We respectfully request the District take the time to thoroughly investigate…

Comment

“we respectfully request the District take the time to thoroughly investigate other technologies and strategies capable of meeting the legitimate needs for certainty in securing fresh water supplies and and wastewater disposal options over the next decade before committing any resources toward pursuing or financing infrastructure or regulatory authorizations supporting a surface water discharge permit as proposed in the Report.”

Response

1. The District has always, and will continue to consider treatment technologies and strategies for disposal. However, the discharge to the Gallatin River is needed to provide a disposal method that is not reliant on third-party agreements, high pressure pump stations, a single 7+ mile pipeline, or large storage reservoirs. Surface water discharge is needed to provide the resiliency and redundancy necessary in all critical water infrastructure systems.

2. The Phase 1 MBR project is not infrastructure supporting a surface water discharge permit, it supports all potential reuse efforts.

Through the Big Sky Sustainable Water Solutions Forum (BSSWSF), the greater Big Sky …

Comment

“Through the Big Sky Sustainable Water Solutions Forum (BSSWSF), the greater Big Sky Community expressed clear goals favoring innovative water resources management… …In stark contrast, the Report’s emphasis on WRRF Upgrades only as necessary to achieving the ability to discharge to surface waters lacks consideration and is troubling considering the two years invested in the BSSWSF by the District’s General Manager and severage District Board Members…”

Response

1. The BSSWSF focused on snow-making as one of the avenues for the District to achieve effluent water balance. As the report explains, that alternative is not in the District’s control.

2. The statement “The Report’s emphasis on WRRF upgrades only as necessary to acheiving the ability to discharge to surface waters.” Again, this indicates that the authors of the conservation group letter did not read the full report, especially the three chapters on snowmaking, subsurface disposal, and additional irrigation (respectively).

3. The Gallatin River Task Force has formally voted to support Phase 1.

The conservation letter references “disposal of at least 160 mgy”…

Comment

The conservation letter references “disposal of at least 160 mgy” (million gallons per year).

Response

As stated on multiple occasions and in the CDR, There is no intent to dispose of 160 mgy annually to the Gallatin. This is an approximate, proposed discharge permitting goal, to cover potential emergency discharges in the event of a reuse pipeline or large reservoir failure. The estimated need for disposal to the Gallatin River, if needed and at full build-out of the District, is 70 mgy (See Figure 2 of the Executive Summary).

There are multiple comments in the November 9 2018 (conservation letter)…

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).