How and where does the ACS…

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.