Comment
How and where does the ACS account for the resorts own permit to take water?
The ACS Does Not Appear to Account for the Resort’s Permit to Take Water (PTTW)
The resort holds an active Permit to Take Water (ERO 019 6965), allowing withdrawal of:
• 131,000 L/day for potable water + 11,498,000 L/day for snowmaking
• Up to 80 days per year
These withdrawals:
• Reduce river flow
• Reduce dilution capacity
• Occur during winter low flow periods
• Coincide with the most sensitive conditions for ammonia and DO
• Alter temperature and timing of return flows
However, the ACS assumes:
• Fixed flow
• No water withdrawals
• Instantaneous mixing
• No snowmaking impacts
Conclusion:
If the ACS does not incorporate permitted water withdrawals, then the calculated assimilative capacity is overestimated, and the effluent limits are based on unrealistic flow assumptions.
If the ACS does not incorporate permitted water withdrawals, then the calculated assimilative capacity is overestimated, and the effluent limits are based on unrealistic flow assumptions.
Submitted January 12, 2026 10:44 PM
Comment on
Searchmont Ski Resort, Inc. - Environmental Compliance Approval (sewage)
ERO number
025-1121
Comment ID
181721
Commenting on behalf of
Comment status