Holland Lake Lodge Wastewater Variance (Condon)

Dear Members of the County Health Board,

I am writing to respectfully request that the current variance request for Holland Lake Lodge be returned to Missoula Public Health for further evaluation. In its current form, there is insufficient information to justify approval, even with the proposed conditions.

Please consider the following points:

1. Delinquent Property Taxes
The applicant is currently delinquent on property taxes. I suggest that no further departmental work or evaluation be conducted until these payments are brought current.

2. Lack of Clear Ownership and Authority
There are currently six different business entities associated with Holland Lake Lodge on the Montana Secretary of State website. None is named Holland Lake Lodge LLC, as mentioned in MPH's first incomplete letter. It remains unclear who holds the controlling interest in the business operations and, crucially, who owns the improvements (buildings and infrastructure) on this public land. Per the State of Montana and Missoula County property information systems, the primary owner of these improvements is Christian Wohlfeil. The County should verify and share:

- Who holds the overall controlling interest?
- Who owns the infrastructure and improvements?
- Is the applicant legally authorized to request this variance on behalf of the owner of those improvements?

3. Failure to Meet Variance Criteria
A variance may only be approved if specific criteria are met. I do not believe the following requirements have been satisfied:

- Extraordinary Conditions: The current situation was entirely preventable. The applicant chose to close on the purchase with full knowledge that the property lacked a functioning, approved wastewater treatment system and was closed to the public. These were known risks that should have been addressed during due diligence prior to closing.

- Undue Hardship: There is no undue hardship that the applicant didn't know about before closing on the Lodge purchase. The status of the wastewater system and the Forest Service’s uncertain timeline for repair were well-documented and communicated before the sale.

The application and public comments contain statements that are unsupported, including employment numbers and claims about exclusivity of events on public land. The Board needs verified facts and documentation when weighing hardship and necessity.

- Feasible Alternatives: Numerous alternatives exist that would allow the property to generate income without a holding tank variance. These include food & beverage catering, gear rentals (paddle boards, canoes, etc.), and gift shop/online merchandise sales. That model provides immediate public land access, fulfills the mandate to provide recreational opportunities, and generates revenue without relying on exclusive events that strain limited infrastructure.

4. Public Health and Environmental Risk
Approving a two-year holding tank variance for the intense use outlined in the applicant’s Operating Plan is a significant risk. There are no clear safeguards regarding oversight, enforcement, or liability should the system fail. Furthermore, the regular presence of septic pumper trucks presents an environmental and aesthetic concern for this public area.
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Staff Recommendation to Approve the Holland Lake Lodge Holding‑Tank Variance
(Based on the February 12, 2026 Staff Report)

Comments:

1. Staff findings show the application does not meet multiple mandatory variance criteria

The Health Code requires all criteria to be met. Staff acknowledges uncertainty, conflicting evidence, and unresolved risks—yet still concludes the applicant “HAS MET” each criterion. That conclusion is not supported by the facts in the report.

Below is a point‑by‑point refutation.

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Criterion 1 — Extraordinary Conditions
Staff conclusion: Applicant met the criterion.
Refutation: The conditions are not extraordinary and were entirely foreseeable.

a. The lagoon failure was known, documented, and under enforcement before purchase
The staff report confirms that DEQ had already identified lagoon leakage, required monitoring wells, and issued violation letters in 2023—before the applicant purchased the lodge
A known,
documented system failure is not an extraordinary condition. It is a preventable business risk the applicant voluntarily assumed.

b. The Forest Service’s timeline is not an “extraordinary condition”
The staff report treats federal process timelines as extraordinary. They are not. Every operator on federal land must navigate NEPA, public comment, and agency review. This is routine, not extraordinary.

c. The Special Use Permit explicitly requires compliance with local health rules
The SUP states the operator “shall comply with applicable standards set by state and local health departments”
The applicant’s misunderstanding of local rules is not an extraordinary condition.

Conclusion: Criterion 1 is not met.

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Criterion 2 — Undue Hardship
Staff conclusion: Applicant met the criterion.
Refutation: The hardship is self‑created, which does not justify a variance.

a. Purchasing a business with a failed wastewater system is a risky and voluntary business decision.
The report documents that the applicant knew the system was shut down and that holding tanks were prohibited without a variance as early as June–July 2025 .

b. Financial hardship is not a valid basis for a variance

The staff report repeatedly cites the applicant’s need for cash flow, deposits, and operations. Financial considerations cannot substitute for compliance.

c. The SUP’s 153‑day operation requirement was waived by the Forest Service because of the failed wastewater treatment system. The Operating Plan says, “For the 2025/26 operating season and until the wastewater treatment system is fully operational, operations may not be open to the public for the minimum number of days.”

Conclusion: Criterion 2 is not met.

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Criterion 3 — No Feasible Compliant Alternatives
Staff conclusion: Applicant met the criterion.
Refutation: Staff’s analysis ignores the most obvious compliant alternative.

a. The Forest Service is already required to replace the lagoon system
The report confirms DEQ enforcement is underway and the Forest Service is obligated to install a compliant system .
This is a feasible, code‑compliant alternative.

b. “Not operating” is a legally valid alternative
The Health Code does not guarantee business continuity. If a system is unsafe or noncompliant, the alternative is to remain closed until compliance is achieved.

c. Staff report seems to equate “feasible” with “financially desirable”
The Board should not allow a variance simply because the compliant alternative is inconvenient or delays revenue.
Economic inconvenience or business preference does not constitute undue hardship.

Conclusion: Criterion 3 is not met.

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Criterion 4 — Minimum Necessary Deviation
Staff conclusion: Applicant met the criterion.
Refutation: A multi‑year holding‑tank operation is not a minimal deviation.

a. Holding tanks are explicitly prohibited because they are high‑risk and unsustainable
Staff’s own report explains why holding tanks are banned:
- prone to overflow
- expensive to maintain
- risk of illegal discharge
- at least one documented problem with a holding tank was identified in Missoula County

A two‑year commercial‑scale holding tank is a major deviation, not a minimal one.

b. The tank’s size, depth, and watertightness are unknown
Staff admits:
- conflicting information on tank volume
- conflicting evidence on groundwater intrusion
- historical documentation of leakage
- uncertainty about construction and compliance with DEQ 4

A variance cannot be “minimum necessary” when the basic facts about the tank are unknown.

Conclusion: Criterion 4 is not met.

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Criterion 5 — No Risk to Health, Water Quality, or the Environment
Staff conclusion: Applicant met the criterion.
Refutation: Staff’s own evidence contradicts this conclusion.

a. The tank has a documented history of groundwater intrusion
The report cites:
- 2005 documentation of groundwater entering the tank
- 2023 WGM memo noting “high water table potentially causing water to leak into the tank”

If groundwater can enter, wastewater can exit.
b. The tank does not meet DEQ 4 construction standards
Staff acknowledges the tank fails multiple DEQ 4 requirements and the applicant is seeking to vary from those standards as well.

A variance cannot be granted when the system is structurally noncompliant.

c. Staff relies on future leak tests to justify present approval
Leak tests need to be done. Existing infrastructure is very old and hasn't been in use since 2023. The applicant must demonstrate safety before approval, not after.

d. Chemical toilets are prohibited for permanent structures
Staff acknowledges chemical toilets are banned for exactly the reasons they are being proposed:
- maintenance failures
- leakage risk
- lack of permanence
Conclusion: Criterion 5 is not met.

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2. Staff’s recommendation contradicts the purpose of the Health Code

The Code prohibits holding tanks because they are unsafe, unreliable, and prone to failure. Staff’s own report reinforces these risks in detail.

Approving this variance would:
- undermine the prohibition
- set a precedent for commercial holding‑tank operations
- shift risk to the public and the watershed
- reward a business model built on noncompliance

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3. The staff recommendation relies on assumptions, not evidence

Throughout the report, staff uses conditional language:
- “as long as…”
- “if the tank is watertight…”
- “if pumping is adequate…”
- “if groundwater does not intrude…”
- “if the tank is large enough…”

A variance cannot be granted on the basis of future hopes or conditional safety.

The Code requires certainty—not speculation.

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4. Conclusion:

Because the application fails multiple mandatory criteria, the Board should not approve the variance.

The safest, most legally defensible path is to deny the variance and require the applicant to fully operate only after the Forest Service installs a compliant wastewater system.

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The public comment record already reflects the following concerns:

- Claims of 20 employees without evidence.
- Assertions of community economic harm without documentation.
- Marketing language implying exclusive private use of public land.

The Board must base its decision on verified facts.The proposed holding tank's true capacity is unknown, but would likely require frequent pumping (potentially daily). Extended reliance on a holding tank for a commercial, event‑oriented lodge is a substantial deviation from the Health Code’s intent and increases the likelihood of failure, transport spills, overflow, and operator error—especially given remote access. These operational risks are not minimal.

A holding tank is not the only option; it is simply the applicant’s preferred option. Preference is not a legal criterion.

Approving a variance that:

- shifts risk onto the public,
- allows a private business to operate on public land with a known failed system, and
- disregards the community’s repeated concerns
would erode trust in the regulatory process.

The community should not bear the environmental and safety risks created by a private entity’s business decisions.

Thank you for the opportunity to comment and for your consideration of this important issue. While I wish to see the Lodge reopen, it must be done with certainty and in full compliance with all regulations. I urge you not to approve this variance without further information and a more comprehensive evaluation.

"Extraordinary Conditions- The sewage lagoon is USFS-owned; Holland Lake Lodge cannot repair or replace it.- The USFS directed the Lodge to operate with daily pumping until lagoon restoration.- Closure would cause major economic harm to employees and the Swan Valley community.- Daily pumping prevents any risk of wastewater discharge to the environment."
This doesn't seem honest, the condition of the wastewater system was well known by the new buyers.

"Demonstration of Undue Hardship Without this variance, Holland Lake Lodge would be forced to close indefinitely, resulting in loss of employment for up to 20 staff members, loss of tourism revenue, and economic harm to Missoula County. There is no feasible wastewater alternative available."
This also doesn't seem honest, the GM R Ramsey was let go recently by the owner and who are these 20 staff that have lost employment. Are these local individuals? I have not heard of anyone being hired on by HHL beyond R Ramsey.

Public land and the water quality in this area needs to be protected.

The email that was sent out and the website also says, “With full property exclusivity, your celebration unfolds without interruptions, timelines, or strangers. Just you, your people, and a place that feels entirely your own. It’s not just a wedding weekend; it’s a once-in-a-lifetime takeover.” This is PUBLIC LAND, exclusivity is not a option here.

Due to the misleading information in this application and the fact I do not believe they meet the "hardship" requirements I respectfully ask you deny this variance.

Please grant the variance. It is clearly not there fault the forest service hasn’t got the lagoon fixed yet. This is one of the staples of our community and state, they have been working with the community and local government to ensure that Montanans are informed all along the way. Providing proof of thier willingness to ensure public health and safety will be considered in every endeavor. Let them open there business. Thank you

This is a comment about wastewater variance for Holland lake lodge.
If there are time limits the on how long the tanks can be used. The USSF
Has the responsibly for getting the wastewater system up to date and working to keep the nitrogen & Phosphorous out are water in holland lake.
The tanks should only be considered a short term fix not forever.
G Lazarowski
5448 Hwy 83 N
Conden MT

Public Comment Opposing Wastewater Variance for Holland Lake Lodge

I respectfully urge the Missoula City-County Board of Health to deny the requested wastewater variance for Holland Lake Lodge (HLL). The application fails to meet the mandatory criteria required for granting a variance and raises significant concerns related to public health, environmental protection, and compliance with existing permits and regulations.

Failure to Meet Variance Criteria

The Board may approve a variance only if ALL criteria are met. In this case, they are not.

1. No Extraordinary Conditions That Could Not Have Been Reasonably Prevented

The applicant was fully aware at the time of purchase that the wastewater lagoon was inoperable, managed by the USFS, and subject to a lengthy repair timeline. These conditions were known and foreseeable. The applicant could have reasonably prevented the need for a variance by delaying the purchase until the wastewater system was repaired or by planning operations consistent with those limitations. Known, pre-existing conditions do not constitute “extraordinary circumstances.”

2. No Undue Hardship Caused by Denial of the Variance

Any hardship asserted by the applicant was present prior to and at the time of purchase, and was well-known. The onus for adjusting to the timeframe required for the USFS to install a new wastewater system, which the operator was well aware of at the time of purchase, is solely on the operator.

In addition, the claimed hardship is tied to a business model that includes large, exclusive events of up to 200 people, which are not authorized under the Forest Service Special Use Permit. The inability to conduct unauthorized activities does not constitute undue hardship. According to HLL’s 11-25-25 Resubmittal, “The business model was reliant upon taking non-refundable event deposits and regular cash flow based upon projected opening dates. Without a projected opening date, and guaranteed cash flow, ownership does not feel comfortable continuing to invest in repairs and restoration and moving forward in hiring a team for operations. Without a projected opening date, none of these things are possible.” This is clearly a flawed business model considering the known circumstances.

“Since closing the transaction in July 2025, not having the ability to use water or toilets within the buildings has already caused hardship and added, unbudgeted expense.” There is no reason this expense should not have been budgeted. This was a known issue prior to purchase, not something that unexpectedly came up. Furthermore, it was the operator’s responsibility to conduct all due diligence with the County PRIOR to purchase. And even furthermore, has Holland Lake Lodge budgeted for pumping the holding tanks multiple times a week up to daily?

Additionally, in addressing undue hardship, Holland Lake Lodge states: “Without this variance, Holland Lake Lodge would be forced to close indefinitely, resulting in loss of employment for up to 20 staff members, loss of tourism revenue, and economic harm to Missoula County” and that “Closure would cause major economic harm to employees and the Swan Valley community.” The fact is, the lodge has been closed and its future has been uncertain for years. Any “major economic harm”, “loss of tourism revenue”, or “economic harm to Missoula County” would have already occurred. We have all been surviving without the lodge since it closed in 2023. Prior to that, the Lodge provided only seasonal employment for a limited number of employees. Holland Lake Lodge is hardly a huge economic driver for Missoula County. And even ownership has made several public statements describing the acquisition as a sentimental legacy purchase, not one necessary for the owner’s financial survival.

Lastly, in Variance Resubmittal 12-2025 the USFS references the 153 minimal days of operation requirement specified in the Special Use Permit. “Failure of the holder to exercise this minimum use may result in revocation of this permit under clause VII.A.” The USFS cites HLL’s inability to meet this requirement as an “undue hardship”. However, the Lodge has not met this requirement in years, certainly not in 2023 or 2024 while transitioning ownership of the lodge, and not even under previous ownership in the years immediately preceding, and yet, the permit has continued to remain in effect and was approved again, in May, 2025, for new ownership. A slide from a presentation that HLL owner Eric Jacobsen made on February 10, 2026 at the Seeley Lake Community Council meeting further shows that the lodge has historically only been open approximately 3 months annually. (File attached in email sent directly to the Environmental Health Director).

So the USFS has not been upholding and enforcing the permit for years, but is now trying to claim it is an “undue hardship” when the permit requirements can not be met? Because of their own failed system? Because they put the cart before the horse in approving a permit that could not possibly be adhered to? Are they going to start enforcing the Non-Exclusive Use and Interference with Public Use Clauses too? Because they have been notified of numerous violations since Mr. Jacobsen assumed ownership in July, 2025 and they haven’t done a thing. The bottom line is, the failed wastewater system was well known prior to the USFS’s approval of the permit in May, 2025 (as referenced here: USFS Holland Lake Lodge FAQs - link emailed directly to the Environment Health Director) and it was known at that time that it would be impossible for HLL to comply with this minimum operating requirement. The Special Use Permit should have never been approved under these circumstances in the first place, and if the permit holder can not meet the terms of the Special Use Permit, the USFS is obligated to revoke it. Missoula County is NOT obligated to provide a variance.

3. Reasonable Alternatives Do Exist

Reasonable alternatives were and still are available:

Mr. Jacobsen could have waited to purchase the lodge until the wastewater system was repaired, and was advised to do so. He was well aware that the system was inoperable, that its repair was costly and not guaranteed, and that any timeline for repair would be a long one.

Holland Lake Lodge could operate at a reduced scale consistent with or less than historical use and permit limits.

Holland Lake Lodge could and should defer large-scale events entirely. They claim on their website and on social media to be starting out with 200 person events in 2026, with packages for both weekdays and weekends, and that they will open to the general public in 2027, which, even if allowable under the permit, seems backwards. Why not start small and non-committal, especially given the wastewater issues? Because they think the work-around is bringing in food trucks and chemical toilets? Neither of which is authorized in the SUP? The applicant chose to proceed with a high-intensity business plan that moves far beyond previous use, and that isn’t even authorized in the Special Use Permit. Nor is it in line with their correspondence to the county. Nor does it make sense for the public to support it or pay one cent for it when Holland Lake Lodge has made it clear that they fully intend to violate the permit’s Non-Exclusive Use and Interference with Public Use clauses by promising “full property exclusivity” on their website: “With full property exclusivity, your celebration unfolds without interruptions, timelines, or strangers. Just you, your people, and a place that feels entirely your own. It’s not just a wedding weekend; it’s a once-in-a-lifetime takeover.” This is PUBLIC land.

4. The Requested Variance Exceeds the Minimum Necessary

The variance request far exceeds what would be minimally necessary to operate the lodge to the requirements and terms of the Special Use Permit.

According to HLL Variance Resubmittal 11-25: “Once we are open, we hope to operate at full capacity for lodging and dining, which will drive the retail and rental business. That capacity is up to 50 overnight guests and up to 350 meals served in the restaurant. The intention is to begin by opening the lodge rooms, restaurant and bar, and add the cabins as they are repaired and updated. The resort is small, and so it is important to maximize the business and be open to full capacity as soon as possible in order to remain operational and to invest in the repairs and restoration needed on this 100-year-old historic resort.”
This isn’t the use and capacity currently stated on HLL’s social media and website: A February 6, 2026 post on Instagram: (File emailed directly to the Environmental Health Director)

A screenshot taken from HLL’s website on 2/8/26: see hollandlakelodge.com/weddings (File emailed directly to the Environmental Health Director)

The applicant’s representations are inconsistent. Statements to Missoula County emphasize small-scale lodging and dining operations, while current public advertising focuses on large private events for up to 200 people, apparently up to every day of the week according to their website, and explicitly excluding the general public from access to public lands. The requested use also doesn’t align with the Special Use Permit, which limits both the type and scale of operations. A variance cannot be approved without an honest picture of intended usage that fully complies with the Special Use Permit. Does HLL plan to operate for the minimum 153 days or for 365 days a year or somewhere in between? Are they planning to serve 350 meals a day? A week? In considering this variance request, these details… spelled out truthfully… matter.

Impact on Public Taxpayers and Environmental Health

According to the Project Description, the “Missoula City-County Health Code prohibits the use of holding tanks because they are an expensive way to manage wastewater, especially on a long-term basis” and “holding tanks require a lot of attention and monitoring to ensure wastewater doesn’t overflow onto the ground or back up into buildings.” This raises some critical questions:

Who is responsible for daily monitoring, oversight, and enforcement?

At what frequency will inspections occur?

Who bears this financial burden — the operator or taxpayers?

What is the emergency plan if tanks are full and pumping cannot occur due to weather, access, or equipment failure? HLL's “contingency plan” for when the tanks inevitably hit capacity calls for the use of chemical toilets… which requires an ADDITIONAL variance. Chemical toilets are typically only permitted for "one off" events... not multiple weddings/events a week. Holland Lake Lodge is asking for a variance on top of a variance, an exception upon an exception. This is NOT how we protect public health and the environment.

Granting this variance would expose drinking water supplies, Holland Lake, and the surrounding environment to unnecessary risk. Holland Lake Lodge and the USFS have a history of violating the Montana Water Quality Act and Public Water Supply Laws. (See DEQ letter dated October 17, 2023) RE: discharge without a permit and unapproved alteration at the Holland Lake Wastewater Treatment Ponds CVID #24989. The rural, forested location increases the likelihood of access by wildlife, rodents, and insects. Preventing nuisance conditions, contamination, or public health hazards would require extensive, ongoing, County oversight, at great expense to taxpayers. Holland Lake Lodge and the USFS have already attempted to fix a liner with duct tape, while failing to report it and failing to conduct follow up testing on it… can we really trust them to diligently care for the system now? Or is it in the best interest of both public health and the environment to simply put a further pause on all operations by denying a variance. What does the public and the environment stand to gain from this variance? And what do we stand to lose?

Conclusion

This variance application does not meet the legal threshold for approval. The conditions were known, the hardship is self-imposed, reasonable alternatives exist, and the request exceeds the minimum necessary while posing ongoing public health and environmental risks.

For these reasons, I respectfully request that the Missoula City-County Board of Health deny the wastewater variance for Holland Lake Lodge.

Thank you for your careful consideration and for upholding the standards that protect public health, state waters, and the public interest.

Deny the variance. The seller and second buyer knew that the sewage lagoon wasn't operational yet closed on the sale. It's not Missoula County's burden to grant a variance for tank pumping for a business that will generate a lot of waste near an alpine lake that is the threatened bull trout's critical habitat. Holland Lake Lodge should be pressuring the Forest Service to provide a functioning sewage treatment facility.

The requested variance does not meet the County's criteria. There is no extraordinary circumstance since Mr. Jacobson purchased the lodge knowing there was no sewage treatment so there is no undue hardship that was not foreseeable. Holland Lake Lodge cannot guarantee that using holding tanks for sewage will not contaminate Holland Lake or the groundwater with hundreds of lodge guests flushing toilets/showering, a restaurant and bar operating, and people living on site.

I understand the owners wanting a temporary fix to their problem; however I am very opposed to this variance! Pollution is a huge problem and we must protect this pristine area at all cost! It is fragile and we must protect it! Thank you ! Marcia Tapp Condon

Please issue the variance requested so this family-run hospitality business can be re-opened and rebuilt.

Holding the new ownership team accountable for the US Forest Service's faults in maintaining and delays in repairing the existent septic system appears to be the requirement the "extraordinary conditions" requirement needed for the issuance of the variance. The fact that the new owners are willing and able to bear the additional operating costs of pumping the holding tank until such time as the Forest Service completes the necessary repairs shows a commitment to reopening the business.

The Swan Valley needs a vibrant tourism sector as a component of a viable economic plan for the Valley given the drastic changes in the regional timber industry with the transfer of Plum Creek forests to USFS via the Montana Legacy Project and the closing of the Pyramid Mountain Lumber mill in Seeley. We have a private entrepreneur prepared to invest to meet the deferred maintenance and operating costs necessary to reopen Holland Lake Lodge.

The County should grant the variance, diligently oversee the use of the holding tank to assure the terms of the variance are met and no leakage or contamination occurs while also continuing to pressure the USFS to fix the underlying issues.

Jon Simon

Grant the variance. Not there fault the forest service hasn’t got the lagoon fixed. Let them open and be a business.

The map shown for the project in question is incorrect and shows a larger area than included in the SUP for the project in consideration.

I strongly oppose this variance! Why the variance request fails completely on its face:

1. A prior application for a Special Use Permit by POWDR exposed substantial issues with Forest Service management and lack of oversight. Due to public pressure, this application was withdrawn.

2. The initial failure of the Forest Service lagoon was documented on 6/1/2022. This was illegally repaired without a permit on 7/22/2022.

3. The new owner of Holland Lake Lodge had full exposure to all public information revealed during the last purchase and permit application event, including the lack of a Forest Service plan to properly address the sewage treatment lagoon, yet still chose to proceed with purchase knowing full well that the resort could not function under these conditions. There was every opportunity to perform due diligence and suggesting that the forest service told them pumping was okay is NOT an excuse for a hardship claim This specifically eliminates the argument claiming "hardship" (1. The variance is necessary to address extraordinary conditions that the applicant could not have reasonably prevented;). Note: It's important to contrast this with a situation where a hardship claim would be valid: For instance, they purchased the improvements on the leased public lands with a functional septic system managed by the forest service, but then it failed one year later and it was going to reasonably take 2 years to redesign and implement a new system. The current situation is the polar opposite of this!!

4. The claim of economic loss for 20 employees that don’t currently exist, does not add to any claimed hardship.

5. Additional criteria are required for a variance from Regulation 1. The Board may approve
a variance from Regulation 1 only if it finds, in addition to all the elements in 6(E)(1)-(4) above, that granting the variance will not:

a. Contaminate any actual or potential drinking water supply; Note: It is critical to note that there's past evidence of ground water leaking into the holding tank, and the properties water supply well is in close proximity to the holding tank.

e. Pollute or contaminate state waters in violation of § 75-5-605, MCA; Note: It's important to note that the ground water level is extremely high in this area and it borders a lake that is a critical habitat for a variety of threatened species.

g. Cause a nuisance due to odor, unsightly appearance, or other aesthetic consideration. Note: It's important to note that this holding tank and the corresponding daily, or multiple times per day, pumping activity is co-located directly in front of Cabin #2 and the main driveway entrance to the lodge, restaurant, and bar. The daily, or multiple times per day, trips of a septic tanking truck are likely to cause damage to the dirt road from the highway to the lake, and disrupt the adjacent campground and trailhead activities.

6. History of noncompliance by Forest Service, prior and current permittees:

a. Missoula County needs to thoroughly review the long list of past failures of the forest service to maintain their septic system, provide oversight of permit holders, and follow federal, state, and local regulations. Structures were built without proper permitting, wells interconnected for public water supplies without DEQ approval or testing for PWS. I see NO new permits to address significant safety hazards that were evident on the property prior to the new owner taking control. Many comments were made during the permit application by the new owner and summarily dismissed by the Forest Service. Here’s a relevant example of those comments: https://drive.google.com/file/d/1LVYJaCl2ZUoRE0VRSOrwNepY4Aa0Nv8U/view?usp=drive_link

b. It’s important to note that HLL is currently delinquent on their 2025 taxes while requesting this variance!

c. Tank capacity of between 4000-5000 gallons, multiple different estimates for the capacity are present in documentation, insufficient for current business plan:

Key assumptions
• Wedding guests (200): on-site several hours, using toilets, handwashing, plus food + bar service.
I’ll use (20–30\ \text{gal/person}) for the event day (includes restroom + restaurant/bar use).
• Overnight guests (50 in cabins): more like residential use.
I’ll use (50\ \text{gal/person/day}) (toilet, shower, sinks).
• Employees (20): full shift with restroom + some handwashing.
I’ll use (15\ \text{gal/employee/day}) as a reasonable planning number.
These are conservative but not crazy—good for sizing tanks or checking septic/utility capacity.

________________________________________
1. Wedding event guests (200 people)
Low estimate:
[ 200 \times 20 = 4{,}000\ \text{gal} ]
High estimate:
[ 200 \times 30 = 6{,}000\ \text{gal} ]
Event guests:
≈ 4,000–6,000 gallons for the wedding day (including restaurant + bar use).
________________________________________
2. Overnight cabin guests (50 people)
[ 50 \times 50 = 2{,}500\ \text{gal} ]
Overnight cabins:
≈ 2,500 gallons for one night.
________________________________________

3. Employees (20 people)
[ 20 \times 15 = 300\ \text{gal} ]
Employees:
≈ 300 gallons for the day.
________________________________________
4. Total estimated wastewater
Low total:
[ 4{,}000\ (\text{event}) + 2{,}500\ (\text{overnight}) + 300\ (\text{employees}) = 6{,}800\ \text{gal} ]
High total:
[ 6{,}000 + 2{,}500 + 300 = 8{,}800\ \text{gal} ]
Planning range:
👉 Roughly 6,800–8,800 gallons of wastewater for:
• 200-person wedding event
• 50 overnight guests in cabins (one night)
• 20 employees
• Fully operating restaurant and bar serving that event