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 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

There are multiple comments in the November 9 2018 (conservation letter) alleging District insincerity in the Report, including: “one desired result”, repeated references to “ultimate emphasis on a direct-discharge to the Gallatin River as primary means for wastewater management”, “lack of good faith”, “clear premise and inherent goal is ultimately a permittable direct surface water discharge as the alleged primary benefit and “solution” to high development pressure in greater Big Sky.

Response

These statements indicate that the authors of the may not have fully read the entire report, especially the three chapters on snowmaking, subsurface disposal, and additional irrigation (respectively).