Northshore Water Alliance Public Comment on PFASNSWAO
North Shore Water Alliance
To: Kalispell City Council Members Date: 34-2024
I am here tonight representing North Shore Water Alliance. The mission of the North Shore Water
Alliance is to advocate for the protection of water quality throughout the Flathead Valley with
emphasis on the areas just north of Flathead Lake. We aim to educate the public on current and long-
term risks to both ground and surface water quality throughout the Flathead region given the on -going
and rapid growth that the Flathead is and will be facing.
First, I hope that Kalispell will actively investigate the source of contamination of PFAS I in its wells,
given the known serious health effects it poses. Research shows there are four major sources for how
PFAS gets into drinking water: fire training/fire response sites, industrial sites, landfills, and
wastewater treatment plants/biosolids.
In our comments this evening I would like to share with you, additional concerns we have for other
high -capacity Kalispell City wells located north of the Lakeside -County Water and Sewer District
(LCWSD). LCWSD is currently applying for a groundwater discharge permit to add to the volume of
waste they are currently permitted to accept. LCWSD is now proposing to take all septic tank waste in
the county from some 30,000 homes. This is in addition to the permit they currently have for the spray
application of the partially pre-treated sewage onto several hundred acres of alfalfa fields. LCWSD
currently collects sewage year around from Somers and south along Flathead Lake and both sides of
Highway 93 through Lakeside and almost to Angel Point. They do not have a sewage treatment plant
as does Kalispell (though they are talking about building a less sophisticated version of a sewage
treatment plant in the near future, whose wastewater would be fed into their proposed ground water
discharge system and when needed also spray applied). LCWSD currently relies on aerated holding
ponds for limited pre-treatment of the sewage before it is spray applied to alfalfa fields.
The proposed ground water discharge permit LCWSD is applying for is of major concern to us and
should be to the City of Kalispell, because you have two 1000 gallon per minute city wells whose
drawdown areas include the LCWSD facility and its treatment areas. Even DEQ has issued two letters
of deficiency to LCWSD to date regrading LCWSD's application for groundwater injection and the
need to show this proposed groundwater injection system will not cause harm to surface and
groundwater in the area.
It is essential to understand that the aquifer underlying the LCWSD property is very shallow and
LCWSD property sits one mile north of Flathead Lake and just west of the Flathead River and just
south of Ashley Creek and Wiley Slough.
' As stated on the EPA website ( Our Current Understanding: of the Human Health and Environmental Risks of PFAS I US EPA )
studies have shown that exposure to PFAS may lead to
Reproductive effects such as decreased fertility or increased high blood pressure in pregnant women.
Developmental effects or delays in children, including low birth weight, accelerated puberty, bone variations, or behavioral changes.
Increased risk of some cancers, including prostate, kidney, and testicular cancers.
Reduced ability of the body's immune system to fight infections, including reduced vaccine response.
Interference with the body's natural hormones.
Increased cholesterol levels and/or risk of obesity.
The Lakeside County Water and Sewer District is now proposing to take over some $21 million in
county funding, which the county received from federal ARPA funding to build a facility to treat all
the septic tank waste from some 30,000 homes in Flathead County. The County has recently decided
not to build this facility in part due to a doubling in costs for building the facility they received after
several years of being told it could be built for approximately $20 million.
LCWSD has also committed to taking the waste from several large new subdivisions (with others also
waiting for approval) that will require the addition of four new high -capacity wells in this same area.
Somers Water district is having to drill two new 400gpm wells to service the newly proposed
development, including Steamboat Landing Subdivision located in this same area of drawdown. North
Shore Water Alliance, along with over twenty other objectors, have filed an objection to the Cooper
Farms water rights permit for the two 300gpm wells to service this 700+ unit proposed subdivision
that boarders LCWSD. We have hired a hydrologist to look at the effect that this draw of water will
have on the water rights of the people who live here.
An additional major concern to us, and we believe to the City of Kalispell, is that there was no
mention in the DNRC's Environmental assessment of Cooper Farm's water rights application for high -
capacity wells and potential impacts to the these wells from their proximity to LCWSD's sewage and
proposed septic tank waste treatment facility within the area affected by the drawdown of water from
these new wells or the city's two existing 1000gpm wells. Among other concerns, we want factual and
scientific evidence that contamination from LCWSD wastewater treatment facilities, both groundwater
injection and spray application, won't be drawn down into our drinking water and that it won't end up
in our surface waters and eventually Flathead Lake. We hope you will join us and others in raising
these concerns with the Montana DNRC (Department of Natural Resources and Conservation) and the
Montana DEQ (Department of Environmental Quality).
We are asking that all the government agencies --- DNRC, DEQ, and the City of Kalispell look at this
entire situation as a full and complete picture and take into consideration the potential for toxic
contaminates including PFAS or high levels of nutrients found in sewage and septic tank waste, and
insist on clear evidence that the City of Kalispell's existing high capacity wells supplying city drinking
water, and that other private wells throughout this area, will not be harmed, now or in the future, by
the proposed current activities and future expansions of the LCWSD facilities and treatment processes.
Please, let's all work together proactively to make sure that the Flathead Valley's human waste is dealt
with in a way that will not harm or degrade our valley's world -class water quality. It is time to ask
hard questions of those agencies tasked with approving new wells and those agencies tasked with
permitting disposal of sewage and septic waste. Now is the time to pause and invest in studies to show
the best way forward to preserve the valley's priceless water quality.
Thank you for your time,
Jennifer Tipton
North Shore Water Alliance Board Chair
northshorewater23@gmail.com
406-253-7863