04/01/2026
The link to submit your public comments to the Flathead National Forest is in the comments below. We are unsure of the actual deadline for comments, so please submit today if possible. The following letter, submitted by Jen Nave of Polson, provides a nice framework of the current issues and concerns. Thanks Jen!
“I submit the following comments in opposition to the proposed Holland Lake wastewater system reconstruction project.
Based on available information, the proposed action would increase system capacity from approximately 350,000 gallons to 1.55 million gallons… a fivefold expansion. At the same time, no expansion of the adjacent public campground is proposed. This indicates that the primary purpose and effect of the project is to support increased private, commercial use at Holland Lake Lodge, rather than to serve the recreating public.
Under the National Environmental Policy Act (NEPA), federal agencies are required to take a “hard look” at the environmental and social impacts of proposed actions, including indirect and cumulative effects, and to rigorously explore reasonable alternatives. The current proposal appears to rely on a categorical exclusion (CE). However, the scale of the capacity increase, the associated construction impacts, and the likelihood of inducing expanded private use raise serious questions as to whether a CE is appropriate in this case.
Specifically:
1. Improper Segmentation and Connected Actions
The proposed wastewater expansion appears to be a connected action to foreseeable increases in lodge use intensity, including large-scale private events. NEPA prohibits segmentation of projects to avoid full environmental review. The Forest Service must analyze the wastewater system expansion together with the reasonably foreseeable increase in commercial use it is designed to support.
2. Indirect and Cumulative Impacts
The proposal fails to adequately address indirect effects, including increased traffic, noise, reduced public access, and intensification of private use on public land. Cumulative impacts must also be considered, particularly in light of prior proposals to expand lodge operations and ongoing pressures on recreation resources in the Swan Valley.
3. Extraordinary Circumstances
The use of a categorical exclusion is inappropriate where extraordinary circumstances exist. Potential impacts to recreation experience, public access, water quality, and the character of the area warrant a higher level of review, such as an Environmental Assessment (EA) or Environmental Impact Statement (EIS).
4. Purpose and Need Statement
The apparent purpose and need for the project is improperly defined. A fivefold increase in wastewater capacity, absent any expansion of public facilities, suggests the true purpose is to accommodate expanded private commercial operations. NEPA requires that the purpose and need not be so narrowly defined as to predetermine the outcome.
5. Reasonable Alternatives
A reasonable alternative, repairing or replacing the existing system at or near its original design capacity, has not been meaningfully analyzed. This alternative would meet current needs, reduce cost and environmental impact, and better align with public use objectives.
6. Fiscal Responsibility and Public Benefit
While the Forest Service refuses to share the cost of this project with taxpayers, making meaningful comment difficult, we can estimate that it will cost at least $3–5 million. The Forest Service must justify how this expenditure primarily benefits the public, rather than subsidizing private profit on public land.
7. Construction and Site Impacts
The scale of construction, including substantial fill and heavy truck traffic, will adversely affect nearby campground and recreational users through noise, dust, odor, and visual impacts. These effects must be fully analyzed and disclosed.
8. Impacts on Wildlife
A lagoon of this size will surely serve as an attractant for grizzly bears, black bears, and other wildlife. These effects must be fully analyzed and disclosed.
Given these concerns, I respectfully request that the Forest Service:
• Withdraw the categorical exclusion determination
• Prepare a full Environmental Assessment or Environmental Impact Statement
• Analyze the wastewater proposal in conjunction with reasonably foreseeable increases in lodge use
• Fully evaluate a reduced-capacity alternative
• Ensure that any final decision prioritizes public access and benefit
• Public lands are held in trust for all Americans. Infrastructure investments should reflect that responsibility.
Thank you for the opportunity to comment.”