“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.”


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.