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Save Portland's Reservoir (again) & Bull Run Water Too!

Time is of the essence to urge and press Portland City Council to vigorously seek legislative relief from the onerous and misdirected requirements of the EPA's Long Term 2 Enhanced Surface Water Treatment Rule (LT2).
Otherwise, the result will be the costly loss of our open reservoirs and costly filtration of our pristine Bull Run water. Pursuing legislative relief is supported by the Mt. Tabor Neighborhood Association, the South Tabor Neighborhood Association, the Arlington Heights Neighborhood Association, and many area business groups, environmental organizations, public health officials, and individuals.

All of those parties are asking the Oregon delegation (Wyden, Merkley, Blumenauer, Wu) for their assistance in securing a Congressional "waiver" exempting Portland from the EPA LT2 Rule's two key mandates of 1) additional treatment of our Bull Run source water and 2) burial, coverage, or treatment of our five in-town reservoirs (or otherwise decommissioning and building storage elsewhere).

With deadlines fast approaching, action is needed now to avoid Portland ratepayer and taxpayer costs of approximately $800 million dollars in capital expenses ($1.6 billion including debt service) for blindly mandated source water treatment and open reservoir removal. This, for no measurable public health benefit and without rational relevance to the intent of the LT2 Rule.

Also worth pursuing is an extension of all related EPA deadlines in order to facilitate the generation of an effective legislative resolution.

Portland is pursuing a "variance" that would "exempt" the city from treatment in Bull Run as long as testing met certain standards, but even that option is unfairly onerous in its testing costs and requirements, which are also vulnerable to a high degree of subjective interpretation. It is frought with pitfalls. As for the open resevoirs, the EPA rule inexplicably removed an originally drafted mitigation option, ie, no "variance" is available. For these reasons, a legislative remedy seems to be the only and best solution.

Fortunately, all of the delegation members have offered their support on this issue, the fundamental facts of which include EPA's failure to rely upon sound science as a foundation for the LT2 policy and law as it relates to Portland's system and open reservoirs in general. It is hopeful to hear that the Obama administration is returning science to its rightful place in such decision-making.

Other fundamental facts have guided two separate and recent Portland community panels, which exhaustively reviewed the costs and benefits of additional Bull Run treatment and elimination of Portland's open reservoirs. They respectfully concluded that there would be no measurable public health benefit from additional treatment and that the best approach to the open reservoirs would be to implement risk mitigation plans rather than bury, cover, provide additional treatment at their sites, or take offline and build storage elsewhere. These fundamentals have not changed, with the following notable exception:

In the course of those public examinations, as well as other times in the past, the huge cost involved with just the burial or replacement of the open reservoirs alone has been cited as a key deterrent, especially given the questionable benefit. Our country, our state, our city and our citizens are experiencing an economic meltdown not seen in several generations, the depth and breadth of which far surpasses the circumstances of those previous inquiries.

Public Hearing March 25th

There is a critical public hearing on March 25, 2009 at 2:30, at City Hall downtown. There, the Water Bureau will be asking City Council to accept and include in the budget plans to eliminate all 5 open reservoirs & build a filtration plant.

Ostensibly, this plan is only if they are forced to comply with the LT2 Rule. However, there is reason to question their word on this, not the least of which is that it isn't necessary to budget for these projects at this time. Members of the public are greatly urged to attend and give their 3 cents.

Some of the concerns include, in addition to the issues with the treatment variance, over a year went by without the Water Bureau pursuing legislative relief for the open reservoirs. Also, the WB has indicated plans to speed ahead with some of these projects even if we do get legislative relief, especially Powell Butte storage, even though it is agreed that water usage forecasts indicate no need for additional storage into the foreseeable future, as long as Mt. Tabor is maintained. The only rationale offered has been that it would provide alternatate storage IF we are forced to stop using the open reservoirs. But if we aren't? Well, we'll surely need it "some day." That's at least $137 million for "some day."

Furthermore, the LT2 Rule requires that for the open reservoirs, the City only needs to provide a negotiated compliance SCHEDULE by April 1, 2009 -- but there is no specific deadline for actually covering/decommissioning them. And the treatment plant deadline is not until 2014 at this point. Council does NOT need to iclude these projects in the budget at this time.

Another cause for doubt is due to the fact that this public hearing (a rare opportunity for public testimony on the record) was only reluctantly scheduled as a result of public pressure.

It is important for members of the public to testify, show up, write. The Water Bureau and the Oregon delegation need to see strong public support for legislative intervention to exempt Portland from the EPA's LT2 Rule.

- No to budget approval for unneeded projects
- No to $1.6 billion for unneeded filtration and destruction/
decommissioning of our open reservoirs
- Urge legislative relief
- Urge extension of compliance deadlines

If submitting comments, you are asked to please bring 6 copies - 4 Commissioners, Mayor and Clerk. If not testifying, it is worthwhile to fill the chambers in a show of support!! Bring the kids!

More information is at www.friendsofreservoirs.org

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