Another major factor is the lack of cooperation between the central municipality and county government in managing sewer-service for an urbanized area. Finally, septic systems remain the cheapest and most simple method of dealing with sewage for an individual homesite. fl]
As fringe development occurs, by the subdivision of land or land splits by exemption, the question of adequate sewer


service is raised, in accordance with Senate Bill 35. If densities are of 1/3 acre or less, on site disposal systems may be proposed; this allows a developer to defer costs of sewer service to the point of obtaining a building permit, and thus reduce the total front end cost of developing the property. Such a subdivision proposal is usually accompanied by a soils feasibility report to determine it there is adequate percolation of filtered wastewater back into the ground, and the level of water table provides adequate distance between the system and ground water resources. [2] If densities of a proposed subdivision are greater than 1/3 acre, a package plant can be installed.
The plant would then be managed by the developer and ultimately a homeowners association.[3] The responsibilities of reviewing and approving the proposed treatment is delegated to the local health department in the case of individual systems, and the state health department for package plants.
The central municipality has little or no involvement in determining the type of sewage treatment to be allowed in this approach. It may be that the plant capacity of the municipality is reached, requiring an expansion that is considered undesirable or too expensive. This situation in turn would limit the ammount of influence a municipality has in controlling the type of sewer service beyond its boundaries. The lack of communication between a county
56


government and municipality about the development of the fringe in general would also lead to different forms of sewer service between incorporated and unincorporated areas.
The countys role in this approach is guided by state regulations for water quality control in the treatment of sewage, requiring little deliberation or planning. In the same vein, ongoing maintenance responsibilities, enforcement of standards, and local government intrusion into the private sectors decision making process tends to be minimal. There are notable exceptions, where counties have restricted the use of I.S.D.S. s to parcels of five acres of greater, effectively limiting the extent of urban development in the fringe areas of central municipalities, including Pitkin and Summit counties. In this case there is some conscious melding of landuse decision making and the choice of sewage treatment on the fringe. It could also be said, however, that these cases indicate a restriction on the development of the urban fringe, and thus do not decisively fall under the leading topic here: coping with sewer service on an urban fringe.
In a sense, this alternative is a precursor to other methods, in that it represents a situation where the urban fringe has not been defined in a comprehensive way and other methods of sewerage are not yet available or have not yet been considered. The decentralized approach also represents


an area not entirely urbanized. The individual on site
system, while being the least expensive as a sewage disposal method, also requires the most land per dwelling unit. The gains realized by the lower cost of sewerage could actually be negated as an area becomes more urbanized and other costs, such as property values and other services rise. Map 3-1 portrays the Grand Valley of Mesa County under the use of individual sewage disposal systems.
The Special District Approach
Title 32 special districts, either sanitation or multipurpose, including sanitation as a function, are the next most common form of sewer management in urban fringe areas of Colorado and have been authorized by the state legislature since 1939.[4] The following table shows that special districts have steadily increased in numbers in Colorado although the rate of their formation has declined since the 1960s.
TABLE 3-1
SPECIAL DISTRICTS INVOLVING SANITATION IN COLORADO
1955 1971 1982
Sanitat ion 60 152 120
Water/Sanitation 22 149 159
Metropolitan 1 6 86


Special districts are generally formed under two sets of motivating circumstances. The first is a massive failure of individual sewage disposal systems or contamination of water supplies in a given location, creating a potential or actual health hazard that must be corrected. The effected property owners are either unable or unwilling to connect to a neighboring municipalitys central sewer system and form a special district instead. In the second case, a "developer" district is formed, so named because the service to be provided is in anticipation of growth, and the developer, or property owner involved percieves a special district as the most feasible way to accomplish their objectives. In either case, a special district typically includes a central treatment facility and accompanying collection system to serve properties in its boundaries. [61
Formation involves the acceptance of owners representing a simple majority of the property to be included in the District, and certification of required documents by the district court. The county government in whose jurisdiction the district is being formed has the potentially powerful role of approving a special districts service plan, at least since 1965, upon passage of the Special District Control Act. More recently, amendments to this Act in 19S5 require the reviewing county to disapprove service plans of


a proposed District if one of the following circumstances applies:
1) there is insufficient existing need
2) if existing service is adequate
3) if adequate service is or will be available to the area
through other existing municipal or quasi-municipal corporations within a reasonable time and on a comparable basis. [7]
Cnee formation has taken place, a board of directors is established to oversee management of the District. The board has the authority to incur bonded indebtedness for the capital improvements of facility and infrastructure. The type of bonds that may issued are either general obligation, assessed as property tax and requiring an election, or revenue bonds based on the projected funds acquired by connection fees and service charges. An ad valorum property tax can also be assessed for operations and maintenance, without an election. [8]
The responsibility of making decisions about sewer service on the urban fringe in this alternative is one step removed from the individual, who transfers this power to the board of directors of the special district. The district in turn must adhere to state statutes in its management, with the State Health Department and Division of Local Government as


regulatory agencies. A countys role is limited to the formation process. Even in this capacity however, counties have not tended to exert a great deal of influence. Prior to the 1985 amendments of the Special District Control Act, many counties questioned their ability to deny a service plan of a proposed district.[9] This attitude was indicative of the lack of involvement asserted by counties in Special Districts as a method of managing sewerage.
The fact that special district formation involves central treatment infers that development at urban densities are to be allowed by the effected county government in the subdivision review process and in zoning classifications.
It is significant that no master plan is required that designates an area as suitable for urban development before a district can be formed to provide urban services in that area. [10] The 1983 Special District Control Act simply states that there should be Map 3-2 shows the Grand Valley with sanitation districts, basically the configuration prio to the Persigo 201 Project.
Regional Approach
This approach consists of a central municipality extending service to outlying fringe areas wdth the passive or active cooperation of the host county government. There are


certain conditions necessary for the regional approach, when a central municipality relies on funding' extensions generated by connections and service charges, or is dependant on property or sales tax revenues. This set of circumstances includes the following:
-The municipality has the capability and interest to extend services into areas beyond its incorporated boundaries.
-Title 32 Special Districts are either not present or are experiencing insurmountable problems with treatment and must connect to the municipal system.
-Development is either not vet occurring, or is in a patter that is consolidated enough to have sewer lines extended in an affordable manner.
By extending lines, the municipality creates a contiguous service area for the immediate urban fringe. The degree of cooperation between the central municipality and the host county government will help determine the effectiveness of this regional approach to sewer service. In many cases, the central town or city may extend infrastructure to serve property immediately surrounding its boundaries, only to have a secondary fringe established beyond its radius of influence, using the first two alternatives. If, however,


the host county has entered into an intergovernmental agreement with the central municipality for an urban service area this side effect may be reduced. The host county would also need to implement land use controls to restrict development outside of the urban service area, adopt a master plan supporting municipal extensions as a predeterminant to urban landuses, and apply municipal standards to subdivisions. Powers created under the landuse legislation of 1973, including housebills 1034 and 1941, and Senate bill 35 enable counties to do this. As noted in the previous chapter, this cooperation is not commonly used in Colorado; only 14% of the counties have urban service and planning agreements with municipalities under their jurisdiction.
In the regional approach, property owners on the urban fringe deal directly with the central municipality on matters pertaining to sewage treatment, and have the least ammount of discretion in making decisions about appropriate service. Although subdivision review and approval falls under the county jurisdiction, the definition of standards is deferred to the municipality providing the service. Maintenance responsibilities are also the central municipalitys. Annexation is typically the end result of this approach, but not always. It may be that other services are not to the municipalitys standards, discouraging this action. Map 3-3 illustrates a version of


the Grand Valley using this approach.
The major impetus behind central municipalities participation in a regional sewer service area has been the EPA 201 Program. By funding up to 75% of a regional waste water treatment facility and major interceptor sewer lines, the Program is an attractive option. Requests for 201 funds have exceeded available monies each year in Colorado since the Programs inception.[11] With the 201 Program are a number of requirements that can initiate a regional approach, with some important qualifications. While the EPA and State Department of Health require long range growTth projections and definition of a regional service area, there is no requirement for a local master plan covering the same area. [12] Nor is there a requirement for landuse controls to be implemented in order to ensure that the service area encompasses future fringe area growth.[13] A central municipalitys participation in the 201 Program, and subsequent creation of a regional service area including the urban fringe may in fact take place with no county cooperation.
If there is no intergovernmental cooperation, other options such as special district formation and permitting of onsite disposal systems are still restricted to some extent. I.S.D.S.s may not be approved by local health departments if the property to be served is within 400 of a sewer line.
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The same holds true for package plants permitted by the State Health Department.[14] Special districts involving central sewage treatment facilities and package plants are also discouraged by the State Health Department, if proposed within a 201 Service Area, because of the States nonproliferation policy. [15] This scenario tends to lead into the fourth alternative.
Mixed Approach
In the mixed approach an urban fringe area has developed around a central municipality over time. The use of individual sewage disposal systems have been used traditionally, and are dispersed through out the fringe.
Where concentrations of individual systems have caused problems there have been small special districts formed to provide central sewer treatment. Larger developments separate from the central municipality have also been allowed using either package plants, or developer formed special districts to provide service. As the urban fringe grows, it and other systems are not adequate to either serve existing or future users, the demand is created for a large regional system. Because of the massive capital outlay required for such a system, the EPA has virturally always become involved, with partial financing or direct subsidies for the construction of a treatment facility and key interceptors.
In this alternative, developed property with sewer
65


are
infrastructure and private treatment facilities targeted, and interceptor sewers are funded and constructed to connect these facilities to a regional waste water treatment facility. If the package plant is in noncompliance with the state or federal water quality regulations, such connection is mandatory. As a result, the interceptor lines cut swathes through developed areas of the urban fringe. Existing I.S.D.S.s within 400 feet of a sewer line also must connect if they are found to be in noncompliance with local health regulations. Pre-existing special districts with sanitation as a function are exempt from these requirements, although they are encouraged to connect to the regional system by the State and the EPA. Special districts can become islands surrounded by the regional service area, or part of the service area boundaries.
This approach does not require a cooperative agreement between a county and central municipality over development and services in the urban fringe. If there is no substantive urban service agreement or contractual delegation of county authority to the municipality, the county is placed in the role of arbitrater between competing sewer service interests. This role becomes apparent when new development is proposed on the urban fringe. Within the 201 regional service area, encompassing sufficient land to provide for growth over a 20 to 50 year time period, a subdivision may be applied for further than 400 from a sewer line. The
66


County must decide whether or not to require connection to the nearest sewer line, or to allow another form of sewage disposal system to be installed. While the State may discourage the latter, it can not deny the option if it is approved by the board of county commissioners, and it technically meets state standards. Local health departments are similarly constrained from making policy decisions. [16]
A county government becomes further involved when a developer or property owner wishes to connect the regional system but can not finance the total cost of a sewer line extension through private means. The County may then be called upon to form a local improvement district (hereinafter referred to as LIDs). Authority for counties to form LIDs for sewer and water lines was established in 1983, under Colorado Revised Statutes 30-20-601 et al. The statutes allow LIDs to be formed in two ways; by petition of property owners representing at least 51% of the land area and assessed value of the property to be included in the District boundaries,, and by a resolution signed by the Board of County Commissioners after a public hearing with 35 days notice. The resolution method involves a forced district essentially, and because of the inherent controversy surrounding such an action, has not yet been successfully initiated by counties in Colorado.[17]
Under the other type of LID formation process, the County
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must make certain decisions upon receipt of petition for sewer line improvements. The first is a determination that the boundaries of the proposed district include all properties potentially benefitting from the sewer line extension, which has generally been interpreted by legal authorities as any property which could connect to the line, developed or undeveloped. The second decision to be made is the distribution of all costs associated with the LID, including design, administration, financing, and construction. The distribution formula is vague in the statutes, but it must be "equitable" and reflect the extent of benefit to be derived by the improvement. Usually, the distribution is based on the ammount of front footage along the sewer line, in combination with the potential number of units which can be placed each property. [18]
A total cost must then be determined, followed by a setting of the rate of assessment for each parcel in the LID. The assessment may be paid in full either within a year of the LIDs formation, or financed by a special improvement bond, attached to the property as a lien. The bonds interest rate is typically one to two points below prime, because of their tax exempt status. The debt schedule may be extended up to 20 years, although a 10 year period is most common. Assessments are billed with property tax; the LID is in fact a hybrid between an ad valorum tax on property and user charge.[19]
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Unlike the other methods of sewerage, the LID process requires significant participation of the county elected officials. Not only must they administer the various details necessary to ensure the legality of formation and make substantive decisions regarding the character of the LID, they must also sponsor the debt. If a property owner is foreclosed on, or fails to pay the assessment, the County must exercise the lien and sell the property to recover the cost of the assessment. In the words of one person involved with an LID formation process, "It is an administrative nightmare". There is also little choice for a County to participate or not. While there is some difference of opinion, it is generally found that if a petition is submitted it must be approved. [19]
While the mixed approach is most often associated with urban areas of with extensive urban fringes such as Larimar or Mesa Counties, smaller centers such as Delta County, with the unincorporated neighborhoods of North Delta and Garnet Mesa, and LaPlata County, with Durango West and Hermosa, are faced with these issues as well.[20] Map 3-4 portrays the current situation in the Grand Valley as an illustration of the mixed approach.
Summary
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Summary
As seen in the discription of different approaches to sewer service, it becomes apparent that in some ways, they represent an evolution. More rural densities will tend to rely on the individual sewage disposal systems, and as these areas become urban, other, more intensive methods must be found. At that point, a central may be willing and capable of providing service outside of its incorporated boundaries, and limiting other approaches form occuring. The other choices, of package plants or special districts, can lead in turn to the mixed approach. Beyond the alternatives described above, there are other legally viable options which have not been used in Colorado, including a county sponsored maintenance program for I.S.D.S.s, where annual inspections and maintenance of systems is done by staff of a local health department, and installation takes place before the sale of lots in a subdivision. While this has been initiated in California, and discussed for implementation in Douglas County, Colorado, there have been no real opportunities to evaluate the effectiveness of this approach.
While it is useful to know the different methods by which sewer service is provided on the urban fringe, this only goes part of the way in understanding their application; we must also consider ways to judge their effectiveness as a public concern. In the following chapter we consider the criteria




Notes for Chapter III
[1] Land Use and the Pipe; introduction
[2] Interview with James Meiklejohn, as cited
[3] Interviews with Dick Bowman, as cited
[4] Henry, James, Attorney at Law; "The Relationship between Cities and Special Districts in Colorado" Paper submitted at the Colorado Municipal League Annual Conference, Vail, Colorado. June 13, 1985.
[5] Ibid. p.5
[6] Handout from Colorado Muncipal League; "The Role of Special Districts in Colorado" 1984
[7] Colorado Revised Statutes, 32-1-203 (2.5); 1985
[8] Summary Table from State Auditors Office, "Limits for bond Financings", 1987.
[9] "The Relationship between Cities and Special Districts in Colorado", p. 9
[10] "Special District Control Plans" Prepared by the Colorado Division of Local Government, October, 1988.
[11] Interview with Peggy Galligan, as cited.
[12] Ibid.
[13] Ibid.
[14] Interview with Duane Watson, as cited
[15] Ibid.
[16] Interview with Dick Bowman, as cited
[17] Interview with Russell Caldwell, as cited
[18] In a series of conversations with Blake Jordan, bond counsel for Mesa County for local improvement districts, through 1985 and 1986.
[19] Ibid.
[20] Assistant Mesa County Administrater, Mark Eckert, after a meeting with property owners petitioning for a local


improvement district, June of 1986.
[21] Blake Jordan, as cited.
[22] Interviews with Duane Watson, Dick Bowman as cited.
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CHAPTER IV
CRITERIA FOR EVALUATION
This chapter sets out the types of attributes to be used in evaluating the four alternatives described in the previous chapter. For the purposes of this study, the criteria for evaluation is grouped under the following headings:
-Harmony with the natural environment
-Promotes the coordinated provision of urban services on the fringe
- Affordable and equitable distribution of sewerage costs
- Efficiency in the administration of the service.
-Integration with planning and landuse control for the urban fringe and the central municipality.
The selection of the criteria was based on a number of factors. In materials dealing with planning principles, concern for developments impacts on the natural environment, and the coordinated provision of urban services tended to be the most relevant and important issues associated with sewer service. [1] While one could perhaps
74


establish urban design criteria, or the appearance of the landscape resulting from different alternatives, there were too many other variables effecting this factor. The question of affordable and equitable distribution of costs not only was considered the highest priority among residents in Mesa County during several neighborhood meetings, but also raised in the International City Managers Association book, Management Policies in Local Government Finanace as a relevant financial issue with sewer service. Efficiency in the administration of the service was also included as a key factor in Management Policies in Local Government Finance The factor of integration with planning and landuse controls was considered in light of current state legislation and local planning practices; Land Use and the Pipes major theme was the relationship of landuse and sewer service, although the subject was handled in the national and more specific context of the EPA 201 Program. The idea of coordinated provision of urban services was repeatedly raised by other service entities in Mesa County as a key issue associated with sewer service and urban fringe growth. Finally, when the Mesa County Board of County Commissioners established a list of their concerns to be addressed by a policy report for sewer service in the Grand Valley, administrative efficiency, affordability and consistancy with other regulations including those dealing with land use were considered priorities.Below is an explanation of how each criteria is to be interpreted.


Harmony with the Natural Environment
This attribute covers a broad spectrum of concerns and features, of which the following are most relevant for the general alternatives presented in Chapter III. The most important environmental factor potentially effected by the different sewerage approaches is the quality of surface and ground water resources.[2] The level of harmony a particular sewerage method has with this factor is the extent to which water quality is protected and preserved, given an equal number of households. As part of this protection, consideration should be given to the stability of a sewerage method over time, and the potential for failure of a system.
Other environmental factors are important as well; geological features, considered as hazards to safe development include slopes in excess of 30%, floodways of rivers and streams, unstable soils such as mancos shale, soils with high shrink-swell characteristics such as clays, and flash flood drainages.[3] Environmentally sensitive areas should also be taken into account, and include wetlands, and wildlife habitat.[4] The extent to which all of these areas are disregarded by a particular sewerage approach determines the disharmony of that approach. The
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extent to which these different features are taken into account as part of the development of a sewer service, or are avoided, the greater the level of harmony.
Promotes the Coordinated Provision of Urban Services
The term urban services is meant to include local public sector functions on behalf of the people in its jurisdiction. Such capital intensive services as schools, parks, treated domestic water supplies and infrastructure and urban streets are included, as well as operation intensive services such as fire and police protection.
There are a number of ways coordinated provision of these services may be promoted or enhanced by a sewerage alternative. The alternative may tend to directly combine the range of public services in a package as part of its implementation. Another way coordination takes place is when the sewerage system used allows public entities to easily and accurately predict demands for other services, or is provided in a way that encourages a consistant density, avoiding inconsistant demands for other services.
Affordable and Equitable Distribution of Costs for Sewer Service
This set of criteria has two major concerns;
77
the first


issue raised here deals with all related capital costs of an alternative, as well as maintenance, operations and replacement. An alternative is considered affordable in relation to other options available, rather than in absolute terms, as the assumption is that some form of sewerage treatment and disposal is necessary.
Method of payment plays a large role in the question of affordability. The ammount of time a property owner may extend payment for a particular type of service can offset total cost differences substancially. The type and ammount of maintenance required to keep a system functioning is as important as the capital costs of that system; the need for replacement or significant repairs over time also effect the affordability of a sewerage alternative.
The distribution of costs for sewer service on an equitable basis means that there is a positive relationship between a particular property owners benefit to be gained from the sewage system and the assignment of the systems costs. The question of benefit arises not only when we consider how-current costs are distributed, but to what extent future users of a system will be subsidized by those in place. Another way of stating this is whether or not there the principle of Rational Nexus is exercised in each alternative.[5]
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When considering the degree of affordability, it becomes necessary to also consider landuse patterns, for they can directly effect the price of a particular method of sewage treatment. For that reason, the alternatives as described in Chapter III have essentially defined the type of land use patterns resulting from a sewerage method, or are commonly found with the particular method.
Administrative Efficiency
While this factor may be considered in terms of monetary cost, there other important ways efficiency may be considered for each sewerage alternative. One way of expressing efficiency is the avoidance or elimination of duplication in managing the system. When more than one agency is involved with providing sewer service in an area, the extent to which each has its own administrative structure and set of regulations will determine the ammount of duplication, or inefficiency. Similarly, if several agencies have responsibilities for administering different aspects of the sewer system, such as installation, enforcement of standards, maintenance, billing, and if these different functions are poorly coordinated this will make administration of the system confusing and cumbersome. Another way of percieving efficiency is the time involved with responding to different needs of users. Intricate review processes, or poorly defined responsibilities within
79


management agencies tend to extend the time required to respond to problems as they arise, or the providing of new service.
Integration with Planning and Land Use Controls on the Urban Fringe
The aspects of planning that most concern us here are those that relate to an orderly vision of a community, balancing its economic needs and mandates for growth with concern for the health, safety and welfare of its citizens, as well as their quality of life. The development of an urban fringe reflects a positive or at least indifferent attitude towards growth on the part of County decision makers. The extent to which quality of life, health and safety are part of this attitude varies in each alternative.
One way of expressing the integration of an alternative with planning principles is whether or not the method of providing sewer service reinforces "the consciousness of governments and the general public (about) the importance of being concerned with relationships among people, physical objects and ecological forces; of trying to see things whole... of aiming at and working for a better future." [6] If this is aided by the management of a sewer system, as opposed to being ignored, the alternative is considered integrated with planning principles. Another way of looking
80


at this factor is whether or not the method of providing sewer service is tempered with basic ground rules that consider community needs as a whole, rather than responding solely to private sector demands.
Land use controls are the tools employed in implementing these principles, and the extent to which they are proactive, rather than simply reactionary dictate the degree of integration between them and the provision of sewer service. Such landuse controls include zoning, the areas master plan, or the adoption of development performance standards. Fairfax County, Virginia, has frequently been held out as a classic example of what happens when sewer service is not integrated with planning and land use controls. During the 1950s and 1960s, Fairfax County allowed growth to take place, disregarding and in some instances over riding the planning and landuse controls in place. Sewer service was the medium allowing such growth to take place; Fairfax County was faced with two state imposed development moratoriums because of plant capacity problems. Important watersheds were threatened by the encroachment of leap frog subdivisions.[7] On the obverse side, management of sewer service, as discussed in chapter II, can be an important tool for planning a communitys growth responsibly.
SI


By considering each alternative in light of the criteria, we can judge how they perform. It is not enough to consider whether an alternative performs particularly well with regard to one of the criteria, but rather if they can perform reasonably well in the range of public concerns. In the following chapter is a detailed evaluation of each of the approaches and a table summarizing the results.
32


NOTES FOR CHAPTER IV
[1] Scott, Randall W. Management and Control of Growth -Volume I deals with the various issues of growth and development, and has been relied upon for this statement.
[2] Land Use and the Pipe p. 5
[3] Colorado Environmental Commission; "Colorado: Options For the Future". March 1972. pp. 24-27
[4] Ibid. pp.34-35. 1974 H.B. 1041 designations of areas of
state interest.
[5] Government Finance Review, "Infrastructure financing", August, 1986. p. 29
[6] Principles and Practice of Urban Regional Planning. ICMA
[7] Land Use and the Pipe pp. 133-143
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CHAPTER V
EVALUATION OF ALTERNATIVE APPROACHES TO SEWER
Initial Remarks about the method of evaluation
The intent of this chapter is to use the criteria defined in Chapter IV as instruments for judging each alternative sewer service scenario. In order to accomplish this, a scoring system of 1 through 5 has been selected, with 1 being the lowest level of performance, and 5 the highest.
The evaluation itself is based on data collected and analyzed in other works, interviews with professional staff who work with the different methods, and the Mesa County case study.
There has been no attempt to perform a quantitative analysis in making the evaluation; such an analysis assumes certain variables to be constant or comparable. Methods of financing, discharge requirements, resulting land use patterns all vary from alternative to alternative, making comparisons difficult. Another difficulty is that in every fringe area around a municipality, individual situations are found that change constantly, or are difficult to quantify because of poor record keeping. Finally, the purpose of this study is to create a conceptual approach to sewer
service on the fringe areas of Colorado, which may be
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refined by others who find it relevant.
The Decentralized Approach
In this scenario, the use of onsite individual sewage disposal systems and package plants were allowed on the fringe areas, either historically or as part of continuing approval process by the County government with jurisdiction over the area.
Harmony with the Natural Environment- Rating 3
Areas where on site disposal systems were allowed on the urban fringe before 1973, with the enactment of Colorado Health Department standards, made significant impacts by polluting ground water supplies. Untreated sewage either frequently entered the water table directly, vrith no filtering, or a concentration of systems on small lots saturated the soils in the vicinity, causing the natural filtering process to fail.[l] Since 1973, such impacts have been substancially reduced, because of larger minimum lot sizes and installation standards prohibiting direct discharges. Despite these improvements, groundwater is still threatened when adverse geologic conditions are not taken properly into account by the local health department. The opinion of state health officials is that the majority of
as


counties in Colorado do not fully enforce state guidelines, or fail to restrict onsite systems when soils or subsurface
geology can not support a conventional septic system. Such
problems as locating a leach field too near a the water
table, or locating the field in fractured shal e still
occur.f 2]
The management of individual onsite systems also poses threats to ground water quality. The average life of a conventional septic system is 12 years; yet there is no requirement for mandatory inspection of such systems at the end of this or any other period of time. [3] Typically, the local health department only plays an enforcement role when failing systems cause untreated wastewater to surface on the ground. [4]
Surface water pollution as a result of onsite systems is minimal. Historic direct discharges into ditches, or irrigation canals have been generally eliminated, and are no longer allowed. Location of septic systems in a designated 100 year floodplains have also been prohibited,[5] thereby eliminating the washing out of leachfields into rivers or streams.
Even the least restrictive installation standards of onsite disposal systems tends to limit the ability of development
to locate in areas where geologic hazards such as
86
steep


slopes or shallow water tables and sensitive ecologies such as wetlands are present. On site disposal systems meeting state standards are physically restricted from locating near steep banks and shallow water tables noted throughout the year must be at least at a depth of 4 feet to allow installation of septic systems. These requirements are usually respected by local health departments. The same holds true for areas with soils having high shrink swell potential; these types of soils tend to have inadequate percolation rates for septic systems.[6] While other individual onsite disposal systems may be installed, such as evapotranspiration or mound systems, the ammount of land and capital costs of these methods are high, and may exceed the value of the property. Evapotranspiration systems have been priced in Mesa County at approximately $15,000.00 [7]
Private package plants installed to serve subdivisions are more uniformly regulated by the Colorado Department of Health, thus avoiding many of the problems encountered by individual systems. The potential problems of package plants are their mechanical failure over time and the lack of ongoing maintenance, causing failure and subsequently water pollution either subsurface or surface, depending on location. The involvement of the State as the regulating agency also restricts the location of package plants where geologic hazards and sensitive ecologies exist, although
only the plant site is actually reviewed. [8]
37


While posing potential and actual ground water pollution problems because of regulatory practices, the decentralized approach, particularly on site disposal systems, are constrained in ways that take into account geologic hazards and ecologically sensitive areas. The rating is 3, in terms of harmony with the natural environment.
Promotes the Coordinated Provision of Urban Services on the Fringe Rating 1
The use of individual sewage disposal systems does not place an unreasonable tax burdon on property owners or drain government financial resources in the provision of sewer service, subsequently causing an imbalance in expenditures. The decentralized approach, however, works against the coordinated provision of urban services. Decisions of where other services are to be invested is made extremely difficult when it is unknown where demands will be expected. The decentralized approach allows dispersed, non sequential growth to occur, because of minimum lot sizes in the case of onsite systems, with development decisions in the hands of the individual. Such a process is made incrementally, frequently by exemption from subdivison regulations, or small subdivisions considered on a case by case basis. [9]
38


These factors hamper public service entities from predicting urban concentrations, and add to the cost of urban infrastructure, including road improvements and water lines, when demands are there. [10] If subdivisions are approved using package plants, their locations are frequently isolated from other urban services, causing inefficient extensions of other infrastructure to serve the area. The results are costly on a per household basis and inconsistant or inadequate levels of urban services. As a result of thes problems, the decentralized approach was considered perform poorly in the coordinated provision of urban services.
Affordable and Equitable Distribution of Costs for Sewer Service- Rating 5
Although the decentralized approach effects the price of other services, on site systems and package plants are less expensive to construct and maintain than the different forms of central sewer service considered here. The typical cost of a septic system in Mesa County is from 1800.00 to 2500.00 dollars to install, with minimal maintenance expenses over generally a twelve year period.[11] At a point where the system fails, the property owner may usually find a suitable location for a replacement field on their site; periodicall pumping effluent out of the leach field is a extreme measure
which may cost up to 200.00 dollars a month. Installing an
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alternative, more costly system, such as evapotranspiration,
is also uncommonly required. [12]
Package plants also tend to be less expensive, in that maintainance is also virtually nonexistant. The costs of major line extensions are eliminated because the area to be served by a package plant is limited to a subdivision adjacent to the treatment facility.
Distribution of these costs is very equitable. Improvement and maintenance expenses are limited to those that directly benefit from them, with no complications of averaging costs or paying for future expansions in order to serve other users of the systems. because of these considerations, the decentralized approach recieved a rating of 5.
Administrative Efficiency- Rating 3
It is fairly simple for a property owner for an individual on-site system from the department once approval for a home site This basicaly consists of a percolation t inspection from a sanitarian to determine requirements of the regulations are being weeks time between application and appro
site constraints, the applicant is typica
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to acquire a permit ir local health has been granted, est and on site if general met, and involve a val. If there are lly required to


install a more expensive, engineered system, or is prohibited from building on the property. [13]
Administrative problems arise when homesites with older systems subject to failure are sold, with no records of compliance with 1973 regulations. Such systems also may have been installed on lots of less than 1/3 acre, or without proper treatment. In such cases, the property owner may enter into prolonged appeal proceedings with the local board of health, be subject to notices of violation and possible condemnation with little recourse. This in turn requires a great deal of administrative time, to ensure violation notices have been handled properly, and to work with each property owner with a problem, to educate and encourage cooperation. [14]
Package plants, being managed by a developer or homeowners association may be very inefficiently managed; poor response time for repairs in the event of a broken pipe or malfunctioning treatment system can be lengthy, with the State department of Health imposing fines, or restricting sale of lots untill the system is functioning properly.
These procedures on the part of the State Health department are lengthy and time consuming, expending inordinate ammounts of time. Frequently, there is no clear responsibility delegated to an individual for package
plants, causing further inefficiencies. [15]
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Integration with Planning and Land Use Controls- Rating 2
In the decentralized alternative the county in effect defers many decisions about a communitys ability to grow and the form of that growth to individual property owners and state or local health departments. The space requirements of conventional septic systems determine the minimum density allowed for residences in the urban fringe, and the location of package plants tend to create satellites that shape its boundaries.
While a county or municipal master plan, meant to articulate the goals and objectives of a community as a whole, can be adopted, the control over utilities, as Kelley stated, gives the plan its power. Approval of package plants and individual sewage disposal systems, as part of a development proposal concievably can be made a part of a long term perspective towards a community. Yet by taking such a perspective, the central municipalitiy is locked into a position of either not expanding, or doing so at great expense because urban infrastructure is costly to extend into the fringe, and difficult legally to defend, because there may be no control over service connections. Since the urban fringe is intrinsically tied to the central
municipality, it is evident that there is no consciousness
Q2


of how sewer service and land use interrelate with the other aspects of urban communities and growth. Nor is there any compulsion for health departments to consider landuse implications when approving on site treatment systems.
Land use controls can be integrated with the decentralized approach but tend to follow the lead of how individuals and developers choose to provide sewer service. Zoning for higher densities than 1/3 acre implies a multiplicity of package plants, an action discouraged by the State Health department. Otherwise, zoning either coincides with the limitations of septic systems, or is inconsistant with service constraints, and subsequently causes conflicts.
Special Districts
Harmony with the Natural Environment Rating 3
Title 32 special districts with sanitation as a function use central treatment facilities for processing effluent; this in turn eliminates problems of contaminating ground water supplies seen in the decentralized option. Surface water pollution, however, can and does occur when the treatment facility fails, is over capacity or is improperly operated and maintained. The inadequately treated sewage is then discharged into surface recieving waters. Smaller districts
have historically tended to cause the greatest problems of
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discharging polluted wastewater of all forms of public treatment, because maintenance is inconsistant or inadequate.
The formation process of special districts requires no environmental impact assessment as part of its justification for existance or service plan; nor must there be consideration of the appropriateness of siting infrastructure in areas where there may be environmentally sensitive or hazardous areas. Unless the district recieves federal assistance, there are no restrictions from locating sewer lines in the 100 year flood plain, or in flash flood drainages. Wetlands are protected through the Army Corps of Engineers 404 Permit Program. The 1985 amendments to the Special District Control Act, although clarifying the relationship between counties and special districts during formation, still does not compel districts to consider environmental constraints in their service areas.
If special districts are formed far beyond municipal limits, the tendency for infill is great, including the use of septic systems or package plants, and thereby bringing in the advantages and disadvantages of the decentralized approach.[17]
Fosters Coordinated Provision of Urban Services- Rating 2
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Decisions about locating Title 32 District sewer infrastructure, and establishing service area boundaries are primarily made either by a developer seeking to use the financing powers of districts, or a group of property owners with immediate need for central sewer service. Untill 1983, there was no requirement that other service entities beyond the county be contacted when formation of a district was proposed. It was not untill 1985 that counties had mandated performance criteria to consider whether services provided by a proposed district were a duplication of existing services or not. Since most districts involving sanitation districts in Colorado were formed before the reform legislation of the Special District Control Act in 1983 and 1985, there were few restrictions to their decision making.
The problems arising with such lack of restrictions include the inconsistancy between levels of service provided to a particular part of the urban fringe. With concentrated urban densities accompanying central sewage treatment there is in all likelihood inadequacies of other services, thereby creating "catchup" demands or severe inefficiencies in service delivery systems. This is because most counties with an urban fringe, have not developed a system of distinguishing between urban population needs and rural.
Even in the case of metropolitan districts, there are other services not covered in the range of district functions. The
other major problem arising from special districts is their
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independence from the central municipality. Design standards for infrastructure may be different between the service entities, causing conflicts if the district should connect to the municipal treatment and collection system.
One exception to this problematic situation is that special districts can play a very important role by "catching up" sewer service with other services already existence in an urban area. These situations, however, are more the exception than the rule in Colorado.
Affordable and Equitable Distribution of Costs Rating 4
This method can provide a very direct and equitable method of distributing costs for sewer service. Only those properties within the districts service area and recieve benefit from the improvements are charged for the provision of sewer treatment. Districts had far reaching powers to set connection fees and charges with very few restrictions or notification requirements; the passage of the Special District Control Act amendments including H.B. 1017 and H.B. 1020 in 1985, however, has made districts more accountable to their public, and has thus limited the potential for inequities in charges or assessments. Because special district formation relies on the support of the owners of
the majority of property to be served, there tends not to be
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an unnecessary duplication of sewer treatment methods in the district boundaries, such as use of functioning I.S.D.S.
This in turn makes the separation of powers alternative more affordable than other methods where such duplication exists.
Efficiency of Administration- Rating 2
Despite legislative changes regarding formation performance criteria and the encouragement for district consolidation in 1985, districts tend to engender more inefficiencies than not. The basic reason for this is that for every district, there is a separate administrative structure, with differences in standards, operation policies and procedures. Not only does this cause duplication in fees, but since communications between entities is not mandated, there is a lack of coordination that frequently leads to confusion and conflict. As pointed out by the Colorado Municipal League, multiple public service entities in particular area effect each other constantly, since most infrastructure is located along public rights of way. When there are construction activities in a street, such as sewer repairs, not one but several public utilities must be present to inspect the work, and ensure that improvements effecting their facilities are properly done.
Integration with Planning and Land Use Controls- Rating 2
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Because special districts have generally been formed and managed as autonomous units of government, there is a tendency for planning to be subordinated by their presence, rather than enhanced. The fact there is no state mandated integration between county planning functions and the service plan approval process allows special districts to be formed without consideration of an areas long term development. And, as observed by a speaker at a water conference in Gunnison, Colorado, there is a tendency to treat one basic urban service as the prime determinant of growth, rather than consider a range of locational factors. In the case of Mesa County, the availability of central sewer service was enough to encourage urban densities of development, even when fire protection and roads could support only rural land uses. [18] Applying the principle that planning seeks to develop a consciousness of how things interrelate, these aspects of special districts would tend to work against integration.
As pointed out above, special district may be formed at an appreciable distance from the central municipality; this in turn creates a situation where there are pressures for in fill development, without benefit of central sewer service, and often lacking other services. The result is even further fragmentation on the urban fringe. This also reflects on districts integration with land use controls.
Zoning and subdivision regulations are intended to provide a
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structure locations treatment services, and subdiv
for counties to designate and ensure for development. Yet, when central s is provided in the absence of other u the impetus is great enough to suppor ision approvals.
appropriate
ewer
rban
t rezonings
Regional Approach-
Harmony with the Natural Environment- Rating 4
The regional alternative involves the collection and disposal of sewage by the central municipality, and subsequently represents the most stable treatment method considered here; surface and subsurface water supplies are not actually or potentially impacted to as great an extent as previously considered methods. Because municipalities in one way or another rely upon federal and state intergovernmental transfers, there are restrictions placed on the location of sewer lines in designated 100 year flood plains, thereby limiting the location of development in such environmentally hazardous or sensitive areas. [19]
Other features of the environment which may pose hazards are not considered as prominantly, and because the collection system is contiguous, there is a possibility of having sewer
service in areas otherwise not suitable for development. On
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the obverse side, development tends to be consolidated rather than sprawling, and lessens the potential for locating development in inappropriate locations. The possibility that a secondary urban fringe may develop outside of the municipal service area effects the viability of this approach.
Promotes the Coordinated Provision of Urban Services-Rating 5
The municipal extension of urban services enhances coordination, in that the control exerted by a general purpose government in deciding the location of sewer infrastructure enables other service entities to predict future demands for other services. Since there is to be only one sewer service provider, it is relatively simple for other service entities to determine future capital improvements and plan accordingly. Another way coordination is achieved is because of the sequential development this alternative represents, allowing other services to be extended in an economical way, rather than be forced to cope with gaps between developed areas.
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Affordability and Equity Rating 3
Because municipal standards tend to be higher than other types of service entities, and the form of treatment more sophisticated, in many cases involving tertiary treatment,[20] sewer service becomes more costly; this in turn reflects on connection charges, and monthly surcharge rates for a user. This is offset by two factors. First, it is probable that the municipality is being partially subsidized by an EPA 201 grant, making capital costs more affordable. With changes, however, in the 201 Program which have eliminated grants and replaced them with long term low interest loans, this savings will not be realized in the future.[21] The other savings is realized by the fact that one treatment facility serves a broader base of users, creating an economy of scale; expansion of that facility is less expensive than construction of a new treatment plant, although this is offset by the initial capital cost.
The regional approach can represent certain inequities. Frequently a dual fee system is adopted by a central municipality that distinguishes municipal from nonmunicipal users, the latter being charged in some instances double the connection costs as a penalty for being in an unincorporated area.[22] This reflects the basic problem of having a governmental entity controlling charges with no enforced
accountability by a voting constituency. Because a general
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purpose government is not subject to the scrutiny of the public utilities commission, there is no outside authority for enforcing fair cost distribution. County governments and the state Health Department also have no direct influence on such a situation, leaving a property owner with the expensive option of a civil lawsuit. [23] These problems are offset by the fact that those using the system are those who pay, and the densities resulting from this approach are more uniform, allowing a balance of per unit cost to benefit recieved.
Administrative Efficiency- Rating 5
The regional approach involves the provision of sewer service by one agency, the central municipality, who is responsible for the construction, maintenance, enforcement activity and billing associated with the system. There is no duplication or multiplicity of administrative structures as seen in other approaches. Efficiency is also seen in the ability to provide a uniformity of service to a collection of users; the responsibility is not on each individual to cope with possible failures or repairs.
Integration with Planning and Land Use Controls on the Urban Fringe Rating 5
By controlling sewer service on the fringe, the central
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municipality is able to influence land use decisions on the part of the County government and prepare for long term growth and annexation. The region is effectively made more of a single community by this control. Land use controls, while remaining in the hands of the county, tend to be more in harmony with the municipalities, as the latter can exert influence in the approval of subdivisions and zoning decisions through the instrument of sewer service. Another important trait of this alternative is that sewer service is directly provided by a general purpose government, whose mandates are to consider a full range of aspects involved with health, safety and quality of life. This differs from the other alternatives so far considered.
Mixed Approach
Harmony with the Natural Environment- Rating 2
The mixed approach exhibits many of the negative attributes of the prior approaches with regard to the natural environment, for a number of reasons. Individual sewage disposal systems are not entirely limited by this alternative, particularly where there is no major interceptor within 400 of properties. Indeed, because of the expectation that central sewer will become available to properties in the regional service area, temporary or
undersized systems can be justified and allowed, causing
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ground water pollution by inadequate treatment over time.
On the other hand, the use of package plants are generally eliminated within the service boundaries, removing the potential of water pollution from that source. Special districts may remain in place; while they are encouraged by the State Health Department to connect with the regional system, this is uncommon, thereby maintaining potential surface water pollution sources.
Because the intent of this approach is to encompass all areas of the fringe, including isolated clusters of development, the service area frequently includes locations unsuitable for development. By being included in the service area the percieved implication on the part of counties is that such locations are to be developed. This problem is compounded when interceptor lines are extended to connect with leap frog development, creating an incentive for locating development along its route, despite the possible presence of adverse geologic conditions, or sensitive ecologies. [24] While flood plains are protected because of EPA and State guidelines for locating interceptors, the presence of special districts may off set this restriction.
Promotes the Coordinated Provision of Urban Services -Rating 3
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The mixed approach seeks to correct the problem of multiple sewer service providers by consolidating service into a regional system; despite this effort, the evolution of a mixed approach perpetuates some service delivery problems. The intent of a regional sewer service area is to include in one sweep all areas within the current and projected urban fringe. By this action, there is a tendency to provide a vast area for development to locate. This leaves questions about phasing other improvements, and the level of those improvements, unanswered for other service entities. Since the outlay of capital can be great when a regional system is installed, this may also limit the ability of the County and central municipal government to finance other needed urban services, while burdoning the existing set of users with charges that innure them to supporting additional public investments through their voting powers. [25]
In cases where the service area is smaller and the development pattern more consolidated, the regional system can promote coordinated provision of urban services by defining the area of projected growth. In the past five years, the EPA and the State Health Department have encouraged more conservative estimates of population growth when approving service areas for EPA 201 projects, although connecting outlying package plants continues to create large service areas. [26]
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t
Affordable and Equitable Distribution of Costs for Sewer Service Rating 2
The mixed approach makes sewer very expensive for owners of developed property who connect to the regional system, after having already paid for I.S.D.S. installation, a package plant, or participated in the costs of a special district involving sanitation. In the same vein, the local share of financing a regional treatment facility and collection system places an inequitable share of capital costs on the initial set of users, since financing is virtually always by revenue bonds. This results in inequitable distribution of costs, for existing users are being charged to subsidise a portion of unused capacity of the treatment facility and major collection infrastructure. Pro rated charges to new users of the system as they connect in order to recover this subsidy is extremely complicated and rarely implemented.
[27]
Another problem of the mixed approach is that development patterns have not tended to be consolidated, creating a potential imbalance between larger properties that add costs to the placement of infrastructure, and smaller lots. This problem can be remedied by the use of local improvement districts, where the front footage of each property is included in the cost distribution formula for assessments.
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Administrative Efficiency- Rating 1
The mixed approach involves several different agencies in its administration, creating severe inefficiencies. The State Health Department and EPA act in the capacity of grant administraters and enforcement authorities to ensure that management of the system is in compliance with federal and state regulations, while the local health department is deeply involved not only with the permitting of new I.S.D.S.s, but enforcing connection to the regional system when there is an I.S.D.S. failure within 400 of a sewer line. The municipality also is involved with supervising sewer line improvements built to adopted standards, and monitoring local health department permitting activities to ensure that I.S.D.S.s are not allowed where sewer lines are available. Finally, the county government is involved when local improvement districts are proposed to finance sewer lines, forcing a time lag from 3 to 8 months for a property owner to connect to the regional system. [28]
Added to these problems are the presence of special districts, having different regulations and charges, and complicating the ability of a property owner to determine who is responsible for their sewer service.
Integration with Planning and Land Use Controls on the Urban
Fringe- Rating 3
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The mixed approach has an ambigous relationship with planning. The fact that this alternative evolves from a disregard for how services and development are related connotes a lack of integration. At the same time, the mixed approach is an attempt to bring this problem under control. Perhaps the strongest manifestation of integration is that counties are compelled to involve themselves directly w-ith the consequences of approving development on the urban fringe, and thus take greater interest in avoiding further dilemnas of growth without accompanying services.
Landuse controls tend to follow7 the lead of service area definition. As described in Interceptor Sewers and Urban Sprawl, T 2 91 the different aspects involved x^ith the 201 process conspired to increase the size of the system, in turn perpetuating urban fringe sprax^l and leap frog grox^th. As stated above, this approach by administraters of the 201 Programs has changed in recent years; yet the legacy of previously approved projects continues. The service area, once defined, can justify the blanket rezoning of lands within it to urban densities. By doing so, there is the possibility of extending the fringe area further.
Summary -
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I
As can be seen on Table 5-1, following page, the different approaches tend to exhibit marked differences in their strengths and weaknesses based on the selected criteria. It should be apparent why the decentralized and separation of powers alternatives have been considered attractive in many areas of Colorado, for the attribute of costs tend to be a priority over other less obvious considerations. The irony of this preference is that over time, if growth continues on the fringe, it leads to the mixed approach which is considered the worst alternative in this evaluation. This leads one to surmise that many county governments have either low or no expectations for growth in their jurisdictions, assume that sewer service on the urban fringe is not their responsibility, or are constrained by current legislation from taking an active role in the development of sewer service on the fringe. Based on the study contained in the second chapter and this evaluation, the answer appears to be a combination of these reasons. Chapter Six, Conclusions puts forth recommendations to address these factors, and suggest alternative methods of dealing with sewer service not currently used in Colorado.
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k
TABLE 5-1
EVALUATION OF ALTERNATIVES
CRITERIA :ALTERNATIVE 1 1 1 1 n jj 3 4
HARMONY WITH THE NATURAL ENVIRONMENT 1 3 1 3 4 2
PROMOTES COORDINATED PROVISION OF URBAN SERVICES 1 1 J 1 1 1 1 1 2 5 3
AFFORDABLE AND EQUITABLE DISTRIBUTION OF COSTS 1 t 5 1 1 1 1 4 3 n &
EFFICIENCY OF ADMINISTRATION 1 i 3 I n 5 i
INTEGRATION WITH PLANNING AND LAND USE CONTROLS ' 1 1 1 2 1 1 1 2 5 3
TOTAL SCORE 1 1 1 1 1 1 11 l 1 15 18 9


Notes for Chapter V
[1] Interview with Duane Watson, as cited above
[2] Interview with James Meiklejohn, as cited above
[3] Duane Watson
[4] James Meiklejohn
[5] Duane Watson
[6] Duane Watson, James Meiklejohn
[7] During a meeting with Mesa County Health Board, presetation by Don Whetstone, Sanitarian with Mesa County. November, 1986.
[8] Duane Watson
[9] Professional observations, in working for Mesa County as a Planner responsible for subdivision reviews, from 1983 to 1988.
[10] Numerous conversations with service agencies in Mesa County during personal tenure from 1983 to 1988.
[11] James Meiklejohn
[12] Ibid
[13] Ibid
[14] Ibid
[15] Interview with Dick Bowman, as cited.
[16] Ibid.
[17] Personal observations in Mesa County from 1983 to 1988.
[18] Ibid
[19] Interview with Greg Trainer, City Utilities Director, and Manager of the Persigo 201 System in Mesa County, April 3, 1986.
[20] Interview with Dick Bowman, as cited
[21] Interview with Peggy Galligan, as cited
Interview with Dick Bowman
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[22]



[23] Personal observations while working for the City of Delta, Colorado 1980-1981.
[24] Personal observations while working for Mesa County, 1983 to 1988.
[25] Ibid.
[26] Interview with Dick Bowman
[27] Interview with Russell Caldwell, Bond Investment Counselor for Kirchner and Moore Inc. Denver, Colorodo. May 1986.
[28] Ibid.
[29] The Introduction of that book.
[30] Personal observations in Mesa County; the Persigo System once on line, became the impetus behind a blanket rezone for the Service Area to PUD in 1984.
ill


CHAPTER VI
SUMMARY AND RECOMMENDATIONS
Summary and Findings
This thesis has sought to describe and analyze one, albeit important, component associated with the emergence of urban fringe areas around Colorado municipalities. Although one can argue volubly and well against it, the fact remains that in Colorado, extensive residential development in unincorporated areas has been unrestricted and in many cases become an entrenched pattern on the landscape. This has not generally occurred because of a deliberate policy, or rationale, but as an evolution that has tended to follow channels of least resistance in the laws governing the location of development. It subsequently becomes vitally important that we understand what the parameters are in the management of wastewater treatment on the urban fringe. The first two chapters of this thesis described the nature of these parameters, the roles of different public agencies, and the general tools available to county governments when dealing with sewer service. A case study of Mesa County was then conducted as an illustration of how these factors work in the real world.
In exploring key issues about sewer service in Chapter II,
certain things became evident. Water quality regulations
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passed by state and federal agencies have exerted enormous influence on sewer service, and in consequence on urban fringe growth in Colorado. While regulations regarding central treatment facilities and individual sewage disposal systems have been oriented to the what is minimally required, there is a common interpretation that these restrictions are acceptable under most circumstances. It was also found that the ongoing decision made by health officials about allowing different sewer systems can effect the development of an urban fringe. With regard to growth management and land use controls, it was found that enabling legislation now in place in Colorado is far reaching, but relatively ineffective without greater pressure or incentives for counties to use them. It was also found that despite extensive enabling legislation that counties and central municipalities have not tended to work together in managing the urban fringe, a matter of concern. Since counties have not traditionally gotten directly involved with the "sewer business", reliance on the private sector and special districts to handle services bias the county planning and development review process. Control over services, it was found, gives planning tools their power. The way sewer service is provided has serious implications in the realms of personal and public finance, as different systems vary widely in how they are paid for. This in turn can exert pressure on decisions about sewer service on the urban fringe.
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In order to gain a more intimate picture of urban fringe areas we considered Mesa County, Colorado, in detail. It was observed that comprehensive planning and zoning had been in existence since the 1960s, yet because of their inconsistancies, the lack of strategic understandings of sewer service, and the absence of phased service planning, these tools were ineffective to provide orderly development and reliable sewer service. The result has been an expensive and controversial regional system superimposed on the central Grand Valley, with duplication of a service.
Given this context, Chapter III set forth four general scenarios of sewer service on the urban fringe, relying on what is currently feasible. Chapter IV established selected criteria to judge the performance of the approaches, and in Chapter V, the evaluation was conducted. The first alternative, Decentralized Approach, was considered to have performed poorly in the areas of coordinated provision of urban services, and integration of planning. The alternative in some ways respected natural environmental constraints more than other alternatives, but the impacts to ground and surface waters offset this advantage. Ultimately, the fact that the Decentralized Approach was considered the most affordable, tended to make this option viable for the urban fringe. The special district approach, while appearing to be a simple solution to the question of sewer service on the fringe, in
actuality complicates the administration of government in such
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areas, and works against planning and growth management. The best alternative for providing sewer service on the urban fringe appears to be the Regional Approach, by a municipality through an intergovernmental agreement. This conclusion certainly has been reached by others before, and current planning wisdom in Colorado supports intergovernmental cooperation on the fringe of central municipalities. Yet this alternative has not been used by the majority of counties in Colorado. / Reasons for this might be speculated on. If there is no clear plan for growth by a municipality, it is difficult to consider logical extensions of utilities beyond incorporated boundaries. The county may not honor a municipalities master plan or proposed extension of sewer service because it is seen as an infringement on the rights of property owners on the urban fringe. Finally, the worst alternative based on this evaluation was the Mixed Approach.
In this case, past actions had created the overwhelming problem of fitting existing circumstances into a new context, incurring high costs, creating administrative confusions and inefficiencies, and inadvertantly locating development in inappropriate areas. This alternative tends to be the result of allowing the first two alternatives to come about on the fringe, as evidenced by Mesa County.
Recommendations
What then must we do? There are specific changes that may
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effectively lead to better performance of sewer service and land use planning on the urban fringe, without radically changing current legislation. The short term recommendations below are organized by the alternatives presented in Chapter IV, to reflect the idea that similar approaches to sewer service will continue to be used in Colorado. General recommendations follow these specific suggestions, and deal with needs for better information systems and ideas for further research. Personal speculation on longer term changes are then offered
Decentralized Approach-
-The state mandated minimum lot size for I.S.D.S.s is too small at 1/3 of an acre. This standard can not support replacement septic systems if they are used, or provide sufficient room for other systems such as mound or evapotranspiration methods if they are required. Densities of 1/3 acre are also sufficiently high to create saturation of surrounding soils, generate a demand for urban services such as central water and an urban street network. If development proceeds at 1/3 acre densities central sewer should be provided. A recommended minimum standard is two acres, which would essentially provide sufficient room for drainage and replacement for most sites, as indicated by the staff of the Colorado Geological Survey.
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-The statutory feasibility report requirement for the siting of an I.S.D.S. is too vaguely worded to force an adequate evaluation of specific site considerations when an I.S.D.S. is proposed. A model feasibility report format should be provided by the State Water Quality Control Division to local health boards in order to clarify minimum information to be provided by an applicant for an I.S.D.S.
-The State Water Quality Control Commission should be provided sufficient field staff to periodically review the regulations adopted by local health boards, and monitor on a random basis the implementation of their regulations. A system for violation hearings and fines must accompany these functions to ensure compliance.
Special District Approach -
Additions to the Special District Control Acts service plan requirements should be made as follows:
- Beyond the mandatory compliance with an adopted County Master Plan and zoning or other form of landuse control,
there should be specific findings tied to the land use concerns established under H.B. 1034 of the 1974 General Assembly. The 1041 regulations enable counties to "control
extensions into a new area on the basis of the financial and
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environmental capacity of the area to sustain growth". Most counties, however, have not adopted 1041 regulations, making this an ineffective way of dealing with this need.
-A Municipality's master plan be must taken into account during the service plan review process if a district is proposed within 3 miles of the incorporated limits of that municipality. Findings of compliance must be made part of the record in a countys approval of a district service plan.
-Findings should be made in the service plan about other urban services in the proposed district boundaries, including managing entities, levels and types of service. The service plan should declare whether or not the proposed district is appropriate or necessary given the extent of other services in the area.
-Capital improvements plans for special districts should be required for public review on an annual basis, to clarify what and where major improvements will be constructed over a five year period. This would in turn enable other service entities to coordinate their improvements programs with each other.
-The Special District Control Act now requires all existing special districts to maintain an up to date service
plan, and submit any substantive changes for county review.
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Any changes should comply with the above conditions.
Most of the points made above are included in the Colorado Division of Local Government's suggested service plan review process. It is recommended however, that these become mandatory rather than advisory.
Regional Approach -
- It appears that the problems associated with this approach are not related as much to inadequacies when it is used, but factors that make it infrequently adopted as an approach by local jurisdictions. There are two major ways of contending with this situation. First, by restricting the inappropriate use of other alternatives, the regional approach becomes more attractive to local governments. Secondly, the states elimination of technical and financial assistance to local governments with regard to land use planning and growth management has tended to halt any momentum towards intergovernmental agreements. It is recommended that the local government assistance program under 1041 be reinstated, with an emphasis on the creation of intergovernmental planning and service agreements for fringe areas surrounding municipalities.
-Another potential drawback for the regional approach is
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the inability for a municipality to finance the extension of sewer lines into outlying areas. The State Water Quality Control Division should place priority on funding municipalities to construct phased extensions beyond their incorporated boundaries.
Mixed approach -
Because the mixed approach represents current inadequacies of other methods, it is difficult to propose further improvements. There are specific ways in which this alternative can be made more efficient, however.
-The LID formation process as set forth in the Statutes is difficult for counties to implement without interpretation and clarification. It is suggested the Division of Local Government provide an information pamphlet for county government, explaining the advantages and disadvantages of LIDs, a flow chart depicting the formation procedure, and clarification of required standards for formation.
-A reinstated 1041 local government assistance program should emphasize working with situations where the mixed approach is present. Assistance should be offered to establish sewer policies for the area, and provide information on intergovernmental contracts. By doing so, there is at
least an opportunity for counties and central municipalities
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to avoid further entrenchment of duplicative costs for service, promote a fair rate schedule for properties outside of incorporated boundaries, and more rational service extension decisions.
General Recommendations -
-In conducting research for this thesis, it became apparent that data about sewer service in Colorado are not readily available or organized in a usable way. Information about grant awards for EPA 201 Programs in Colorado including the number of communities participating, the total amount expended, and the general way funds were expended were accessible only by a computer printout of all checks issued to local government by the State, with no totals and cryptically coded explanations. It would be helpful for anyone interested in sewer service on a local level to gain a picture of the magnitude of the 201 Program in Colorado.
-The State Land Use Commissions report on landuse planning in Colorado, last prepared in 1983, should be updated and enlarged to cover different types of growth management controls in county and municipal jurisdictions.
-Assistance should be provided by the Water Quality
Control Commission to local health departments in
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establishing and managing effective data bases on I.S.D.S.
The data should be organized by location, age, and type of system, size of parcel, and history of repairs or replacement. This could create a major step towards relating sewage disposal systems to landuse and the environment, and lead to a maintenance tracking program. This requires a
much greater emphasis on providing field staff than has been demonstrated by the State Water Quality Control Division.
-Profiles on successful intergovernmental agreements between municipalities and counties for managing the urban fringes development should be developed by the Department of Local Affairs. Such information can be used as a powerful tool in educating local decision makers about better intergovernmental relationships.
Recommendations for Further Research
The presence of an urban fringe around many Colorado municipalities may be readily acknowledged by those in the planning community, but there is little information about it. The U.S. Department of Census in the diennial population counts, separate Census Designated Places for special consideration, and these Places come closest to areas on the urban fringe. Unfortunately, criteria for meeting the Census
Designated Place category restrict the terra enough to by pass
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many urban fringe areas. And, as pointed out above, data regarding sewer service on the urban fringe is limited, and difficult to obtain. Considering these factors, it is recommended that further research be conducted on services and the urban fringe around Colorado municipalities. There should be survey work for the population centers identified in the documents of the Colorado Land Use Commission during the 1960s, to investigate how services are delivered there now.
It is also recommended that county governments be surveyed for certain key positions, including:
-How they define their relationship with municipalities in their jurisdiction. What problems do they percieve with this relationship.
-What role do they percieve themselves playing with regard to urban populations in unincorporated areas, and what problems do they see with that role.
-What is their understanding of the relationship between services, land use planning and regulation, urban development.
-As further information becomes available, it would be possible to arrive at detailed models of urban fringe growth and development, to identify with greater precision the
impacts arising from these scenarios, and to provide better
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guidance to local and state officials.
Speculations on Long Term Change
Land use planning legislation only goes part of the way to define effective approaches to growth management. There is little recognition of the relationship between services and land use in the language of state legislation enabling counties to control development. It would seem appropriate to require all counties to adopt master plans in Colorado, as has been done in Florida, with model documents and technical
assistance available from the state. The planning process should take into account in detail the environment, the way services should be provided, and a capital improvements plan.
As indicated in the second chapter, the state has adopted a nonproliferation policy for multiple sewer systems, which has accomplished a great deal to package plants. Yet there is no similar policy for water systems, creating conflicts between general standards about service. Essentially, there may be multiple water wells, private companies, and special districts providing potable water on the urban fringe, and working against any gains made in consolidating sewer service. It is recommended that a similar anti proliferation policy be adopted by the state as that in place for sewer service.
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The use of individual sewage systems in areas next to municipalities will always cause problems, because the densities necessary for their use are not efficient, yet are high enough to eliminate viable farm units. This problem could be addressed by requiring larger lot sizes for an I.S.D.S., such as 10 acres or greater. The other way this might be handled is by requiring the health department to make a determination that the site is not in a designated growth area of the County before issuing a permit.
< Counties must be better prepared to manage the growth they
have allowed in Colorado. Possible ways to improve their performance include required orientation to governmental roles in urban development, principles and practice of land use planning, and delivery of urban service strategies. Another improvement would be legislative, enabling counties under a single clearly drafted bill to provide the full range of urban services, rather than rely on complicated amendments to existing statutes now in place. Finally, it should be mandated that counties adopt master plans within a specific time frame, as opposed to the open ended wording in existing legislation. The master plan would then be the legal basis for adopting zoning resolutions and capital improvements plans, rather than adopting these documents on an almost arbitrary basis as is now commonly done.
124


SOURCES CONSULTED
Books
Aronson, J.Richard and Schwartz, Eli, Ed. Management Policies in Local Government Finance 1981.
International City Management Association. Washington D.C.
Binkley, Clark, et al; Interceptor Sewers and Urban
Sprawl. Lexington Books, 1975. D.C. Heath and Company. Lexington, Mass.
DeGrove, John M. Land, Growth and Politics. 1984.
Planners Press, American Planning Association; Washington D.C.
Hollman, Howard. Small and Large Together:Governing the
Metropolis. 1976. Sage Library of Social Research.
Scott, Randall W., Editor. Management & Control of Growth;
Volume I. 1974. The Urban Land Institute; Washington D.C.
Tabor Richard D., Micheal Shapiro and Peter Rogers. Land Use and the Pipe. 1976. Lexington Books. DC Heath and Company; Lexington, Mass.
Warner, Dennis, and Dajani, Jarir S..Water and Sewer
Development Rural America. 1975. Lexington Books, D.C. Heath and co. Lexington Mass.
Other Publications
Colorado Environmental Commission; "Colorado: Options For the Future". March 1972.
Colorado Department of Health, Water Quality Control Division, Colorado Sewer Needs Categorization List. January, 1988.
_____.Water Quality Plan For Region 11. September,
1986.
_.Annual Report on Waste Water Treatment Needs. January, 1988.


Colorado Department of Local Affairs, Division of Local Government, "Land Use Planning in Colorado". 1983.
_____Colorado Division of Local Government,"Special District
Control Plans" October, 1988.
_____Division of Planning, Human Settlement Policies July
20, 1979.
Colorado Land Use Commission. A Citizens' View of Land Use in Colorado. 1976.
Colorado Municipal League,"The Role Of Special Districts in Colorado", Denver, Colorado. 1984.
Colorado State Auditors Office, Summary Table,"Limits for Bond Financings", 1987.
Government Finance Review, "Infrastructure financing", August, 1986.
Henry, James, Attorney at Law; "The Relationship
between Cities and Special Districts in Colorado" Paper submitted at the Colorado Municipal League Annual Conference, Vail, Colorado. June 13, 1985.
Kelly, Eric Damian. "Piping Growth: The Law, Economics and Equity of Sewer and Water Connection Policies." 1984.
Land Use Law and Zoning Digest 36, no.7
Mesa County and the City of Grand Junction Planning Departments. Mesa County Data Book. 1985.
Mesa County, Colorado Board of County Commissioners, Minutes. February July, 1961. Mesa County Clerk and Recorders Office, Grand Junction, Colorado.
_____Minutes, 1973. Mesa County Clerk and Recorders Office,
Grand Junction, Colorado.
_____"Mesa County/Grand Junction Sewerage Agreement." May 18,
1983.
_____"Mesa County Sewer Policy Paper". 1985.
Paragon Engineers,"Carrying Capacity Study for the Grand Junction Area". Grand Junction, Co. November, 1979. Funded by the Colorado Oil Shale Trust Fund.


Small-Cooley and Associates, Denver, Co. Grand Junction ; Master Plan. 1970.
1980:
U.S. Department of Commerce, Census Division, 8th Summary; 1960, 1970, 1980.
Interviews
Bowman, Dick, District Engineer, Colorado Department of Health. Water Quality Control Division. Interview with author, August 29, 1988, Grand Junction, Colorado.
_____August 30, 1988.
Caldwell, Russell, Bond Investment Counselor for Kirchner and Moore Inc. Interview with author, in May 1986. Denver, Colorado
Davidson, Cliff, Robert Engelke and John Ballagh, employed as planner with the Mesa County/Grand Junction Development Department during the years 1972-1981. Numerous interviews during the summer of 1988.
Galligan, Peggy, Grants Coordinater, Colorado Department of Health, Water Quality Control Division, Western Slope Section. Interview with author, March 31, 1988, Grand Junction, Colorado.
_____ April 12, 1988.
Jordan, Blake, Bond Counsel for Mesa County Local Improvement District Program. Numerous conversations with author during 1985 and 1986, Denver and Grand Junction,
Colorado.
Mamet, Sam Deputy Director, Colorado Municipal League.
Interview with author, February 12, 1987. Denver,
Colorado.
Matthews, Gary, engineer with Ute Water Conservancy District.
Interview with author, November 17, 1988. Grand Junction, Colorado.
Meiklejohn, James, Sanitarian, Mesa County Department of Health. Interview with author, July 7, 1986, Grand Junction, Colorado.


Trainer, Greg, City Utilities Director, and Manager of the
Persigo 201 System in Mesa County. Interview with author, April 3, 1986, Grand Junction, Colorado.
Watson, Duain, Sanitary Engineer, Colorado Department of
Health, Water Quality Control Division. Interview with author. March 31, 1988.
______April 12, 1988
______October 18, 1988.