September 13, 2023
Save Holland Lake News
Montana’s Environmental Department Says Holland Lake Lodge Wastewater System Likely Leaking
SHL Pushes State, Forest Service, Missoula County to Protect Pristine Environment
(Contact: Bill Lombardi 406-459-8860)
(Condon, MT) – Montana’s environmental agency says Holland Lake Lodge’s wastewater system is likely leaking, and Save Holland Lake is pushing state, U.S. Forest Service and Missoula County officials to protect pristine waters in the area proposed for a large destination resort overwhelmingly opposed by Americans.
In response to a complaint, the ad-hoc grassroots group Save Holland Lake (SHL) recently received a memorandum from the Montana Department of Environmental (DEQ) acknowledging that the wastewater lagoon system serving the lodge and nearby U.S. Forest Service (USFS) campground system is likely leaking and could be contaminating groundwater and surface water owned by the public and managed by the USFS.
“The complaint noted a decrease in the number of times that spray irrigation occurred from the wastewater lagoon since 2003, based on sampling data required by Missoula County,” says DEQ’s August 21, 2023 letter to the USFS.” This decrease was noted even though the number of visitors appeared to have increased. After the complaint was filed, DEQ’s Engineering Bureau determined that the lagoons may be leaking in excess of the allowed rate. After looking at nearby precipitation and evaporation data, effluent volume and spray irrigation records, DEQ’s Engineering Bureau determined that the lagoons may leaking [sic] in excess of the allowed rate and that a water balance study may be needed to get an accurate estimate of leakage.”
“This lingering wastewater problem and leakage into a pristine environment is a perfect example of why the lodge expansion shouldn’t be authorized,” said David Roberts of SHL. “Public agencies responsible for monitoring wastewater need to protect our public lands and waters. It’s that simple.”
SHL noted that tripling the lodge’s size and extending its operating season to year round will only exacerbate the problem when wastewater failures occur.
Two DEQ employees visited the Holland Lake wastewater lagoon site in June this year. And, in an August report and letter, DEQ told the USFS that the state environmental agency recommends a “water balance study to provide a more precise estimate of leakage from the system.” Such a study, DEQ added, would be required by the agency’s Engineering Bureau before approval of any expansion of the system.
(Tripling the size of the lodge and its ancillary operations, including an enlarged dining hall, could increase wastewater to six times the current rate produced at the lodge, which is located on public land and in prime bull trout habitat.)
DEQ requested that the Forest Service complete the water balance study by September 17 to determine the next steps to meet compliance.
“A lagoon leaking in excess of the allowed rate, or land application at greater than agronomic rates, could be considered a discharge to state waters without a permit,” DEQ said in its letter to the USFS.
Margarite Juarez Thomas, DEQ’s Environmental Enforcement Specialist in the agency’s Enforcement Program, also noted to the USFS pertinent state laws regarding the complaint:
• “It is unlawful to cause pollution of any state waters or place or cause to be placed wastes where they will cause pollution of any state waters.”
• “It is unlawful to carry on any of the following activities without a current permit from the department: discharge sewage, industrial wastes or other wastes into any state waters.”
• Pollution is defined as contamination or other alteration of the physical, chemical, or biological properties of state waters that exceeds that permitted by Montana water quality standards...”
• State Waters are defined as “a body of water, irrigation system, or drainage system, either surface or underground.”
• “Prohibited acts. A person may not: (1) commence or continue construction, alteration, extension, or operation of a system of water supply or water distribution that is intended to be used as a public water supply system or a system that is intended to be used as a public sewage system before the person submits to the department necessary maps, plans, and specifications for its review and the department approves those maps, plans, and specifications;” )
DEQ’s letter also was copied to Scott Snelson of the USFS, Rachel Clark of DEQ, the Missoula County sanitarian, and Vincent Chapell of the Seeley Lake Water District.
Since last winter, SHL has prodded federal, state and county officials to take action on the wastewater problem at Holland Lake, especially because the watershed is prime habitat for bull trout, which are listed as a threatened species under the Endangered Species Act and require large watersheds with cold, clean water to thrive.
SHL also recommends that:
• An independent third party (not the USFS or the lodge developer’s engineering firm) perform an agreed-upon testing protocol, which may include the water balance test proposed by DEQ and installation of groundwater monitoring wells downgradient from the plant to be tested.
• Equipment upgrades be made immediately to the wastewater plant, including new inflow monitors that report in real time. Accurate outflow monitors should also be required.
• All testing and reporting requirements from the existing permit should immediately be required and be made public in real time.
Missoula County issues and holds the wastewater permit and this issue has immediate potential health and environmental impacts in the county.
Background
Even before a proposed expansion, Holland Lake Lodge is the primary source of sewage near Holland Lake, even with a limited operating season. The lodge draws its water from a shallow groundwater well, and its sewage is pumped uphill to a USFS wastewater treatment plant above the campground, where wastewater is spray-irrigated into the woods.
SHL has questioned if the lodge’s current wastewater plan operates safely and properly, with adequate management, monitoring and oversight. Previous monitoring reports, for example, have shown that the plant failed three of four tests required for permitting.
Test reports attached to the 2004 permit show three of four tests failing for total suspended solids (TSS) and biological oxygen demand (BOD) limits in 2003, while other monitoring requirements, such as coliform tests, were not included. Despite these failures, the permit was issued. When POWDR submitted its Holland Lake Lodge expansion proposal in 2022, WGM attached a “Wastewater Technical Memo” stating that the existing wastewater treatment system appears to be in working condition.
Through a Freedom of Information Act (FOIA) request, SHLreceived flow readings from the campground and lodge to the wastewater plant, as well as some irrigation records. SHL submitted another FOIA on Feb. 27, 2023, requesting the remainder of records required to be kept by the permit holder. As of this date, the second FOIA has not been returned, although the new DEQ report would suggest some of these will be lacking or missing entirely.
But as SHL analyzed the data it received, it became apparent that the numbers did not add up. More wastewater was being pumped into the plant than was being irrigated after treatment.
SHL discussed this issue with former Flathead National Forest (FNF) Supervisor Kurt Steele and Tami MacKenzie, FNF deputy supervisor, in a meeting last winter. SHL had a follow up discussion with Beth Gardner, a USFS employee who administers the HLL Lodge permit, and Peter Borgensen, the West Zone Environmental Engineer for the USFS’s Northern Region, in February. The discussions were intended to understand the issue, find possible solutions and allow time for a plan or fix prior to the 2023 season. These discussions seemed to achieve no traction.
SHL also had discussions with Missoula County and Montana DEQ. Although the permit issued through Missoula County has monitoring requirements, neither Missoula County nor Montana’s DEQ actually require these records to be submitted or reviewed.
It became apparent to SHL that the only way to press the issue forward – and to gain answers –was to issue a formal complaint to DEQ. SHL’s complaint was sent in early May 2023.
After being told the report was done and waiting for a cover letter in early July, the report was finally issued to the Forest Service on August 21, 2023.
The report’s upshot: The DEQ letter notes DEQ Engineering Bureau “determined the lagoons may be leaking in excess of the allowed rate,” and suggests the USFS conduct a water balance test prior to September 17, 2023.
This is not an acceptable solution to a potential ongoing problem.
DEQ is asking the same agency and in fact the same people that have ignored this issue to selfperform a test that would be incredibly easy to manipulate and then report back. This will mean the lodge and campground have pumped water to the apparently leaking lagoons all season and now will push any repairs into the following year or just claim there is no problem.
There were numerous other indications of a known problem. But even now, the solution proposed by the DEQ is to have this same group of people perform a test that can be easily manipulated and reported back. This is not acceptable.
And the USFS is still reviewing the transfer of the Holland Lake Lodge Special Use Permit to POWDR, which has indicated it still plans to submit an Master Development Plan and expansion proposal that does not compromise on scale. That would require a significant expansion to this system.
Save Holland Lake has again reached out to the USFS to propose a common-sense approach that we could work with them on. And once again the communication has fallen silent.
The people who were aware of the failing wastewater system are the same people who want to be trusted with expanding the lodge and creating a major increase of flows to this plant to serve the lodge.
Following is a letter written by Margarite Juarez Thomas (Environmental Enforcement Specialist) to Patrick Siers at the Flathead National Forest
August 21, 2023
Patrick Siers
United States Forest Service 650 Wolfpack Way Kalispell, MT 59901
RE: Water Quality Complaint [CVID #24989]
Dear Mr. Siers:
The Montana Department of Environmental Quality (DEQ), Enforcement Program received a complaint alleging that the wastewater lagoon system serving the Holland Lake Lodge and United States Forest Service (USFS) Campground (system) may be contaminating groundwater and surface water, on property owned by the USFS located on Holland Lake Lodge Road near Condon, Missoula County, Montana (property).
The complaint noted a decrease in the number of times that spray irrigation occurred from the wastewater lagoon since 2003, based on sampling data required by Missoula County. This decrease was noted even though the number of visitors appeared to have increased. After the complaint was filed, DEQ’s Engineering Bureau determined that the lagoons may be leaking in excess of the allowed rate. After looking at nearby precipitation and evaporation data, effluent volume and spray irrigation records, DEQ’s Engineering Bureau determined that the lagoons
may leaking in excess of the allowed rate and that a water balance study may be needed to get an accurate estimate of leakage.
On June 8, 2023, Josh Viall and Mike Abrahamson of DEQ performed a technical assistance visit at the system. That report was sent to you on August 17, 2023. The letter sent with the report describes and recommends a water balance study to provide a more precise estimate of leakage from the system. This water balance study would be required by DEQ’s Engineering Bureau prior to approval of any expansion of the system.
DEQ requests that you complete this water balance study by September 17, 2023, in order to determine any next steps needed for compliance in a timely manner. A lagoon leaking in excess of the allowed rate, or land application at greater than agronomic rates, could be considered a discharge to state waters without a permit.
I am providing the following information, to ensure that the USFS is aware of the Montana laws and rules pertinent to this complaint:
• “It is unlawful to cause pollution of any state waters or place or cause to be placed wastes where they will cause pollution of any state waters.” See §75-5-605(1)(a) Montana Code Annotated (MCA).
Patrick Siers August 21, 2023 Page 2
• “It is unlawful to carry on any of the following activities without a current permit from the department: discharge sewage, industrial wastes or other wastes into any state waters.” See §75-5-605(2)(c).
• Pollution is defined as contamination or other alteration of the physical, chemical, or biological properties of state waters that exceeds that permitted by Montana water quality standards...” See § 75-5-103(30)(a)(i) MCA.
• State Waters are defined as “a body of water, irrigation system, or drainage system, either surface or underground.” See § 75-5-103(34)(a).
• “Prohibited acts. A person may not: (1) commence or continue construction, alteration, extension, or operation of a system of water supply or water distribution that is intended to be used as a public water supply system or a system that is intended to be used as a public sewage system before the person submits to the department necessary maps, plans, and specifications for its review and the department approves those maps, plans, and specifications;” ) See §75-6-112(1) MCA
If you have any comments, questions, or believe any of the information stated above is incorrect, please feel free to contact me at the telephone number listed below.
Sincerely,
Margarite Juarez ThomasEnvironmental Enforcement Specialist Enforcement Program
(406) 755-8956
email: mjuarezthomas@mt.gov
cc via email: Scott Snelson, USFS Rachel Clark, DEQ ENG
Missoula County Sanitarian
Vincent Chappell, Seeley Lake Water District Complainant