WSP01843

• File Number: 5000.100
• Description: Flood Protection Section - Coal Creek Project
• State: CO
• Basin: South Platte
• Water Division: 1
• Date: 7/21/1980
• Author: City of Louisville
• Title: City of Louisville - Coal Creek Proposal
• Water Supply Pro - Doc Type: Report/Study

I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I

00173J

MUSICK. WILLIAMSON, SCHWARTZ,

LEAVENWORTH & COPE, P. C.

Water Quality Control Commission
June 27, 1980
Page Six

Louisville, therefore, believes that either a status quo
instream concentration should be set on this segment of the stream,
or the number be set on a case-by-case basis. To prevent degradation,
individual numbers could be set reflecting the present instream
concentration at the point of discharge for the Louisville sewage
treatment plant.

Louisville recognizes that the drinking wate~ standard which
is proposed is 0.5 mg/l. The City believes that this is a number
which they can probably meet with their present facilities. But,
this belief is based on only two summer samples and no winter
samples. (The proposal of the WQCD appears to be based on one
sample.) Thus, Louisville believes that additional sampling is
necessary in order to set a proper number for this segment of
Coal Creek.

IV. Conclusion

Louisville believes that the evidence supports the conclusion
that Coal Creek should receive a Class 2-Warm Water Aquatic Life
classification and not a Class 1-Warm Water Aquatic Life classi-
fication. Should the Commission desire such an upgrading of the
stream, Louisville believes that the incredible economic burden
that will be placed on the communities in achieving the proposed
ammonia level does not justify the elusive improvement that may
be expected in the fishery.

Louisville believes that the evidence submitted indicates
that a reduction in ammonia concentration will have a doubtful
improvement on the fishery for this segment of Coal Creek. Therefore,
if the Commission desires to upgrade the fishery in this area,
Louisville proposes that the Commission establish an in-depth
study, as suggested by Dr. Lewis, for this segment of the stream.
Thus all factors which affect the fishery can be addressed and
ultimately evaluated. In the interim, Louisville believes that,
due to the enormous expense involved in treating to the 0.06
mg/l ammonia instream standard, the Commission should presently
set an ammonia level on the stream which maintains the status
quo until future decisions can be made on adequate information.

Finally, it should be noted that in the Water Quality Standards,
Section 3.l.6, the Commission states that