Send us Tabor Reservoir historic photos, documents, and stories

The Mt. Tabor Neighborhood Association (MTNA) seeks your historic photos, documents, and stories about Mt. Tabor Park's historic open reservoirs. 

We are interested in collecting photos, stories, documents about:

• Mt. Tabor’s open reservoirs, from construction to today;
• The Bull Run watershed, from the late 1800’s to today;
• The original engineering and construction of the Bull Run system, from the watershed to the city.

How to share materials with MTNA?

If you have materials in your own personal collections, please consider sharing them with our team.  You can email:  MtTaborReservoirHistory@gmail.com with your digital files.  Or, if your materials are not digitized, send us a note to that same address with a description of what you have and a way to contact you and someone will get in touch. 

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What's this about?

As you may remember, the land use review for the disconnect construction project at the Mt. Tabor reservoirs mandated that the Portland Water Bureau capture some of the story of Mt. Tabor's reservoirs, and their role in the Bull Run water delivery system.  This story is to be made available through on-site educational materials.  This kind of effort is known as an “interpretive program.”  MTNA is part of the joint team (which includes professional historians and PWB staff) that will help craft this interpretive program over the next 2 years. This summer, this team will be dedicated to collecting materials and conducting research, and sometime this fall you can keep an eye out for a public meeting at which we will share some of our emerging ideas for the program.

Treatment Variance application reveals a stale plant design, flawed testing, and more nonsensical behavior

This morning I read just one section of the Treatment Variance Application Portland Water Bureau submitted to the state Drinking Water Program this week. LT2 is outlandishly expensive. Even the variance is going to cost us (testing at high volumes takes money). LT2 is also completely void of benefit to us, because we don’t have the problem LT2 is trying to fix. So, to summarize, LT2 is expensive and unnecessary for Portland’s pristine Bull Run Water. And yet, in section 6.5 of the variance application PWB just filed with the state, PWB makes the case for conducting useless LT2 tests even MORE frequently and at higher volumes than LT2 requires. Wha? If a useless test is no good, then doing even more of them is better? Well, it will funnel a little more money to PWB’s consulting buddies (a.k.a. their future employers) so somebody is getting something out of this, right?

In section 6.4.2, PWB lets slip that the UV plant design we are paying for right now (to wait on the shelf, just in case we don’t get our variance) will be stale, and possibly need “updating” (cha-ching). And the land use and environmental permits they are buying now, will likely also have to be redone (cha-ching). This is good planning? I don’t generally pack my potato salad the week before the picnic, because, that isn’t actually efficient preparation. If there is the possibility the UV plant design will be STALE by the time we need it, surely they built a clause into the contract that allows for a brief review for updating. Oh no, silly me, I keep forgetting. The principle is “funnel more money” not “conserve limited public resources.”
 
But most upsetting of all (it gets more upsetting) is the trigger to build the $100 million UV plant and the flawed testing protocol PWB put on that trigger. With so much at stake ($100 million dollars + future operating expenses) on the line for just two inconclusive test results, wouldn’t it seem prudent to be particularly careful when negotiating the test method. We wouldn’t want to choose a test method with well-known flaws, that the scientific community has identified as producing high false positives which overstate public health risks. Yet, rather than make the case for how much the science of Crypto testing has changed since EPA suggested testing Method 1622/23 as the standard for LT2 tests, PWB stated in the variance application they would employ flawed testing Method 1622/23. Almost unexplainable.

Cost without Cause

If you've read my PURB testimony from March 3, 2010, you've read this paper.

In 1973, citizens sued to protect the Bull Run watershed from logging. At the time, logging was being promoted by both the federal government and the Portland Water Bureau.*1 These citizens asserted that logging in the watershed was destructive to water quality. The judge on the case, Justice James M. Burns, rather pointedly identified one of the flaws in that 1973 debate surrounding our water system. He drew a distinction between statements of policy or purpose and statements of fact, noting that one should not be confused with the other. At that time, the federal government issued policy statements like, “logging will protect Bull Run from catastrophic fire,” but upon investigation the facts proved logging increased both the risk of and the damage caused by fire. The policy to log Bull Run as a means to control fire risk or damage in our watershed, was a policy based on an erroneous assumption about the relationship between logging and fire. Asserting that assumption unchecked, in a policy worded as a doctrine to protect, almost allowed a destructive practice to move forward under the guise of a policy meant to help.

Portland is again in a position where the federal government has asserted a statement of policy. And again, when Portlanders investigate the assumptions underlying these policy statements, the facts just don’t bear out.

Unsupported Policy #1: Covering your reservoirs will protect public health. Fact: EPA has documented multiple cases of death and illness caused by infectious Cryptosporidium outbreaks in drinking water systems. Every single case was either in a system with covered drinking water storage, or in a system where sewage, industrial, and farm runoff mixed with drinking water.* 2 The policy to “protect people from infectious Crypto” can be supported. The facts, however, don’t seem to support the use of lids as a meaningful treatment technique for microbes. Debris of all sizes enters all forms of water storage devices. If there is an inlet and an outlet for the water, there are entry points for non-water matter including microbes; covering a reservoir does not eliminate the need to manage contamination. Covers do not provide a silver bullet in the effort to protect public health.

New York City’s Department of Environmental Quality has spent significant resources collecting data on one of their large open reservoirs, known as Hillview. Their question was simple and quantifiable: Is water any more likely to contain Crypto or other protozoa once that water has been in the Hillview open reservoir than water that has not been in this open reservoir? The answer also seems to be simple: No. Time in the Hillview open reservoir does not increase the incidence of protozoa found in that water.* 3

Portland, too, has spent significant resources documenting the safety of the city’s open reservoirs. Between May 2008 and May 2009, the Portland Water Bureau paid to participate in a study conducted by the Water Research Foundation (WRF project #3021 *4); this was a large-volume collection study, analyzing finished drinking water gathered at the outlet of our open reservoirs (water sampled spent time in the open reservoirs). A preliminary report from this study has been published and the basic results found in Portland were communicated throughout the year-long test period. There was no infectious Crypto found in Portland’s drinking water.

Unsupported Policy #2: Constructed facilities are superior to engineered, protected watersheds when creating quality drinking water. Fact: There is no substitution for starting with the purest water possible. Portland’s drinking water system is uniquely engineered within a substantial framework of protection (possible because this system was established more than 100 years ago), and the result is some of the purest tap water in the country. The federal LT2 Rule favors construction over protection, without much data to support that favoritism.

EPA can produce surprisingly little evidence to verify chemical filtration plants perform the duties we expect them to perform. Drinking water exiting a chemical filtration plant is assumed to meet a particular set of standards; but that water is not tested to confirm that it meets those standards. When Portland tests its source water as part of the Variance process this coming year, it will be testing to see if Bull Run water meets the standards chemically filtered water is assumed to meet, with little evidence that chemically filtered water can actually meet these same standards. Furthermore, if ratepayers in Portland do buy an additional treatment plant, in theory so that Portland’s water can meet these standards, consumers have little in the way of a guarantee that they will actually get the results for which they are paying.

Recently, EPA scientists publicly revealed that EPA policies are often politically motivated rather than scientifically motivated. In testimony before a US Senate Committee this past summer (June 9, 2009) the Director of the Scientific Integrity Program at the Union of Concerned Scientists (USC) exposed an EPA producing compromised work-products between the years of 2002 and 2007 (these are the same years LT2 draft and then final rule was issued; * 5) , because of undue interference largely driven by industry lobbyists. Responders to a survey of EPA scientists revealed 22% had personally experienced the “selective or incomplete use of data to justify a specific regulatory outcome.” The percentage of scientists reporting interference was highest in the program offices with regulatory duties (68%) and at EPA headquarters (69%). One survey-responder explained that in cases where regulation is industry driven rather than scientifically driven, “the regulations contain a scientific rationale with little or no merit,” because, “the real reasons can’t be stated.” *6

One can begin to see evidence of possible industry influence on the LT2 Rule by reading the 2004 public comments from the Unfiltered Systems Working Group (comments made while LT2 was still in draft form * 7 ). This group calls-out a particular favoritism being afforded, at that time, to one specific industry by EPA with LT2’s mandate to use an exact treatment technique (UV).

We are also concerned with Calgon’s UV patent and its cost impact to unfiltered
systems, which, based on the proposed rule, will have to rely on the operation of UV to
meet the Cryptosporidium inactivation criterion. We believe it is inappropriate that the
proposed rule’s reliance on “UV only” causes the unfiltered systems to pay a substantial
patent fee annually to Calgon to meet the LT2 requirements.*7

Note that representatives from Calgon served on at least one of the Federal Advisory Committees funneling information into the LT2 Rule. *8 A number of participants on these federal committees, some of whom were Portland grown, *9 appear to have conflicting interests including connections to the various industries that stand to gain lucrative contracts as municipalities attempt to comply with the LT2 regulation.

One can see further evidence of possible industry influence on the LT2 Rule when considering the Rule’s open reservoir requirements, which heavily favor constructing new facilities without providing sound scientific reasoning. The open reservoir requirements found in LT2 are a perplexing insertion into a Rule which is otherwise dedicated to source water issues, not storage issues. EPA does not offer a single citation of a public health incident linked to open storage; EPA does, however, cite public health incidents in water systems employing closed storage devices. Yet, the LT2 Rule does not prescribe any new requirements for closed storage (the devices with incidents on record). EPA’s focus here seems less about protecting public health than it does about promoting the financial interests of industry lobbyists.

EPA’s application of this cookie-cutter regulation on a water system as unique as Portland’s, has always been a questionable approach to ensuring the public’s interests. As evidence mounts that EPA regulations are grounded less in science than in special interests, cities like Portland must carefully question the efficacy of compliance.

Unsupported Policy #3: Microbes are a threat to public health, while chemicals are not. Fact: The overarching goal in drinking water management is to produce water that supports the public’s good health. Portlanders should question the underlying assumption that the public’s health will subsequently improve with an even further reduction of microbe exposure (beyond the low-microbe levels already achieved by first-world, modern drinking water systems). Does completely eliminating all microbes from drinking water make people healthier?

There is data that suggests otherwise. A 2004 study by the Water Research Foundation (WRF) suggests a surprisingly complex relationship between microbe levels found in American tap water and the incidence of chronic diseases associated with microbes found in an American’s everyday environment. *10 Decreasing the microbes found in a drinking water supply clearly increases health, up to a certain point. Modern drinking water systems have mastered this point by separating sewage and drinking supplies (among many other conventions). Beyond a certain point, however, a further reduction of microbes seems to be linked to an increase in the number of people suffering from chronic, related diseases. The WRF study would seem to suggest that there may be a point at which the public is dependent on some small amount of microbe exposure in the drinking water to provide them immunity and increase resistance to those microbes encountered in the normal course of a person’s day. Which sounds familiar = small, occasional exposure builds immunity and increases resistance to chronic disease. Employing large chemical treatment plants as an additional barrier between taps and a well protected, clean water supply like Bull Run may unnecessarily deny the population a chance to incrementally build immunity to microbes, while dramatically increasing the chemicals to which the population is exposed. Modern drinking water is increasingly laced with a myriad of chemicals, many of which are employed to adjust the composition of said drinking water. There is remarkably little recognition among water industry officials and municipality managers of the long-term effects those chemicals have on humans, in various stages of life.

Endnotes:

1 Cooperation and Conflict in a Federal-Municipal Watershed, by Roy R. Wilson. Available online: http://ir.library.oregonstate.edu/jspui/bitstream/1957/9685/1/Wilson_Roy_R_1989.pdf

2 EPA whitepaper Finished Water Storage Facilities, prepared August 2002. Available online: http://www.epa.gov/safewater/disinfection/tcr/pdfs/whitepaper_tcr_storage.pdf

3 www.dos.state.ny.us/watershed/2009presentations/AlderisioWSTCHillview091409ppt.ppt

4 Project snapshot available online: http://www.waterresearchfoundation.org/research/topicsandprojects/projectSnapshot.aspx?pn=3021

5 Also the same years during which the open reservoir requirements were inserted into the LT2 Rule.

6 Testimony by Francesca T. Grifo, Ph.D., Senior Scientist with the Union of Concerned Scientists, Director of the Scientific Integrity Program. Delivered June 2009, before the U.S. Senate Committee on Environment and Public Works. Written testimony available online: http://www.ucsusa.org/assets/documents/scientific_integrity/Grifo-EPW-Testimony-June-9-2009.pdf

7 A copy of the Unfiltered Systems Working Group comments, January 2004, can be found on the Friends of the Reservoirs website: http://friendsofreservoirs.org/LT2/LT2comments-USWG.pdf

8 http://www.epa.gov/EPA-WATER/2000/December/Day-29/w33306.htm

9 http://www.portlandtribune.com/news/story.php?story_id=22165 As a representative of MWH, Joe Glicker served on various federal advisory committees with influence on the LT2 Rule. In recent years, Joe Glicker has joined CH2MHill, another global engineering firm specializing in water system projects. CH2MHill has secured several of the most recent LT2 related contracts, including the design contract for the Powell Butte reservoir and a contract to perform at least part of the work associated with the Bull Run treatment plant ( see Notice of Intent to Award associated with solicitation WTR082 https://docs.google.com/fileview?id=0B0FLHRhrA9yaMTMxZmY3ZjctNTA2YS00YzljLThmMTItYzQwYTRmZWVlNjA1&hl=en).

10 Water Research Foundation, Northwest Epidemiologic Enteric Disease Study, Project # 2637; project summary available online: http://www.waterresearchfoundation.org/research/TopicsAndProjects/projectProfile.aspx?pn=2637

Bull Run land-swap not a good deal for citizens

We often hear the City Council assure us that logging and development could never happen in the Bull Run watershed because the land is Federally managed and therefore Federally protected. Today, the Portland Water Bureau brings to City Council a land-swap proposal involving land in our watershed. This swap will remove some of our watershed lands out from underneath significant Federal protections.

Oregon Wild, formerly known as the Oregon Environmental Resources Council, has been involved in the development of this proposal and they have flagged a serious flaw with it; you can read their article alerting citizens to this flaw here: http://salsa.democracyinaction.org/o/1780/blastContent.jsp?email_blast_KEY=1168789

Stakeholders like Oregon Wild have worked with the City to write a new “protection code” for City land, so that the Bull Run watershed land that is about to move from Federal hands to PWB will be similarly safeguarded as if it were still Federally managed. According to Oregon Wild, this new code goes a long way to offering solid protection but falls short in one key area: it is weak on public involvement when management makes major decisions (like, say, choosing to log).

In an email to one concerned community member who contacted City Council this week regarding this land-swap, David Shaff of PWB assured there would be plenty of time to weigh in on this discussion in the future. Don’t worry your pretty little head, what we are deciding today is of little consequence, you can speak later (clearly, my own editorializing of what I read in Shaff’s letter). Portlanders know better; weighty agendas are furthered with incremental decisions like this one. There is no reason to move forward with any land-swap discussion if we can’t first all agree on how to protect that land once it is removed from Federal hands. PWB has historically been hostile to public involvement, and as long as that culture persists within PWB, citizens must be cautious and not let go of any leverage.

Bull Run has a long and sordid history. The parties involved and their agendas are nothing short of complicated. At times, both the Federal government and the Portland Water Bureau have promoted logging and commercial development within our watershed; at every turn, involved citizens have been the protectorates of our watershed and our drinking water. I once read a great PHD thesis exploring 100 years of competing influences in Bull Run, which presented differing definitions of “natural resources”. The paper is “Cooperation and Conflict in a Federal-Municipal Watershed,” by Roy R. Wilson (I found pages 84-124 quite educational and enjoyed reading about the 1973-76 legal case regarding logging in Bull Run).

Be suspicious. We have arrived in a new era in which Wall-Street discusses water as “the new oil”, while it leverages water-system investments as awkward as the ones it made in real estate. If competing influences in our watershed have been complicated before, they will be mind-boggling from here on out. Citizens will need to actively police decisions made in Bull Run. These new City Land protection codes don’t offer the public the kind of oversight access they will need in this new paradigm. If Oregon Wild says this proposal is flawed, you don’t want it to move forward.

UPDATE 2-21-10: Unfortunately, Portland's City Council approved this agenda item regarding the land-swap proposed in the Bull Run watershed. Only Commissioner Amanda Fritz stood with the myriad of citizen-groups requesting more substantive public participation policies; Commissioner Fritz voted to halt the land-swap discussion until the flaws in the city-land protection codes are addressed.

Commissioner Nick Fish was disappointing on this vote, contending his yes vote was just the beginning of a conversation; he fails to recognize the leverage sacrificed by allowing the discussion to move forward while so much of the community is already dissatisfied. Nevermind the fact that they aren't listening to citizen input right now, they promise to listen more, later on in the conversation.

This vote allows the Portland Water Bureau to formally open the next phase of the land-swap process. If left unchanged, these new city-land protection codes (now the only safeguards on the land to be held by PWB) seem to eliminate all environmental impact review processes, previously provided for under Federal regulations and open to public input. PWB can now move on any development on their new land holdings without a review. You can view the City Council discussion on this topic, items 220 and 221: http://www.portlandonline.com/index.cfm?c=49508&a=286230