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<br />- <br />I <br />- <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br /> <br />001726 <br /> <br />MUSICK, WILLIAMSON, SCHWARTZ, <br />LEAVENWORTH & COPE, P. C. <br /> <br />Water Quality Control Commission <br />June 27, 1980 <br />Page Two <br /> <br />The proposed Class 1 classification is an upgrading of the <br />stream, and as the evidence indicates that the benefits which <br />will result from such upgrading are questionable, Louisville <br />believes that the economics of meeting such a classification <br />are particularly important in this case. Presently, the City <br />estimates that it will cost $2,138,000 for the City to treat <br />the ammonia levels that will be required by the 0.06 mg/l intra-stream <br />standard for a 2.68 MGD plant. In addition, there are two other <br />communities, Lafayette and Erie, which also discharge into Coal <br />Creek. The costs of upgrading those facilities should also be <br />considered in weighing the benefits to be achieved by the 0.06 <br />mg/l unionized ammonia standard. <br /> <br />II. Class 2-Warm Water Aquatic Life Classification. <br /> <br />On April 8, 1980, Gary Broetzman of the Water Quality Control <br />Division submitted a memorandum to the Water Quality Control <br />Commission ("Commission") setting forth some key issues for the <br />South Platte River proposed stream classifications. On page 2, <br />paragraph 4, concerning Coal Creek, Mr. Broetzman stated as follows: <br /> <br />Although the present quality along the stream <br />in the lower reaches is poor, we propose <br />a Class 1 Warm Water Aquatic Lire classi- <br />fication because of the capabilities to <br />restore such a habitat once a municipal point <br />source discharge is improved. <br /> <br />Thus, the WQCD determined to propose an upgrading for the stretch <br />of Coal Creek which includes the Louisville discharge point. <br /> <br />The proposed classification for this segment of Coal Creek <br />is Class I-Warm Water Aquatic Life, a classification which requires <br />waters which "provide, or could provide, habitat consisting of <br />water quality levels and other considerations such as flow and <br />streambed characteristics which could protect and maintain a <br />wide variety of warm water biota, including a sensitive species." <br /> <br />Louisville believes that Class 2-Warm Water Aquatic Life <br />is more appropriate for this segment of the stream. This classifi- <br />cation states that "these are waters where the potential variety <br />of life forms is presently limited primarily by flow and streambed <br />characteristics. Standards will be assigned to protect existing <br />species and encourage the establishment of more sensitive species <br />which are compatible with the flow and streambed characteristics." <br />