Victor Wastewater Treatment Facility

Victor is currently engaged in mediation conversations with the City of Driggs to determine whether Victor will continue to send its wastewater to Driggs, combine forces with a joint powers partnership, or separate and build two separate plants. More information will be posted here as it becomes available.

Letter to the Editor: A Responsible Path Forward for Teton Valley

Mayor Frohlich's Comments, Driggs Council Meeting 12/16/2025

Hello Teton Valley! I would like to give thanks to the City of Driggs for allowing me to speak during their meeting on December 16th, 2025. I would also like to thank the Driggs City Council for all voting in favor of agreeing to mediation between the two Cities. I wanted to further share with the public what I presented to the Driggs City Council on the 16th for those who were unable to attend.

- Mayor Frohlich

Please visit the City of Victor’s link here for additional information - https://victoridaho.gov/wwtp

Driggs City Council Meeting – 12/16/25 – Agenda item – Victor Wast Water Treatment Plant Mediation Proposal

Hello Council and Mayor - Thank you for letting me speak tonight.

I appreciate the opportunity to provide additional context regarding the matter before us and am happy to answer any questions you may have.

First, I would like to thank the Council for your service and dedication. As the powerful decision-making body, your role is critical. It is the responsibility of Mayors and City Staff to support your decisions and provide the necessary information to guide you through the decision-making process. Sound decisions are built on solid information, and complex issues become more manageable when all data is present.

I would like to address the working relationship between our two cities. Our communities have a long history of collaboration that predates our respective administrations, continues today, and will endure long after we leave office. It is essential that all of us maintain a professional and respectful approach in our interactions.

To provide a brief background on the current situation: As is well known, the existing WWTP has experienced issues since its inception. At the time the plant was designed, the City of Victor expressed opposition to the chosen design, as it involved an unproven option for our location. But Driggs’ Engineers said it would work as promised.

As a User, Victor was aware of existing issues but did not know the full extent of the problems. We later learned that multiple concerns and actions had been raised by the DOJ (Department of Justice), EPA (Environmental protection Agency), DEQ (Department of Environmental Quality), and other entities. We only received formal notification from Driggs of the DOJ lawsuit and resulting Consent Decree after the terms of the Consent Decree had been negotiated between Driggs and the Department of Justice.

Unfortunately, Victor often learned about these significant issues years after the problems arose through public sources, such as social media and newspaper articles, rather than directly from our partner. Victor continues to learn through third parties that Driggs is in continued violation of the Consent Decree.

In hindsight, and per our agreement, a proactive audit should have been done annually. This was not agreed to on multiple occasions.

Years ago, I instructed the Victor City Administrator to begin working with the Driggs City Administrator to address the issues and align on a plan. Following the Driggs City Administrator's departure, we learned that Driggs was unaware of these recent conversations and communications and needed time to investigate further.

A third-party independent audit was eventually agreed upon by both cities. The scope was intentionally narrow to control costs. Even within this small sample size, the audit found several discrepancies. It’s important to clarify that the audit was conducted by an independent third-party firm with no ties to either city. The financial data used in the review came primarily from Driggs, since Driggs owns the facility and maintains all related financial records. Because the audit relied on Driggs’ own documentation, the findings reflect that information — not any outside influence from Victor. To that end, I want to emphasize the audit firm was selected in part because they had no prior relationship with either city.

Following the initial audit, we requested an additional, broader audit to review a longer time frame and address outstanding issues, but this request was denied on multiple occasions. Driggs has only recently consented to a broader audit but admitted that they do not possess records needed for the audit.

Additional meetings were held between the two Cities, but these discussions concluded without a resolution. Victor’s concerns regarding financial discrepancies were dismissed or minimized and, on several occasions, Victor was directed to ‘GO BUILD YOUR OWN PLANT,’ among other discouraging comments.

After two plus years of having our concerns dismissed or minimized, Victor engaged outside counsel, Smith Currie, to advise us on the outstanding issues and to help us negotiate a mutually beneficial inter-city agreement for wastewater treatment services. However, the new agreement presented to Victor proposed reduced involvement while simultaneously asking us to increase our financial contribution. We would also maintain zero input or control over the plant’s design or operations. And would allow Driggs to pass on its costs associated with the Consent decree disproportionately to Victor users for Driggs’ benefit.

As a point of clarification, Smith Currie is not advising us on whether to build a new plant. Regarding the tone of the letters/requests sent—it is fair to say they reflected the frustration and urgency felt at the time. Victor desperately wanted and desperately wants its financial and legal concerns to be taken seriously. Following multiple failed attempts at negotiation, Driggs gave Victor a deadline last Spring of just over a week to decide whether to remain under the current agreement or commit to building a new plant.

The Victor City Council voted unanimously to proceed with building our own plant. As this process continued, public interest grew, leading to encouragement for one final attempt to work with Driggs. We have spent weeks seeking confirmation from Driggs on what options the DOJ is willing to consider. To date, we have not received a definitive answer, and we now face hard deadlines. It has been confirmed that the DEQ, not the DOJ, will support a joint plant, which obviously we already know. (Driggs’ City Attorney did confirm during the meeting that the DOJ is open to JPA discussions).

During our Council meeting last week, Mayor August stated that if we choose to advance this discussion, Victor must lead the effort. In response to that request, we moved swiftly to send a letter requesting mediation as a starting point. This letter was sent to Driggs on Friday.

Regardless of the decision made tonight, your focus must be on what is right for the rate payers of Driggs and the environment, just as our focus is on what is right for the rate payers of Victor and the environment. Please know that I hold no personal ill will toward any member of this body, and that has been my perspective throughout this entire process.

Wastewater Decision Analysis

Financials

There is no clear financial winning scenario in this situation. The consent decree filed against the Driggs plant has a strict timeline and requirements that will result in tens of millions of dollars of expenditures. 20250115 Filed CD | MuniDocs | Driggs, ID | Municode Library

The costs associated with building a brand-new plant in Victor, an upgrade to a non-compliant plant in Driggs, or a combination of the two are extremely complex and vary in operational costs, debt service, and grant eligibility. Below are estimates of the various paths forward.

These estimates could change dramatically. It could be the difference of a single grant, an operational efficiency, a new hire, a change in interest rates, a large commercial building or development added to the system, or any number of other factors.
Victor and Driggs are actively pursuing grants from state and federal agencies and corporations to lower the cost of the build, as well as investigating alternative financing structures for better interest rates.

The two drivers of the monthly cost for users will be debt service and operations. City of Driggs is working on an operational budget to compare.

There are four options for moving forward with wastewater treatment:

-Alternative 1: Both Cities go their own direction. Estimated to be $16M for Driggs, $35M for Victor.

-Alternative 2: Victor and Driggs partner and do not accept the trunkline into the partnership (this would also be similar financially to a customer model). Estimated to be $34M combined, Victor could have a potential $20M in upgrades

-Alternative 3: Victor and Driggs partner and accept the JPA with trunkline into the partnership. Estimated to be $54M with upgrades included

-Alternative 4: Victor and Driggs partner and accept the JPA with trunkline into the partnership and make the necessary improvements for Class A Discharge (the highest environmentally conscious discharge). Estimated to be $60M

Driggs Debt Service

Driggs Debt Service (not including any grants, operational expenses, or collection expenses, also does not include dredging expenses). These are simple calculations based on a 30 year, 4% amortization. This is a possible route and interest rate using the Idaho Bond Bank. It is possible that the City of Driggs may get better financing offers but it would likely come with BABA and other provisions, increasing the costs. City of Driggs has reached out and expressed they are interested in a twenty-year amortization. If a twenty year amortization is chosen, the payments on each option increase by approximately $250k/yr.

Debt Service for only City of Driggs (not including 2016 debt)

Alternative 1, Only Driggs, $916,637/yr

Alternative 2, JPA no trunkline, $973,927/yr

Alternative 3, JPA w trunkline, $1,546,826/yr

Alternative 4, JPA with Class A w Trunkline, $1,718,695/yr

Victor Debt Service

Victor Debt Service (not including any grants, operational expenses, or collection expenses, also does not include dredging expenses at the Driggs facility).

These are simple calculations, based on a 30 year 4% amortization, a likely financing option with the Idaho Bond Bank. The second, third, and forth alternatives are with the 4% loan shared with Driggs above.

Debt Service for only City of Victor (not including 2016 debt)

Alternative 1, Only Victor, $2,005,144/yr

Alternative 2, JPA no trunkline, $2,119,724

Alternative 3, JPA w trunkline, $1,546,826

Alternative 4, JPA with Class A w Trunkline, $1,718,695

Victor's payment is higher for the no trunkline because in Alternative 2, Victor is paying for trunkline capital expenses

Treasurer's Report

Garland, Utah Wastewater Facility Tour

History of the City of Victor's Wastewater Treatment

Prior to 1999, the City of Victor, managed its wastewater through individual septic tanks. However, as environmental regulations under the federal Clean Water Act became more stringent in the 1980s and 1990s, these older, natural-process systems increasingly struggled to meet required discharge standards for pollutants. For growing communities like Victor, the cost of building a lagoon system and acquiring the necessary land for expansion became a significant financial and logistical burden.

This set the stage for a decades-long partnership with the nearby City of Driggs. On October 13, 1999, Victor signed an agreement to send its municipal wastewater to the Driggs facility for treatment. At the time, Driggs operated a lagoon-based plant. For years, this arrangement offered Victor a cost-effective solution, allowing the city to manage its local sewer collection system while cost sharing in the treatment with Driggs.

The landscape of this partnership began to shift significantly in the late 2000s. Driggs faced growing regulatory pressure from the U.S. Environmental Protection Agency (EPA) due to repeated violations of its discharge permits. In response, Driggs embarked on a major upgrade, replacing its lagoon system with a modern Multi-Stage Activated Biological Process (MSABP) mechanical plant in 2013. The two cities updated their original contract with a new inter-city agreement in 2011 to account for this change.

Despite the upgrade, Driggs' compliance issues persisted. In 2022, the U.S. Department of Justice filed a formal complaint against Driggs for thousands of permit violations, leading to a consent decree with the EPA in January 2025. As part of this settlement, Driggs was required to pay a $400,000 penalty and undertake another major facility expansion and upgrade, estimated to cost over $30 million.

This new financial pressure brought the Victor-Driggs partnership to a breaking point. An independent audit, initiated by Victor in early 2023, revealed significant historical billing discrepancies. Additionally, in October 2024, anticipating increased costs, the city implemented significant sewer rate hikes. Facing a lack of control over rising costs and management of the Driggs plant, Victor began to seriously consider its own independent system.

In March 2025, after reviewing a feasibility study by Keller Associates and evaluating multiple alternatives, Victor's City Council unanimously voted to "break up with Driggs". The alternatives considered included staying with Driggs, building a new lagoon system, or constructing a mechanical plant with either a surface discharge or rapid infiltration system. The decision was made to pursue the construction of a new plant, in which Victor would have control over legal compliance, costs, and management.

Following the decision, Victor took decisive steps toward self-sufficiency. In August 2025, the city entered a contract to purchase a 40-acre parcel of land to serve as the site for its new wastewater treatment facility. Driggs has agreed to continue treating Victor's wastewater until at least January 2029, allowing Victor time to complete construction of its new plant. This major infrastructure investment is a pivotal moment for Victor, shifting its wastewater management from a customer-model to a local asset under its own control.

Meeting links and staff reports for the March and August 2025 mentioned above are located in the City Council Meeting Links Tab below. It also includes all meetings where actions regarding the WWTF will be cataloged.

Teton Valley News Article about the Council Vote to begin the process of building a Wastewater Treatment Plant for the City of Victor.

Teton Valley News Article regarding the plan to purchase land for use of the WWTF.

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Victor Wastewater Treatment Facility

Letter to the Editor: A Responsible Path Forward for Teton Valley

Mayor Frohlich's Comments, Driggs Council Meeting 12/16/2025

Wastewater Decision Analysis

Financials

Treasurer's Report

Garland, Utah Wastewater Facility Tour

History of the City of Victor's Wastewater Treatment

City Council Meeting Links

Supporting Studies

Request for Qualifications Process - for Engineer

Annexation - Rezoning Application and Process

Lot Split Application Process

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