Northern South Park has recently become the proposed site for nearly 1,000 new houses, each of which will need connection to water and sewer.
Before we can even begin to analyze their value to our community, we must first ask if we can absorb that growth without further imperiling our water. As a community on the headwaters of the Wild and Scenic Snake, and as a community that relies on a single aquifer for all of our drinking needs, we must engage in responsible planning to protect our water. Read the full version of this joint letter with the Wyoming Outdoor Council and Protect Our Water Jackson Hole here.
We have a water quality crisis.
Over 40 years ago, a study tied to our first land use plan recognized the threat of insufficient wastewater treatment and poorly functioning septic systems. The study identified high groundwater and coarse soils in many areas of the county as constraints to septic systems’ functionality, increasing the potential for contaminating wells, surface water, and groundwater. Importantly, it also established “environmental protection districts” for the land use plan to ensure future density would work within those constraints. And of the 19 total policies in our first comprehensive plan, one clearly specified the need to protect water quality from discharged wastewater.
Yet decades later, our current Comprehensive Plan no longer references the 1978 water quality plan and, further, lacks a water quality or wastewater vision. Groundwater protection districts have since been removed, and we have 3,600 private septic systems dotting the valley—located without adequate setbacks from wells or other water sources, and free to operate without any inspection and maintenance requirements. Many of those old systems are now leaching minimally treated wastewater into the Snake River Aquifer, our sole source of drinking water.
With respect to drinking water, nearly all of the county’s 114 public water systems lack basic protection plans, while others show alarming increases in nitrate concentrations, indicating the presence of insufficiently treated sewage. We’ve seen nitrate concentrations in Hoback’s drinking water exceed the Environmental Protection Agency’s limits, necessitating expensive equipment and prompting community efforts to find alternative water sources. And Hoback isn’t alone; the Teton Conservation District recently presented several other areas experiencing rising nitrate levels to the Board of County Commissioners.
The pattern is clear: past leaders permitted irresponsible development, and our community members without clean water are paying the price today. We thank this Board of County Commissioners for supporting water quality in the Comp Plan Update and allocating matching funds for a wastewater management plan as proposed by Protect Our Water Jackson Hole. Let’s not endanger that progress now by approving massive new subdivisions without the best wastewater solutions.
A comprehensive wastewater management plan must be in place before considering any upzones in Northern South Park.
We have no analysis of the demand for drinking water, how much wastewater will be produced, and how it will fit into the county’s overall wastewater management. Introducing even more fragmentation, as proposed by the Gills’ offering of a new utility, is a direct contradiction to the EPA’s recommendations for “areas of greatest environmental sensitivity” including “sole source aquifers.” We cannot envision a standalone solution for these subdivisions that would not further imperil our water.
Referencing the county’s own regulations, our back-of-the-envelope math indicates that full build-out could yield hundreds of millions of gallons per year of wastewater. Town Council has wisely indicated its unwillingness to allow any connections to its treatment plant or water system without a neighborhood plan.
And even if connections were granted, Public Works staff has advised Town Council that:
When we start looking at bringing on large areas of the county onto the sewer treatment plant, the number one thing I think…you as the council needs to understand, that will trip us into a larger discussion…we have to start considering an expansion. Because…this doesn’t happen overnight; it’s years of planning, environmental review, EPA review, DEQ review. Plus there’s the funding piece too of getting that together.
The current proposed upzones would surge well past the units projected in the town’s ongoing sewer capacity study. Nearly 1,000 homes proposed could translate to around another 2,200 residents. An unexpected population increase of more than 21% in town would clearly hasten the timeline that town taxpayers would be required to make a greater investment. And if connection to town infrastructure were never granted, the county might need to consider its own plant, which depending on size, could cost its taxpayers nearly $10-15M.
We must keep our headwaters healthy.
A county-wide wastewater management plan should precede –and inform– any large and unplanned changes to the county’s development and must be implemented through a neighborhood plan. Our community deserves safe drinking water and swimmable streams: our abundant wildlife, recreation-based economy and way of life depend on clean water.