Appendix D of the May 2024 Water Quality Management Plan - LDR Recommendations

jzung Nov 16 2025 at 8:16PM on page 4

Agree with Phil's comment about what is "feasible". needs a more concrete definition. Mostly commonly this is defined as a certain distance from existing system (ie 300-ft).

jzung Nov 16 2025 at 8:14PM on page 6

increase area required for on-site for snow storage to 15-25% of the plowed area. The current requirement of 2.5% is much too small per our observations and feedback from the snow haulers. 25% is the most common % used in similar communities. We observed 15-20% used on parking lots during winter 2024-25.

jzung Nov 16 2025 at 8:10PM on page 6

this is already in the LDRs but lacks oversight

jzung Nov 16 2025 at 8:07PM on page 6

shall not drain directly into water bodies without treatment. Unless all snowmelt and runoff is being infiltrated or evaporated, all sites will drain to a water body eventually.

jzung Nov 16 2025 at 8:03PM on page 6

if snow is being stored on site

LBeckworth Nov 14 2025 at 6:08PM on page 6

Suggestion

Developement regulations and/or design standards should consider pooling or ponding that may occur as a result of retaining stormwater and the impacts on breeding habitat of disease-vectors (i.e. mosquitoes). Well maintained stormwater systems and/or complete habitats that include appropriate vegetation and natural predators should reduce mosquito breeding.

LBeckworth Nov 14 2025 at 5:58PM on page 4

Question

TC LDRs define livestock as "horses, mules..., rabbits, llamas, cattle, swine, sheep, goats, poultry, or other animals generally used for food or in the production of food or fiber, working animals and guard animals actively engaged in the protection or management of
livestock."

Would "livestock pens" include pens for all of those animals?

LBeckworth Nov 14 2025 at 5:43PM on page 4

Suggestion

Agree with other comments, "hazardous materials" needs to be clearly defined. Some common herbicides and insecticides, frequently used in "commercial grade" formulations, are included under the EPA Hazardous Wastes P and U Lists.

Shannon Brennan Nov 14 2025 at 3:47PM on page 3

Thank you for the opportunity to comment. Clearly you all have put a lot of thought into this important document, as shown by these proposed amendments. Great work! Shannon Brennan

Shannon Brennan Nov 14 2025 at 3:44PM on page 8

Recommend eliminating the rules that RV dumping to a septic is prohibited; this may be unrealistic, as in many cases, this may be the only option.

Shannon Brennan Nov 14 2025 at 3:42PM on page 8

Recommend identifying what constitutes a commercial campground, as private homeowners sometimes offer multiple sites, ostensibly privately to the public for a price (think HipCamp). These operations should also be covered under these regulations.

Shannon Brennan Nov 14 2025 at 3:38PM on page 8

Suggest no de minimus for the number of RVs in a commercial RV resort (vacation travel) before some type of waste removal is required. Options are the RV park design could incorporate individual RV unit direct disposal to sewer system or shared underground collection system, could host a single septic dump onsite, or could offer individual haul-off service for a price. Recommend not allowing any RV park to engage in business without some type of waste service (unlike older parks where sometimes there are no options).

Shannon Brennan Nov 14 2025 at 3:31PM on page 7

Question

Is there grandfathering for this requirement? Also, what about replacement of fencing - can it be original (replacement) design or does it have to be wildlife friendly? Do we need to specify height restrictions, materials of construction, as well?

Shannon Brennan Nov 14 2025 at 3:28PM on page 7

See earlier comments about water rights and manmade ponds

Shannon Brennan Nov 14 2025 at 3:22PM on page 5

See comments above regarding storage of hazardous and toxic materials.

Shannon Brennan Nov 14 2025 at 3:21PM on page 5

See comments in section above realtive to failing SWFs.

Shannon Brennan Nov 14 2025 at 3:20PM on page 4

See comments in section above regarding manmade water bodies.

Shannon Brennan Nov 14 2025 at 3:19PM on page 4

Recommend adding "toxic" substances, as well. Also, I agree that EPA covers this, but Teton County can be more conservative if it chooses.

Shannon Brennan Nov 14 2025 at 3:17PM on page 4

Suggestion

Include a timeframe when this should be accomplished.

Shannon Brennan Nov 14 2025 at 3:14PM on page 4

I agree that in Teton County, no new manmade water bodies should be allowed without a specific larger public beneficial use. However, this should be a policy, not a regulation, ordinance, or rule. I would like to see this rule removed from the amendments. [Background: Although water is plentiful in the County, water rights must be considered. To promulgate rules for creation of water bodies (or allow by indifference) is de facto to authorize use of water that may already be reserved (or water that the county or state may want to hold in reservation for the future).]

Shannon Brennan Nov 14 2025 at 3:07PM on page 4

Suggestion

Recommend that this be tightened to an actual schedule or triggered by an anticipated major new build, i.e large hotel or convention facility. Scheduled updates should be included in budgets.

Shannon Brennan Nov 14 2025 at 3:05PM on page 4

Not sure if this should be limited to PGs. Not all PGs have hydrology or geohydrology background. Also, concerns exist that this may be limiting in that many PGs are discerning about the work they do, based on professional liability. This requirement may be too restrictive, especially here in WY.

Amy Kuszak Nov 14 2025 at 1:24PM on page 8

Question

Are inhabited RVs currently permitted in off street parking locations? Is this addition necessary?

Amy Kuszak Nov 14 2025 at 1:21PM on page 7

I agree with this concept but is there a better way to measure the amount of non-native groundcover allowed? Possibly based on a percent of the size of a structure? Otherwise a very large, sprawling development would maintain a very large area of non-native landscape, requiring large quantities of irrigation.

Amy Kuszak Nov 14 2025 at 1:17PM on page 7

Agricultural landowners should be consulted prior to implementing this recommendation. Instead of blanket exemptions - some compromise to protect water quality while maintaining the ability to continue agricultural operations is needed.

Amy Kuszak Nov 14 2025 at 1:07PM on page 7

I do not agree with a complete prohibition of terrain disturbance in the buffer for wildlife habitat enhancement - this would prohibit restoration of riparian habitats. However, we do need more stringent standards for what constitutes habitat enhancement.

Amy Kuszak Nov 14 2025 at 1:04PM on page 7

Strongly support this recommendation. Agricultural ponds should be included in this prohibition.

Amy Kuszak Nov 14 2025 at 1:02PM on page 6

Agree, this is an important addition.

Amy Kuszak Nov 14 2025 at 1:01PM on page 6

Agree, this is an important addition.

Amy Kuszak Nov 14 2025 at 12:54PM on page 6

Snow storage setbacks should be consistent with existing LDR setback requirements.

Amy Kuszak Nov 14 2025 at 12:31PM on page 5

Yes, this change makes sense.

Amy Kuszak Nov 14 2025 at 12:30PM on page 5

Yes, agree.

Amy Kuszak Nov 14 2025 at 12:27PM on page 4

Agree.

Amy Kuszak Nov 14 2025 at 12:19PM on page 4

Agree - countywide requirement.

Amy Kuszak Nov 14 2025 at 12:19PM on page 4

Agree - countywide requirement.

Amy Kuszak Nov 14 2025 at 12:18PM on page 4

No CAFOs - strongly agree - countywide.

Amy Kuszak Nov 14 2025 at 12:17PM on page 4

I agree that livestock should be fenced out of waterbodies for protection of water quality and this should be a countywide requirement.
However, I think that our large agricultural landowners should be consulted about how this may or may not work. Adjustments to this prohibition for large agricultural operations may be necessary to maintain our agricultural lands.

Amy Kuszak Nov 14 2025 at 12:01PM on page 4

The following comment applies to all areas of the county, it is not limited to Area 1. Teton County is the source of surface and groundwater for many downstream communities. For the purpose of protecting water quantity and quality, water use for over-consumptive and aesthetic purposes inherent to ponds should be prohibited. Specific concerns include:
- Ponds require continuous refilling due to evaporation and seepage - unnecessary consumptive use.
-Minimal ecological value. Most constructed ponds do not function as healthy or sustainable ecological systems.
- Even in closed systems there are issues with liners. Plastic liners degrade, crack, and leak over time. Clay liners can contain heavy metals and also risk seepage. Chemical leaching from liners can degrade water quality and harm aquatic wildlife. Temperature fluctuations (which Teton County has not only seasonally but also daily) increase the likelihood of liner failure.

Amy Kuszak Nov 14 2025 at 11:42AM on page 3

Suggestion

Although basements are not addressed in the WQMP LDR recommendations, I think basement prohibitions should apply in the identified Groundwater Protection Areas and should be limited elsewhere in the county. Excavation below grade increases the potential for groundwater interception, infiltration issues, and contamination. Restricting basements in sensitive areas is a prudent and necessary step.

PHILIPGYR Nov 14 2025 at 9:47AM on page 6

Question

What is the scientific rationale behind this? Is it proven that plowed snow is a source of water quality degradation in Teton County?

PHILIPGYR Nov 14 2025 at 9:44AM on page 4

Suggestion

Feasible is a very loose term. Can a line be bored under the Snake River for millions of dollars? Yes. Instance where a property is very close to an existing sewer but a neighboring property owner would need to grant an easement? This entire section is not enforceable in a practical sense.

PHILIPGYR Nov 14 2025 at 9:41AM on page 4

Suggestion

The definition of manmade waterbody is overly broad and needs to be specific. Are manmade wetlands included? Ditches and watercourses constructed in association with critical access?

Sefan Fodor Nov 10 2025 at 4:59PM on page 7

Again, dont let a firm like Tryhydro do away with the ag Exemption. Ag producers are the last protectors of open spaces. Keep this up and you will get more divisions of land into 35 acres or family subdivisons. Stop this assault on ag properties.

Sefan Fodor Nov 10 2025 at 4:58PM on page 7

We should not have to justify to the County Engineer if there is a need for flood control. If someone needs a DEQ or ACE permit, they should not have to get the blessing of the County Engineer to protect their property.

Sefan Fodor Nov 10 2025 at 4:57PM on page 7

So now we dont want to allow wildlife enhancement. These suggestions defy logic.

Sefan Fodor Nov 10 2025 at 4:57PM on page 7

Again, no justification for this prohibition. Is a habitat pond really a bad thing, or a fire supression pond?

Sefan Fodor Nov 10 2025 at 4:56PM on page 6

Snow melts, as long as its not flowing across property lines, Teton County should not be regulating it. Enough with the permits.

Sefan Fodor Nov 10 2025 at 4:55PM on page 6

How many employees will be required to regulate this? What if, just spitballing here, Teton County makes it so time consuming and expensive to store snow in Teton County that someone hauls it to Sublette or Lincoln. Then someone cannot comply with this onerous regulation. Stop regulating every aspect of life in Teton County. The LDRS are already 643 pages. That is quite enough.

Sefan Fodor Nov 10 2025 at 4:54PM on page 6

This suggestion is poorly written. it is not feasible to remove all snow stored.

Warning message

Appendix D of the May 2024 Water Quality Management Plan - LDR Recommendations

Comments

Warning message

Appendix D of the May 2024 Water Quality Management Plan - LDR Recommendations

Comments

Log in to Add Comments