Response: As shown on the attached exhibits, the property is adjacent to US Hwy 89 R/W and is located between five and eight miles east/southeast of the City of Great Falls corporate limits, and traffic to/from the site will be via US 89 approximately 3.5 miles east of the Stockett Rd intersection.

The average daily traffic (ADT) near the site as measured in 2017 is 4342 vehicles per day. This count was measured on US Hwy 89, east of the Stockett Rd intersection. The traffic volume drops slightly to 4118 (2017 ADT) just west of Belt. The dairy processing facility is estimated to generate additional traffic as follows:

- Milk, liquid whey, delivery trucks, etc.: average seven (7) vehicle trips per day

- Staffing/employees: average eleven (10) vehicle trips per day

- Retail customers: average thirty (35) vehicle trips per day

The development is anticipated to generate an added 52 vehicle trips per day, a one-percent increase over the current ADT.

Peak daily traffic impacts are expected to occur just prior to and after work shifts, generating approximately ten (10) additional vehicle trips between 6:30 and 7:00 a.m. and again between 4:00 and 5:00 p.m. The majority of vehicles will likely be entering from the west and exiting to the west.

The Montana Department of Transportation will require an approach permit to connect the access roads to Hwy 89 and may require a traffic impact study (TIS) for the purpose of identifying any/all requirements for mitigating traffic impacts, including dedicated turn lanes at the proposed project approach, or the use of other mitigating measures as may be required by the review authority (Montana Department of Transportation). The TIS will be completed by a Montana-licensed professional engineer with the appropriate qualifications and experience.

If any improvements to Hwy 89 are required as a result of the TIS (turning lanes, signalization, etc.), MFP will be responsible for the cost of such improvements.

The Cascade County Zoning Regulations permit a wide range of uses in the Agricultural Zoning District, including many that generate significant amounts of traffic such as campgrounds and recreational vehicle parks, commercial dairies, power plants, and community centers. Additionally, an even wider variety of land uses which generate significant levels of traffic are allowed via a special use permit, including quarries, veterinary clinics, mobile home parks, equipment rental and sales facilities, hospitals, and many others. Therefore, the Zoning Regulations anticipate and accommodate land uses generating traffic.

The MFP facility will create an additional amount of traffic that can easily be handled by Hwy 89 without affecting its level of service. Turning movements in and out of the facility onto Hwy 89 may require some improvements to Hwy 89 consistent with development of this nature. MFP is prepared to make such improvements as may be required by the Montana Department of Transportation. The amount of traffic generated by the MFP is consistent with both permitted land uses and those allowed and anticipated by the zoning regulations and will not have a material, negative effect on traffic conditions.

Response: The dairy processing facility will be served by onsite water and wastewater facilities. Wastewater treatment will be completed onsite using Montana DEQ-approved wastewater treatment system(s). Commonly practiced treatment technologies will be used for managing both domestic and industrial waste streams, and beneficial reuse of treated effluent will be performed in a manner that is compliant with DEQ and local government regulations. The overall volume of industrial wastewater generated as generated from dairy operations is estimated to be approximately 13,000 gallons per day (gpd). With the 5 day/week operation, this will result in approximately 339,000 gallons of industrial wastewater each year. The industrial wastewater will be pretreated using nutrient reduction/removal technologies, then treated/stored in a facultative pond system, followed by land application of treated effluent on approximately 10-15 acres of cropland, either onsite or on adjacent farmland.

All liquid whey will be stored onsite until it can be hauled away and used as feed by area ranchers. The total liquid whey production is estimated at approximately 9,720 gpd.

Domestic wastewater generation is expected to be the equivalent of approximately a single residence, or less than 300 gpd. Domestic wastewater will be treated and disposed via a conventional septic tank and drainfield, all in strict compliance with DEQ and local standards and regulations.

Water for the dairy operations, fire flows and domestic usage will be supplied to the dairy via onsite wells, a series of transmission mains and storage tanks.

The water and wastewater systems for the site must be reviewed and approved by the Montana DEQ. Fire protection will be provided via onsite storage tanks and booster pumps.

Natural gas service to the property will be provided via Energy West and electrical service will be provided by NorthWestern Energy. Telecommunications will likely be provided by Charter or CenturyLink through new service lines to the proposed development. The MFP principals are also considering the use of wind turbines and solar farms for the generation of supplemental electrical power and are also considering a system for the possible capture and reuse of methane gas.   

Response: Construction and development of the dairy processing facility will include the construction of access roads, dairy processing buildings, parking lots, wastewater treatment and disposal facilities, and related items. This construction is consistent with permitted land uses in the Agricultural Zoning District. In the short-term, during construction, there will be an increased possibility of soil erosion and stormwater run-off consistent with typical construction activities. Traditional erosion and sediment control best management practices (BMPs) will be utilized during construction which will include but are not limited to silt fences, straw waddles, and storm water detention and retention ponds.

As the site disturbance will be over 1 acre, a DEQ “General Permit for Storm Water Discharges Associated with Construction Activity” permit will be required and will address and mitigate soil erosion and sedimentation during construction. This permitting process will involve the submission of a Notice of Intent (NOI) and Storm Water Pollution Prevention Plan (SWPPP) to DEQ. Additionally, the SWPPP will need to be updated and maintained throughout the course of the project. Upon completion of work and after final site stabilization has been completed, a Notice of Termination (NOT) will be submitted to DEQ, at which time the permit will officially terminated.

BMP’s suggested by the DEQ will be utilized throughout construction to maintain water quality and minimize soil erosion. Following construction, stormwater runoff will be collected within onsite detention and retention/treatment basins and discharged at predevelopment rates in strict accordance with DEQ Circular 8.

Soils at the proposed dairy building are generally described by NRCS as Lawther-Gerber Complex (8%-15% slopes) and Gerber-Lawther Silty Clays (4%-8% slopes). These soils predominantly consist of silty clays and silty clay loams and they are defined as “well drained.” The soils are further defined as have no frequency of flooding and no frequency of ponding. NRCS indicates these soil types have a “capacity of the most limiting layer to transmit water to transmit water” as moderately low to moderately high at 0.06-0.20 inch/hour.

The existing topography is generally rolling hills with moderate slopes. The north side of the property drains northerly toward the MDT R/W. Storm drainage from the north side of the property will eventually reach the Missouri River. The south side of the property drains south and west into Antelope Creek and eventually enters Sand Coulee Creek, which also discharges to the Missouri River just upstream and south of City of Great Falls.

Upon completion of construction, there are no anticipated significant impacts for erosion, sedimentation, and stormwater runoff. Impacts will be consistent with an increase in impervious surfaces; however, these impacts will be mitigated using appropriate BMPs, storm water detention, and other applicable regulatory requirements. Revegetation of disturbed areas combined with proper storm water collection and detention as required by the DEQ’s storm water permit will minimize impacts to the site. Additionally, water leaving the site will be properly treated (i.e. sediment removal) and flows will be maintained at predevelopment rates.  

Response: There are no public, community, or private water supplies on the property. There are a variety of private wells adjacent to the property primarily serving individual homes and agricultural operations. It appears that all such wells are located at least one mile from the proposed dairy processing facility.

The dairy operations will require process water with estimated volumes of ~13,000 gpd, which equates to 10.4 acre-feet/year. It has been demonstrated that the underlying Madison formation can easily satisfy these volumes. The depth to the Madison formation at this location is estimated to be 400-500 feet bgs (below ground surface) and the aquifer is estimated to be 350-500 feet in thickness. A well contractor will be employed to construct a test well and provide test pumping so as to demonstrate that existing wells on adjacent properties will experience no adverse impacts.

A new public water supply will then be constructed to serve the development. Well construction and protection requirements of DEQ Circulars 1 & 3 and the Administrative Rules of Montana will be strictly adhered to so as to protect the new public water supply and groundwater within the general vicinity of the project.

Surface waters in the vicinity of the project will be protected by maintaining effective runoff collection and conveyance systems to direct stormwater to onsite detention ponds where it can be detained and treated prior to discharge. Discharge will be restricted to predevelopment rates.

All wastewater treatment and/or storage ponds will be designed such that they are safeguarded against impacts to local groundwater and surface water by utilizing adequate liners and/or best management practices to avoid leaks and spills. Additionally, all setback distances as required by the Montana DEQ will be strictly maintained between water supply wells and potential hazards so as to limit contamination potential.  

Response: Land uses in the vicinity primarily consist of large-scale agricultural operations and associated rural residential uses. The dairy processing facility will be located more than one mile from any existing dwelling or agricultural buildings. Possible conflicts are expected to be minimal, but could include additional traffic, visual changes (additional buildings, night-time lighting), and some noise. Yet, MFP’s design team will utilize buffering features to help mitigate noise and visual impacts whenever possible.

The proposed development is agriculturally based and thereby complements existing uses of the surrounding properties. Additionally, the facility is proposed to be centrally located within the relatively large subject properties which will help eliminate any potential conflicts with surrounding land uses. Visual impacts can be mitigated using strategic landscape placement and by implementing exterior lighting technologies to direct lighting downward to reduce or eliminate glare and offsite lighting “pollution.” Traffic has been addressed previously in this document.

Permitted land uses in the Agricultural zoning district have the potential to create similar conflicts. Agricultural operations, by their nature, tend to generate dust and odors associated with tilling, planting, harvesting, and the use of chemicals. Commercial dairies generate their own impacts from odors and have increased waste management needs. The MFP dairy processing facilities impacts will be similar to those land uses already permitted by the zoning district and can be mitigated using readily available measures.  

Response: This consideration is an alternative to the previous one and need not be met. This consideration exists to allow approval of a special use permit in the rare instance that a proposed land use is so important that its impacts should be accommodated. MFP is not making such a claim with respect to its dairy processing facility.

All development allowed by the zoning district regulations, whether as a permitted use or as one requiring a special use permit, creates some level of impact. This is expected and appropriate. All potential impacts created by MFP’s dairy processing facility can and will be appropriately mitigated and minimized such that there will be no appreciable impact on public health, safety, and the general welfare of the community or County.

Additionally, the facility will also provide some benefits via increased tax base and the addition of jobs for area residents and will utilize milk that is produced in and around Cascade County and throughout northcentral Montana.