COMMENTS ON PROPOSED REVISIONS TO TETON COUNTY SMALL WASTEWATER FACILITY REGULATIONS

April 23, 2020

Comments submitted on behalf of Protect Our Water Jackson Hole, Wyoming Outdoor Council, and the Jackson Hole Conservation Alliance on the proposed revisions to Teton County’s small wastewater facility (SWF) regulations. The existing SWF regulations were adopted by the Teton County Board of County Commissioners on July 6, 2010. Amendments to WY Department of Environmental Quality regulations governing wastewater facilities necessitate revisions to the county’s regulations. Overall, although the proposed revisions contain a number of requirements likely to achieve environmental benefits, they lack many basic safeguards recommended by the U.S. Environmental Protection Agency in its Voluntary National Guidelines for Management of Onsite and Clustered (Decentralized) Wastewater Treatment Systems. The threat of significant impacts to both ground and surface water from a proliferation of residential septic systems in Teton County highlights a need for bold and decisive action to better protect public health and the environment in Teton County.

Original Proposal for Philanthropic Support for Comprehensive Wastewater Master Planning in Teton County, Wyoming

February 11, 2020

As our population and the number of visitors to our valley have grown the patchwork of wastewater treatment plants, independent sewer districts and septic systems has become responsible for treating larger and larger quantities of waste and, as a result, these systems are no longer sufficient for properly removing enough nitrogen and phosphorus from wastewater before it is discharged into our surface or ground water. The lack of county-wide wastewater planning has led to a loss of efficiency and economies of scale while having adverse effects on the health of our residents and the health of our local waterways. In the absence of any coordinated wastewater planning, the economic, regulatory and environmental issues surrounding this issue will only increase – exponentially.

Residential Landscape Best Practices to Minimize Impact on Water Quality

Many of the streams and creeks that flow into the Snake River in Jackson Hole have demonstrated elevated levels of algae that are well above what would be considered healthy for this area. Elevated algae levels can negatively impact fish habitat and human health. While we are not at crisis levels yet we want to solve this well before we get anywhere close. A prime cause of the algae is directly related to excess levels of nutrients entering the surface and ground water. It has been determined that one of the largest sources of this nutrient pollution comes from excessive residential lawn fertilizer applications.

Designing Residential Landscapes to Minimize Fertilizer Impact on Water Quality For Home Sites on the Valley Floor in Jackson Hole

Intended for Architects and Landscape Architects

Many of the streams and creeks that flow into the Snake River in Jackson Hole have demonstrated elevated levels of algae that are well above what would be considered abnormally high for the western US. A prime cause of the algae is directly related to excess levels of nutrients entering the surface and ground water. Elevated algae levels from nutrient loading can alter fish habitat, impact fishing conditions and create human health issues. While we are not at crisis levels yet we want to reverse this trend well before we get anywhere close to those circumstances.

Estimated Nitrogen and Phosphorus Inputs to the Fish Creek Watershed, Teton County, Wyoming, 2009–15

Scientific Investigations Report 2016–5160

By Cheryl A. Eddy-Miller, Roy Sando, Michael J. MacDonald, and Carlin E. Girard Prepared in cooperation with Teton Conservation District Scientific Investigations Report 2016–5160 U.S. Department of the Interior U.S. Geological Survey

Fish Creek – A Situation Assessment by Flitner Strategies

August 2014

Generally, the first step with any collaborative solutions process is the completion of a situation assessment that identifies the problem (e.g., environmental contamination) and key stakeholders (community residents, organizations, businesses, government representatives, etc.), envisions possible solutions, set goals, and develops a strategy that identifies the actions needed to produce desired results. In August 2014, Flitner Strategies released the report Fish Creek: A Situation Assessment. The situation assessment’s purpose was to gauge opinions and perceptions regarding changes to Fish Creek resulting from nutrient loading. The report goes on identify opportunities for developing a collaborative approach to stewardship of the watershed.

Applied Environmental Design and Research Report to the Crescent H Stream and Trail Committee

December 2013

In 2013, the Crescent H Stream and Trail Committee sought the independent advice of a qualified scientist to evaluate available information concerning possible nutrient pollution and biological degradation in Fish Creek. Specifically the Committee wanted the scientist to discuss the results of this USGS study in a national context, highlighting communities with similar water quality trends and successful best management strategies. The Committee retained the services of Applied Environmental Design and Research, Inc. (AEDR). In December 2013 AEDR released the Report to Crescent H Stream and Trail Committee; Assessments of Fish Creek, Teton County Wyoming and their implications for management and restoration efforts.

Characterization of water quality and biological communities, Fish Creek, Teton County, Wyoming, 2007–2011: U.S. Geological Survey Scientific Investigations Report 2013–5117

Eddy-Miller, C.A., Peterson, D.A., Wheeler, J.D., Edmiston, C.S., Taylor, M.L., and Leemon, D.J., 2013

Fish Creek, an approximately 25-kilometer-long tributary to Snake River, is located in Teton County in western Wyoming near the town of Wilson. Fish Creek is an important water body because it is used for irrigation, fishing, and recreation and adds scenic value to the Jackson Hole properties it runs through. Public concern about nuisance growths of aquatic plants in Fish Creek has been increasing since the early 2000s. To address these concerns, the U.S. Geological Survey conducted a study in cooperation with the Teton Conservation District to characterize the hydrology, water quality, and biologic communities of Fish Creek during 2007–11.

Characterization of interactions between surface water and near-stream groundwater along Fish Creek, Teton County, Wyoming, by using heat as a tracer: U.S. Geological Survey Scientific Investigations Report 2009–5160

Eddy-Miller, C.A., Wheeler, J.D., and Essaid, H.I., 2009

Fish Creek, a tributary of the Snake River, is about 25 river kilometers long and is located in Teton County in western Wyoming near the town of Wilson. Local residents began observing an increase in the growth of algae and aquatic plants in the stream during the last decade. Due to the known importance of groundwater to surface water in the area, the U.S. Geological Survey (USGS), in cooperation with the Teton Conservation District, conducted a study to characterize the interactions between surface water and near-stream groundwater along Fish Creek.

Seepage Investigation on Selected Reaches of Fish Creek, Teton County, Wyoming, 2004: U.S. Geological Survey Scientific Investigations Report 2005-5133

Wheeler, J.D., and Eddy-Miller, C.A., 2005

The U.S. Geological Survey (USGS) in cooperation with the Teton Conservation District conducted a seepage investigation of selected reaches of Fish Creek during 2004. The objective of the investigation was to estimate the magnitude of gains and losses in streamflow over six independent reaches of Fish Creek during two different flow regimes.