Comment

We believe this outcome (litigation) can be avoided if we work together and, as requested (herein), the District undertakes further analyses of alternative advanced treatment and disposal options…

Response

The District welcomes input from any interested party, but request the author’s acknowledge the sincerity of the District’s effort in evaluating treatment, technology and disposal options to date, which are thoroughly presented in the report. The District’s work in these arenas goes back many years. In addition, if there are specific “alternative advanced treatment” options that the authors feel are merited, please name them. The alternatives screened to date represent the best combination of powerful treatment performance and tried and true track records.

Comment

We respectfully remind the District that opportunity cost must be considered in failing to examine the alternatives discussed (herein). Specifically, please consider the cost of time lost in litigation

Response

Time lost could also slow the District from implementing projects that clearly benefit the environment. Based on the preliminary permitting work in the report, DEQ’s regulatory framework for surface water discharges appear to support discharge of effluents having a lower quality than an MBR plant would provide, without Advanced Treatment, outside the nutrient season.

Comment

Throughout the conservation group letter, there are references to other treatment and technology alternatives, that are more “robust”, “innovative”, “proven”, but somehow also “cutting edge”

Response

The source of the technical review accompanying the conservation group letter does not appear to have any experience with wastewater treatment process design (although none is claimed, only expertise). No treatment or technology alternatives are named, there are only nebulous references to their existence. The world of municipal wastewater treatment is not one to try to be too innovative or cutting edge, due to the challenging environments, harsh conditions and critical, 24/7/365 performance requirements. MBR is as robust and proven of a treatment technology as the field of wastewater treatment has ever seen.

Comment

If more robust treatment works capable of producing higher quality effluent is built, the District could use that effluent in a variety of ways including purple pipe projects, rapid groundwater infiltration, snowmaking, or indirect potable re-use via deep aquifer recharge safely and with certainty

Response

Please define “more robust treatment works”. The report documents that MBR is very capable of providing an effluent that meets Montana DEQ Class A-1 effluent, suitable for irrigation reuse (purple pipe), subsurface (groundwater) disposal, and is the preferred base treatment for indirect potable reuse in the United States, as evidenced by California’s use of MBR in Full Advanced Treatment regulations for potable reuse projects. And without detailed hydrogeologic information on the “deep aquifer”, there is nothing certain about injecting effluent into the formation, technically or regulatory, as DEQ currently has no IPR permitting framework.

Comment

The District should weigh the economic benefits of a scalable, state-of-the-art WRRF system upgrade with innovative wastewater recycling and re-use options against the illusion of certainty offered by direct-discharge

Response

MBR is the scalable, state-of-the-art WRRF. That is all that is moving forward at this time. The District will continue to develop reuse alternatives and is not implementing direct discharge at this time.

Comment

The Draft Report does not contemplate WWTF capacity upgrades capable of meeting pressing wastewater management needs in Greater Big Sky.

Response

The District does not have a mandate or the jurisdiction for sewering of the Canyon Area, or other un-sewered properties outside of its boundaries. An effort to sewer the Canyon and route the wastewater to either the site-constrained existing WRF or a new site will require several years to implement, and the District’s WRF needs expansion and upgrades much sooner than that. The best strategy at this time is to construct the most space-effective treatment possible at the existing WRF, which is MBR. Finally, if un-sewered portions of the area were added to the District’s wastewater responsibilities, the additional effluent generation would need direct discharge more than ever.

Comment

“the Report reflects a primary driver of WRRF upgrades emphasizes protecting ratepayers from spikes in fees, yet fails to provide any meaningful consideration of other available and proven upgrade technologies… …that would obviate the need for a direct-discharge to the Gallatin River.”

Response

1. Evidence is requested regarding other available and proven upgrade technologies that is more proven in providing a high quality effluent with a smaller footprint than MBR.

2. No treatment technology will obviate the need to have a direct discharge option for the District, as it is necessary for backup/emergency conditions at minimum.

Comment

In fact, it appears that community feedback – including that made by key ratepayers within the District – favoring innovative wastewater treatment and disposal alternatives that protect and improve the local environment condition without resorting to a direct-discharge to the Gallatin, was never a meaningful consideration underpinning the draft Report’s foci.

Response

The District has evaluated “innovative” wastewater treatment and disposal alternatives, these are described in the Report. And the selection of MBR for construction does “protect and improve the local environment condition without resorting to a direct-discharge to the Gallatin. The only wastewater treatment process proposed by a ratepayer was Integrated Fixed-Film Activated Sludge, which as explained and shown in the November 27th presentation, produces a worse-quality effluent than MBR, with a larger footprint and higher cost. It does not make sense given the site constraints at the existing WRF.

Comment

If the District takes an aggressive approach to bringing an MBR facility and other synergistic, advanced treatment technologies online we can expect a simplified process of permitting effluent snowmaking and groundwater recharge

Response

Note that the projected effluent quality from an MBR facility would meet discharge requirements for snowmaking and groundwater discharge, without “other synergistic, advanced treatment technologies”.