Tuesday, May 7, 2013

PORTLAND, OREGON WATER INVESTIGATIONS POST HASTE!: Randy Leonard, ET AL

Dear Friends,
 
I am forwarding this, albeit lengthy, explanation and urgent appeal to a select few of you to save Portland's amazing reservoirs from being covered. This, like the fluoridation issue, was the doing of no-longer-water-commissioner Randy Leonard who will have damaged our incredible water (and our health!) in so many ways unless we make our voices heard...now! Randy created much unnecessary business for CH2M Hill -- at our expense!

In addition our water bill that has already doubled -- and doubled again in recent years -- is going to climb higher again this year with Mayor Hales 3.6% water increase + a base charge increase + a sewer rate increase!  Please forward to anyone you know who can/will take action. I know this is a lot of information. Please call me if you have questions: 503-242-1111 (Charlie).

Please protect our drinking water and our grand open reservoir system by objecting LOUDLY and alerting your friends, family and neighbors to do the same.

WATER BUREAU FAST-TRACKING TABOR DISCONNECT

As of this week (Monday morning), The Portland Water Bureau and their contractors have heavy equipment in Mt. Tabor park just below Reservoir 1, "potholing," digging the area above water mains that supply water to the open reservoirs in preparation for shutting off the water to the Mt. Tabor Reservoirs.

In December the Water Bureau inserted Tabor disconnect consultant work in a Powell Butte II contract so they could continue down their fast-track, corporate-benefiting path without having to go back to Council and face ratepayers. After the Council session Commissioner Amanda Fritz told us that she didn't know that she was voting on anything related to Mt Tabor reservoirs. She said she was focused on the Washington Park contracts brought to Council two years ahead of schedule by Randy Leonard's Water Bureau. In essence, by allowing the Water Bureau to include this work in the Powell Butte tank contracts, Randy Leonard's crony-lead Portland Water Bureau sees nothing in the way of thwarting community will again.

Mayor Hales is in charge right now, but there isn't any evidence yet of his reigning in the ever bloated, ever wasteful Portland Water Bureau.

Call and/or write Mayor Hales and City Commissioners right now. Demand that they stop any further activity related to disconnecting Tabor or Washington park reservoirs. Mark your calendars for the water rate hearing on May 15 at 9:45 a.m. Your water bill that has already doubled and doubled again in recent years is going to climb higher again this year with Mayor Hales 3.6% water increase + a base charge increase + a sewer rate increase! 

Tell City Hall to end this bad reservoir/so-called "public health" policy, spending hundreds of millions on projects that will degrade our water system (send Columbia South Shore Wellfield Radon venting into homes, and limit the venting of disinfection by-products at the open reservoirs) for no measurable public health benefit.

Protest bad governance: spending $40 million on open reservoir upgrades designed to keep the reservoirs safely operating until 2050 then abandoning their functionality. 
Demand better Water Bureau leadership: terminate Leonard's crony management of the Water Bureau, management that has unnecessarily raised your water bills, water bills that are one of the highest in the nation. 

There is still time to chart a better course, one that retains the functionality of our open reservoirs. To do that this City Council must stop any further work at Tabor NOW and actively engage the Congressional delegation to assure that we secure permanent relief for our great water. Mayor Hales also needs to fire the crony management at the Water Bureau, http://www.oregonlive.com/portland/index.ssf/2013/05/most_top_city_of_portland_admi.html


SPREAD THE WORD. Write, call and show up at City Hall on May 15, 2013.

Oregon Health Authority - no legitimate basis for denial:

This last week, after an inexplicable delay in responding to both the City's reservoir deferral request and stakeholder's November 2012 request, the Oregon Health Authority (OHA) denied deferral of costly reservoir projects. This was their second denial -- both times providing no legitimate basis for the denial. The reason given for first denial was that EPA was requiring steady project progress barring construction delays -- no public health reason. 

In Rochester, New York, deferral of all work and of all spending on reservoir projects until at least 2022 has proved OHA's reason for denial is no longer valid. Rochester will not be spending one dime on "treating" (or covering) their two historic open reservoirs set in City parks, not until (at the earliest) 2022. It will take Rochester years to collect the statistically significant Crypto sampling that Portland has already collected at our open reservoirs. Prior to securing their deferral, Rochester -- unlike Portland -- had not invested $40 million in open reservoir upgrades. While Rochester's watershed is not federally protected as is Bull Run, they have a filtration plant, but not post reservoirs. All source water public health outbreaks have occurred in systems with filtration plants, in unprotected watersheds just as all storage facility outbreaks have occurred in covered reservoirs.

Rochester like NYC, Friends of the Reservoirs, Physicians for Social Responsibility, the AWWA and others, will continue to actively work on revision of the onerous and unsupported LT2 rule including revision of the onerous "treat or cover" requirement that was not based on any EPA open reservoir data collection or supported by any scientific study of open reservoirs. 

Contrary to OHA's implication, our open reservoirs are very similar to Rochester's two engineered, historic open reservoirs set in City parks with chlorination facilities located on site. Rochester does not have post reservoir Crypto treatment in place. Here's the primary difference between Rochester's open reservoirs and Portland's: the PWB has a long history of cozy-consultant contracting going back to 1994 to http://friendsofreservoirs.org/Consultant%20Contracts3jan11%2011x17%20LT2.pdf and Rochester does not. 
http://friendsofreservoirs.org/background.html  (Note that this background information is dated. Consultant Glicker is going on his 20th year as a PWB revolving-door consultant, no longer just a 14-year revolving door consultant. And his Powell Butte II contract has been extended to work on non-mission critical projects.)

OHA's April 29, 2013 letter does not provide a legitimate basis for denial of deferral of onerous and unsupported LT2 reservoir projects. Sound scientific research (American Water Works Association Research Foundation 3021), massive open reservoir sampling (AwwRF 3021), comprehensive disease surveillance associated with the source water Variance, and nearly 120 years of open reservoir history of providing safe drinking water, soundly demonstrates that we already meet the goal of the poorly-craft LT2 rule to reduce the level of disease in the community from Cryptosporidium, Giardia and viruses. 

We will respond line by line to themisleading, irrelevant, or inaccurate OHA comments, including addressing their reference to bacteria which is not an LT2 issue, but is a Coliform rule issue. You may be unaware there was e-coli detected at the buried Powell Butte tank being addressed by the Coliform rule currently under revision. This acknowledges, in part, the real public health problems, the deaths and illness documented by the EPA as only having occurred in covered storage facilities where water degradation can be a problem, and cancer-causing nitrification occurs. These are issues of genuine concern with any move to cover open reservoirs!
Referenced in the only LT2 Rules open reservoirs study: Protozoa in Open Reservoirs, a study of non-engineered reservoirs in New Jersey (AWWA Journal volume 89, issue 9) where researchers did not find a basis for any reservoir requirement.

Tell City Hall you want them to immediately engage with the Federal delegation to put an end to this costly degradation of our water system. Ask Mayor Hales to direct the Water Bureau to stop any further activity at Mt. Tabor associated with disconnecting the Mt. Tabor reservoirs. Though Federal legislative relief for the open reservoirs has been (on paper) a top City priority, Randy Leonard interfered with opportunity last year to further enlist the help of Senator Merkley. With Representative Earl Blumenauer now publicly supporting deferral of reservoir projects, it is time for City Hall to align their words and actions to secure permanent relief so Portland can retain the functionality of our historic, recently upgraded open reservoirs.

Where there is a will there is a way.
Thanks to NYC's water department and Senator Schumer the onerous reservoir requirement will be revised (scheduled for 2016) likely to include a mitigation option that would allow us to retain the open reservoirs without "treating or covering" for contaminants that do not exist. But it is up to this City Council to make sure that their constituents are not further harmed before this takes place. 

SPREAD THE WORD. Write, call and show up at City Hall on May 15, 2013. Be sure to contact all on City Council as it is the next Water Bureau Commissioner who will be the deciding factor in securing relief.

Write and call:

Mayor Charlie Hales,
503 823-4120
Noah Siegel, Water Bureau Liason, noah.siegel@portlandoregon.gov

Commissioners : Amanda Fritz,amanda@portlandoregon.gov
503 823-3008

503 823-4682

Dan Saltzman dan@portlandoregon.gov    503-823-4151

Nick Fish  nick@portlandoregon.gov    503-823-3589

Please be respectful and clear in your messages. Tell City Hall to take actions that assure that Portland retains the functionality of our upgraded historic open reservoirs. Mayor Hales said he supported retaining the open reservoirs when running for office. He also said he would lower water and sewer rates.

Below is the communication that includes the OHA "panel" Mel Kohn, OHA referenced.
 
From: david.e.leland@state.or.us
To: floy21@msn.com
CC: jonathan.n.modie@state.or.us; keely.l.west@state.or.us; kentcraford@hotmail.com; melvin.a.kohn@state.or.us; merrittregna@gmail.com; stewartstclair@gmail.com
Subject: RE: Team evaluating reservoir deferral request- public records request
Date: Fri, 26 Apr 2013 23:40:04 +0000

Floy

My apologies for my delay in responding to your request. Here is the extension request review team:

Dave Leland, Interim Administrator-Center for Health Protection, Public Health Division (PHD)
Kari Salis, Manager-Technical Services Region 1, Drinking Water Program, PHD
Michael Tynan, Policy Officer,PHD Director's Office
Kathleen Vidoloff, PHD Communications
Katy King, PHD Intergovernmental Liaison
Shannon O'Fallon, Dept. of Justice, Senior Assistant Attorney General for PHD

In addition we are consulting with the following agencies for the indicated issues:
Tony Barber, EPA Region X Oregon Operations Office - current status of LT2 rule review and process
Lynn Schoessler, Oregon Infrastructure Finance Authority (drinking water revolving fund) - water rates and debt ratio


Dave Leland
Interim Administrator - Center for Health Protection
Public Health Division
Oregon Health Authority
971-673-0403

From: floy jones [mailto:floy21@msn.com] 
Sent: Friday, April 26, 2013 9:11 AM
To: David Leland; Keely West
Cc: Regna Merritt; Kent Craford; Stephanie Stewart - MTNA Board
Subject: FW: Team evaluating reservoir deferral request- public records request

Mr. Leland and Mr. West, 

Responsive to my April 18, 2013 e-mail  I was anticipating a quick reply with the names of the individuals evaluating Portland's request for reservoir project deferral . 

Baring receipt of this information today, I am requesting under Oregon Public Records law an electronic copy of any communication with persons evaluating Portland's request for a deferral of reservoir projects directly related to this task including any communication regarding who should serve on this team and how it would function, and any related communication  with any LT2, PWB, or EPA consultants.

Floy Jones
 Mr. Leland and Dr. Kohn,

Could you please provide the names of the team assembled to evaluate Portland's request for a deferral of reservoir projects.

 I offer the following in brief to further support OHA's expediting approval of Portland's deferral request:

 The LT2 "treat or cover" reservoir requirement was not based on any scientific open reservoir data, the absence of which is the reason why there was not a review of such scientific data at EPA's April 2012 LT2 reservoir meeting held in Washington D.C ..   The official LT2 record (reviewed by the City of Portland and stakeholders such as Friends of the Reservoirs) contains no more than a handful of documents (out of the approximately 700 in the record) that even once mentioned the words open reservoirs. There was only one study of open reservoirs in EPA's LT2 record, a 1997 study of non-engineered, lake-like storage reservoirs in New Jersey conducted by Mark LeChevalier, William Norton, and Thomas Atherholt.
The published report on this study (AWWA Journal volume 89, issue 9), Protozoa in Open Reservoirs, did not support a "treat or cover" requirement for open reservoirs. The researchers found the public health risk at these New Jersey open reservoirs to be low. The researchers concluded by speaking to the problems with covered storage,  nitrification problems that are common in covered storage in chloraminated systems, the degradation of water that occurs in covered reservoirs, problems with covers themselves. The researchers also stressed the importance of developing improved Cryptosporidium sampling methods, methods that accurately assess the viability and infectivity of Cryptosporidium oocysts, an issue that remains today.

EPA has documented real public health problems, deaths and illnesses, only with covered storage facilities.

As noted in the City's deferral request, scientific research (AwaaRF 3021), a study of 7000 liters sampled at the outlet of Portland's open reservoirs, concluded that Portland's water system already meets the goal of the LT2 rule.

Thank you in advance for forwarding the names of those evaluating Portland's deferral request.

Floy Jones
 
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