Showing posts with label Tabor Disconnect. Show all posts
Showing posts with label Tabor Disconnect. Show all posts

Monday, May 15, 2017

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. 

Please share this request with others!
Help us get the word out.  Share this message on facebook, nextdoor…

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.

Thursday, July 9, 2015

Tabor Disconnect Newsflash: Settlement

Today MTNA representatives finalized a settlement with the Portland Water Bureau in the Tabor Reservoir land use appeal (LU 14-218444 HREN).  

These are the terms:  
  • We agree to eliminate Condition E from the land use Decision's Conditions of Approval (this Condition mandated spending on the preservation work called out in the Historic Structures Report).  
  • We agree to modify Condition B in the land use Decision's Conditions of Approval (this Condition deals with water).  
  • We co-wrote a Council Resolution, which carries the binding force of law, which covers several community concerns and mandates $4 million in spending for the preservation work called out in the Historic Structures Report.  
  • At the hearing on July 15, Council will be asked to adopt this Resolution, and in turn MTNA will pledge not to appeal the land use Decision to LUBA. Then Council will approve the modified Decision for this land use case.  If any of these steps go awry, the deal will also.  
The documents
Click here for the modified Condition B.
Click here for the new Council Resolution.
Concerned about the binding nature of the Resolution?  We are too.  Read this.

It's taken 18 months, what have we achieved?
commentary coming soon...

Monday, May 11, 2015

Tabor Disconnect Appeal News

Appeal Date
Thursday, May 28th at 2 pm
Council Chambers, City Hall

Media
Op Ed in the Oregonian on Sunday, May 17.  Click here.
Op Ed in the SE Examiner on May 1; written by Eileen Brady.  Click here.

Important Documents
MTNA's Appeal Report, April 29th -- Click here.  MTNA submitted a substantive appeal report to each City Commissioner and the Mayor.  This document lays out our case.  In short, we support the February 9th Historic Landmarks Commission Decision and seek to strengthen their work.  

SHPO's rebuttal, March 20 --  Click here.  The State Historic Preservation Office responded to Water Bureau's appeal.  They openly reject two assertions made by Water Bureau, undermining that appeal.

MTNA's initial appeal filing, Feb 27 --  Click here. Our first formal paperwork for the appeal; this makes us Appellant #2 in this case and gives us equal footing to Water Bureau in the appeal proceedings.  This form briefly cite's specific code failures.

Water Bureau's appeal filing, Feb 26 --  Click here. Water Bureau challenges essential elements of the approval conditions stipulated by the Historic Landmarks Commission; this move opened the appeal process and made Water Bureau Appellant #1.

Appeal Hearing Facts

  • Expect oral testimony to be strictly limited to 2 minutes.
  • Written testimony can be emailed into the record until May 27: CCTestimony@portlandoregon.gov


Sunday, March 1, 2015

Water Bureau Appeals HLC decision

We are disheartened to report that on February 26, the Portland Water Bureau (PWB) filed an appeal to overturn aspects of the decision rendered by the Historic Landmarks Commission (HLC) review. The PWB continues to resist their responsibility to care for Tabor’s historic resources, even going so far now as to oppose those mandates set forth by Portland’s respected Historic Landmarks Commissioners.    Specifically, Water Bureau objects to aspects of the requirement to keep water as a central feature at the site, and to the requirement to perform much needed historic-preservation work.  Contrast this with Water Bureau's response to directives from the Historic Landmarks Commissioners regarding the reservoirs in  Washington Park — at Washington Park's reservoir site, Water Bureau respected input from the HLC, they took a careful and holistic approach to the construction plan for the site, and they're providing water features and thoughtful historic preservation work there.  

MTNA has now entered an expensive appeal process, by which we hope to secure, again, deep water views and historic preservation-maintenance for Mt. Tabor's reservoir site.  Tabor's reservoirs need your financial support, today.

Donate Now!
What is Mt. Tabor Park worth to you?  What does it bring to your life and your routines?  How will your park experience be affected, if Tabor's anchoring  features are allowed to sit empty and crumble?  The historic reservoirs on Tabor are part of a captivating American story that marries ingenuity and beauty.  They provide the magnificent, deep-water views that are the hallmark of this Eastside, crown-jewel park.  Historic preservation specialists agree that this site's story is worth preserving.  We need your help to secure what is right for Mt. Tabor's historic site.

Please, sit down now and write  a check of any size.  It’s tax-deductible!  Every dollar counts.  If 100 people write $200 checks, we can meet our goal quickly.  If you can be one of those 100, please stretch yourself and help make it happen.  If not, just remember, every single dollar counts!

Make checks payable to “SE Uplift” and include “MTNA-reservoirs” in the memo line. 
Mail checks to:
SE Uplift
3534 SE Main St.
Portland, OR 97214

Monday, February 16, 2015

Reservoir debrief - HLC hearing #4, Decision

The Decision
At the fourth and final hearing before the Historic Landmarks Commission February 9th, the volunteer Commissioners continued to push for protections for Tabor’s historic resources.  A revised Staff Report was presented by BDS, with a new Approval Condition to mandate historic-preservation work for the reservoir structures.  While the language of this Approval Condition was not as specific (and therefore, not as easily enforceable) as we’d like it to be, its inclusion was a significant win.

A seventh commissioner joined the proceedings for the first time, and as it was immediately clear she would break the tie-vote in favor of an approval, the no-voters worked to strengthen the proposed Approval Conditions so as to afford the best protections available within this approval.  The Commission approved the Water Bureau application with significant Approval Conditions, you can see that decision here:  http://www.portlandoregon.gov/bds/article/519041  (the Approval Conditions are summarized on pages 30-31). 

Documentary filmmaker Brad Yazzolino offers his footage of the hearing here:  https://vimeo.com/119428556

While we have won significant improvements to this construction plan, the Approval Conditions in this decision do have two significant flaws.

1) A massive factual error, caused by BDS.  As the Commissioners tried to pen stronger Approval Conditions on the fly at the hearing, they asked BDS employee Hillary Adam to clarify what the record stated were the historic fill levels for these reservoirs.  Without referencing the actual case record, Adam incorrectly and inappropriately answered from memory that fill levels were between 50% and 75%.  In fact, the December 23, 2014 letter from Portland Water Bureau to the Historic Landmarks Commission specifically answers this question, it is Exhibit H-51 in the case record, and on page 3 this letter states the historic fill levels are between 65% and 85%. 

As the Historic Landmarks Commissioners clearly intended to include accurate historic fill-levels in their Approval Condition, and as the record provides the accurate data point, MTNA immediately raised this mistake with the Hearings Clerk at the hearing, citing the exhibit number.  The Hearings Clerk carried the error to the BDS employee running the hearing, Tim Heron, and he refused to bring the mistake forward to the floor.  MTNA again addressed the mistake with these BDS employees at the close of the hearing, and again in writing within a few hours of the hearing.  MTNA also alerted the Landmarks Commissioners to this mistake, and the Chair initially responded with confidence that the error could be corrected because their intention to quote accurate historic fill levels was clear.  Yet, the official decision was published 4 days later with the significant fill-level error.  This error should have, and could have been corrected by now. 

2) It’s missing quantifiable metrics.  The language in the Approval Criteria could be more specific, such that compliance was easy to verify.  We are concerned that the existing language will lead to future compliance and enforcement disputes.

Is it over yet?
Nope.  Your water bureau, funded by you, in service to your community, directed by a Commissioner you elected, opposes mandates to care for Tabor’s historic resources, even those mandates set forth by Portland’s respected Historic Landmarks Commissioners.  We are disheartened to report that there is a high likelihood the Portland Water Bureau will file an appeal to have those mandates overturned.  BUT, the decision to appeal is one the Water Bureau will make in concert with the Commissioner in charge = Nick Fish.  And Commissioners are politicians, and politicians notice when the community calls in.

You can help NOW!
We need 1,000 phone calls or emails to Nick Fish’s office between now and February 27th.  Have everyone in your house make a separate call!  Tell Nick Fish to direct the Portland Water Bureau to accept the Landmarks Commission decision from February 9th – “Do not appeal!”  Spread the word widely about this call campaign, and track progress by logging your calls here: https://docs.google.com/forms/d/15LHA5bxdIU0ghx2LxDKPjXOyHutMt0oPbwSbl53vjMM/viewform?usp=send_form                

Nick Fish’s office: 503-823-3589

And while you are at it, call Amanda Fritz’s office and urge her staff to fix the mistake BDS staff Hillary Adam made at the hearing on February 9th, which resulted in a factual error in the Approval Condition, regarding historic fill levels.  “Fix the fill numbers!” 

Amanda Fritz’s office: 503-823-3008

The reservoirs need your financial support!
While the volunteers at MTNA would prefer not to litigate this case through an appeal, we are committed to doing what is necessary to protect water as an essential feature for the Tabor site, and to secure preservation work and planning for Tabor’s historic resources.  If Portland Water Bureau continues to reject their duties as stewards of the public’s historic resources, and they appeal the HLC decision, we will enter an expensive appeal process.  Additionally, if we can’t get corrected through less-litigious means, that significant error BDS staffers made in the Approval Condition language (regarding the historic fill-levels of Tabor’s reservoirs), then we may have to litigate the point.  And, it is likely that the community will have to litigate to get any of the mandates enforced going forward.  It is time to raise money.  Send a check of any size, it’s tax-deductible!

Make checks payable to “SE Uplift” and include “MTNA-reservoirs” in the memo line . 
Mail checks to:
SE Uplift
3534 SE Main St.
Portland, OR 97214




Tuesday, February 3, 2015

Reservoir debrief - HLC hearing #3

On January 26, the Tabor Reservoir Disconnect project had its third public hearing in front of the Historic Landmarks Commission (HLC).  Documentary filmmaker Brad Yazzolino makes his full video of the hearing available here: http://vimeo.com/117979561

Deadlock vote
A year-long land use review for the Tabor Disconnect came to a head last week with a rare, deadlock vote before the volunteer Historic Landmarks Commission.  And here’s a twist: a seventh Commissioner, absent thus far for hearings, public testimony, and debate among the Commissioners, will be breaking that deadlock vote at a new hearing on February 9th. 

All of the six Commissioners involved thus far consider the application unacceptable as written by the Portland Water Bureau – they all found it needed Approval Conditions -- but three of the six found that even with Approval Conditions, the application failed to meet the legal requirements.  A motion before the Commissioners to support approval of the application with Approval Conditions failed in a 3-3 tie vote at the January 26th hearing.  Commissioners will return for another public hearing on February 9th to consider new motions with seven Commissioners.

Debate at the Jan 26 hearing before HLC
Commissioners who voted “no” shared the same complaint, that is, that the file did not contain enough evidence to support Water Bureau’s assertion that they can meet the Historic Resource Approval Criteria (this criteria establishes preservation standards for historic sites).  Commissioners had at other hearings requested the data they needed to vote in support of the application, and Water Bureau has not provided that data.  When further pressed at this hearing, Water Bureau asserted they would add no new information to the record.

When an application is found to lack evidence that the approval criteria will be met, the law offers the hearing body two options:  deny the application and send the applicant back to improve the proposal themselves, or take on the task of improving the application yourself by carefully writing Approval Conditions.  To see land use attorney Ty Wyman’s analysis of related case law, read Exhibit H-63 or click here.                  

Commissioners specifically cited enforcement difficulties that will arise due to the lack of evidence in the file.  MTNA shares this concern.  We’d like to avoid future compliance/enforcement disputes by setting transparent, quantifiable metrics within the Approval Conditions.  These metrics are currently not found in the Approval Conditions drafted by BDS.

Commissioners specifically cited a failure to meet approval criteria related to preserving character and reversibility.  MTNA shares these concerns.  We’d seek an additional Approval Condition that mandates a mitigation plan specific to preservation tasks, and we’ve advocated for the 2009 Mount Tabor Historic Structures Report to be rolled into this project timeline to serve as that mitigation work plan.  And again, we’d like quantifiable metrics tied to this action.  This Approval Condition was named as a minimum-to-move-forward by the “no” voting Commissioners at the Jan 26 hearing.

Commissioners specifically cited the lack of evidence regarding Water Bureau’s decision to cut and remove sections of pipe.  MTNA shares this concern, and directs interested parties to correspondence between attorney Steve Wax and City officials about this topic (Exhibits H-4 and H-130).  EPA does not require Portland to sever the open reservoirs from the drinking water system – EPA just requires PWB to stop serving water from them in December 2015.  The Oregon Health Authority does require PWB to sever the open reservoirs from the system, but NOT immediately.  As we’ve seen with Reservoir 6, a simple disconnection is allowed on a “temporary” basis – at Res 6 “temporary” has lasted 5 years.  PWB can stop serving water from the open reservoirs in December, using the same disconnection technology they’ve employed at Res 6 for the last 5 years, and be in compliance with the EPA rule.  They can also then wait until Jan 2017, when the EPA rule revision is published, before they move forward with the forceful severing work.  This strategy meets the EPA regulation and better protects the historic resources than what is proposed in the current application.  MTNA does not know of any Approval Condition that can address this failure of the application – the lack of evidence in the case file on this issue, and the possibility that their might be an alternative that better protects these resources, may give the Commissioners reason to deny the application.

If MTNA were still allowed to speak in this case, which we are not because the record closed on Jan 20, we’d advocate, at a minimum, for the following Approval Condition additions and changes (our additions to the existing BDS Staff Report added in red).

Condition B. Following completion of the disconnection, Reservoirs #1, #5, and #6 must continue to hold healthy, periodically refreshed water with fill levels maintained for each reservoir at 65%-85% of capacity (as per historic operational norm cited in Exhibit H-51). The reservoirs must be maintained and cleaned, and may be emptied (partially or fully) for brief periods, as necessary, to address system operational requirements, to maintain security, regulatory compliance, or for safety concerns. Any proposal to permanently remove visible water from the site, as required in the preceding sentence, will require a follow-up land use application to be reviewed by the Historic Landmarks Commission.

…

Condition E. Within two years of the effective approval date of this application, the following work shall be completed:
a.         all recommended work projects categorized as Short- and Long-term priorities in the 2009 Mount Tabor Reservoirs Historic Structures Report (Exhibit H-17b);
b.         an Implementation Plan addressing all recommended work projects prioritized as Maintenance in the 2009 Mount Tabor Reservoirs Historic Structures Report (Exhibit H-17b) will be written;
c.         all of the strip-mall lighting (as shown in Exhibit H-19, slides 3 and 4) shall be removed and replaced with historically appropriate fixtures (as shown in Exhibit H-19, slides 1 and 2) including, where they exist, restoration of the original historic light fixtures; and
d.         all paved pedestrian and bicycle paths within the boundary of the Mount Tabor Park Reservoir Historic District shall be repaired or replaced per City regulations enumerated in Title 17, Chapter 28.

As to tasks c. and d., the Mt. Tabor Neighborhood Association shall be notified before (1) publication of any RFP and (2) actual construction pursuant to such RFP.

Any fencing that has been in place for more than one year within the boundary of the Mount Tabor Park Reservoirs Historic District (for boundary see Exhibit A-1, pg 18) -- such as the existing chain link fence currently between reservoirs 5 and 6 (see Exhibit H-19, slides 8 and 9) – will be replaced with a historically sensitive alternative.

What Next?
Attend the February 9 hearing, at 1:30 pm (1900 SW 4th Ave, Room 2500A) to show support to the Historic Landmarks Commissioners.  They have been swimming upstream and could use to see the community support for protecting these historic resources.

MTNA members like myself see a path to put this case to rest today and avoid a lengthy appeal. However, our attempts to open that conversation with Portland Water Bureau have been rebuffed since December.  If Water Bureau continues to push this application forward without more evidence, or quantifiable Approval Conditions that make up for the lack of evidence, we are prepared for an appeal.

You can begin advocating NOW.  Call each City Council member (Nick Fish, Amanda Fritz, Steve Novick, Dan Saltzman, Mayor Charlie Hales) and promote 1) a delay to the pipe cutting and 2) stronger, quantifiable Approval Conditions that address preservation concerns.

Links:
Documentary filmmaker Brad Yazzolino’s video of the Jan 26th hearing is here: http://vimeo.com/117979561               

To see all written comments from MTNA to the Historic Landmarks Commission for this case, click here.                




Thursday, January 15, 2015

Reservoir debrief - HLC hearing #2

On January 12, 2015, the Tabor Reservoir disconnect project had its second Historic Resource Review hearing in front of the Historic Landmarks Commission (HLC).  Documentary filmmaker Brad Yazzolino has posted video of the 3 hour hearing here: https://vimeo.com/116833723

Water Bureau continued to resist including in their project documents, the preservation plans required by Oregon land use law.   If you’d like to see more about the Water Bureau’s failure to meet land use law with this proposal, see land use attorney Ty Wyman’s brief on this subject here.  Additionally, Water Bureau only addressed 6 of the 11 items about which the Historic Landmarks Commission previously requested more documentation.
                 
Without proper documentation (including preservation plans for the site), PWB’s application violates land use law, and if this proposal is allowed to move forward in its current state there is ground for an appeal to LUBA.  MTNA and other neighborhood groups are prepared for that possibility.  However, as the right path forward serves both the interests of the community and the interests of the law, we continue to hope the proposal will be amended by either the Water Bureau or the HLC.

The Historic Landmarks Commission was not satisfied with Water Bureau’s application, and these Commissioners did not make a decision at Monday’s hearing.  Because new information was introduced just before the hearing, the record is held open until 12 noon on January 20th to allow comment on that new information.  (To see the information in the record thus far, visit the HLC EFiles site linked below)

All of the comments received by noon on January 20th will be posted to the HLC’s Efiles site by January 21st (linked below).  Then, to allow comment on that new comment, the record will be held open until 12 noon on January 26th, at which time a new public hearing will happen.  There will be no public comment at this January 26th hearing.


Links:
For all documents submitted to the Historic Landmarks Commission in this case, visit the City’s EFiles site for this case: http://efiles.portlandoregon.gov/record/7060913        

For MTNA’s January 8th letter to HLC, responding to the Dec 1st hearing and the Dec 23rd document from Water Bureau, follow this link: http://mtna-landuse.blogspot.com/2014/11/hlc-comments.html   

For a debrief on the first hearing on December 1st, 2014; follow this link:



Wednesday, December 10, 2014

SIGN THE PETITION! (to protect park and reservoirs)

To see and sign, click here:
https://docs.google.com/forms/d/1hagzRy2Ko3ZNdHNsZTUDkg6lnrCSPobARGBWfEveEuY/viewform?usp=send_form


Petition: Protect Mt. Tabor’s Historic Park and Historic Reservoirs

We the undersigned request authorities with Oregon’s State Historic Preservation Office (SHPO) and with Portland’s Historic Landmarks Commission (HLC), help the community protect the nationally recognized historic resources on Mt. Tabor, which include the nationally registered Historic Mount Tabor Park and the nationally registered Mount Tabor Reservoir Historic District.

We the undersigned value this Historic Park and these Historic Reservoir features central to that park, for the American story they preserve and for the functional-beauty they bring to the lives of every Portlander.

We the undersigned fully support the comments and requests made to your respective bodies by the Mt. Tabor Neighborhood Association in November 2014, regarding the proposal to disconnect the historic reservoirs from Portland’s drinking water system.  We find this proposal will seriously impact the historic reservoir assets, as well as the historic park within which these reservoirs sit.

We the undersigned make the following requests to SHPO and to HLC:

1) Please provide rigorous process and outside oversight of the plan to disconnect the reservoirs from Portland’s drinking water system;
2) Please take all actions available to protect the historic character, aesthetic and record of use of the entire Tabor site;
3) Please mandate water as a feature central to any future-use of the historic site;
4) Please honor the preservation ethic of reversibility, by scrutinizing this disconnection plan for every avenue by which it could be made more affordably reversible;
6) Please use all measures available to ensure good preservation planning and preservation funding for this site going forward.

(The Mt. Tabor Neighborhood Association continues to maintain that this disconnection is unnecessary.  However, we have involved ourselves in the disconnection construction planning process to ensure that plan is respectful of the historic reservoirs and the historic park.  We find the disconnection proposal as written flawed.  MTNA comments to HLC are available here: http://www.mtna-landuse.blogspot.com/2014/11/hlc-comments.html .   MTNA’s comments to SHPO are available here: http://www.mtna-landuse.blogspot.com/2014/11/tabor-disconnect-letter-to-shpo.html .)

Friday, December 5, 2014

Reservoir Debrief - public hearing before the Historic Landmarks Commission

On Monday, Dec 1, the Tabor Disconnect construction project had it's Historic Resources land use review at a public hearing in front of the Historic Landmarks Commission.  It was a long but productive day (many of us were there for the full 6 hour hearing session).

The volunteers that sit on the Historic Landmarks Commission are professionals with historic preservation specialties within their respective fields.  They asked the kinds of questions MTNA hoped they would ask, and they asked for more detail on many of the same issues about which MTNA would like more detail.  They delayed their decision until a future hearing on Jan 12, 2012, so that they could 1) hear from stakeholders and 2) gather more data.  Water Bureau is to supply the HLC with the requested data before the Christmas break, likely around Dec 23.  

Additional data requested by HLC:
  • Comments from the State Historic Preservation Office (SHPO), now reviewing this case
  • City Council's "future-use" plan decision
  • A look at the City's legacy plans for the reservoir assets (roles, responsibilities)
  • Cost estimate, scope of work for reversing the disconnection
  • A formal review of site by a professional geo-archeologist
  • Yearly cost to keep reservoirs between .5 and .75 full (normal fill range is .5 to .75)
  • Yearly cost for functional-maintenance at the reservoirs
  • Cost to complete deferred preservation-maintenance listed in the 2009 Mt. Tabor Historic Structures Report
  • An analysis of the current "Use Determination," if it is still valid given the changes at the site.  They wanted to hear from the City Attorney and BDS on this point.
Many items in the HLC case file are available online, including the staff report from BDS, visual aids used in presentations given at the hearing, and an audio file of the hearing: http://efiles.portlandoregon.gov/record/7060913

Documentary filmmaker Brad Yazzolino has made video footage of the hearing available here: https://vimeo.com/113709479

For time/date of the next public hearing, see HLC agendas here: http://www.portlandoregon.gov/bds/42443

Next Steps
Next steps just got a little confusing, since Portland Commissioners Fish and Fritz decided to postpone their future-use plan announcement scheduled for Dec 10.  The Historic Landmarks Commissioners want to see the Parks/Water Bureau future-use plan, before HLC makes their decision; Fish and Fritz now want to wait for HLC's decision in the land use case before they announce their future-use proposal.

MTNA will make our concerns about this project known to the State Historic Preservation Office, and work for more involvement from them.   I encourage others to advocate for the conditions and mandates found in MTNA comments on this case (you can read our comments here:  http://www.mtna-landuse.blogspot.com/2014/11/hlc-comments.html ).  Advocate by signing the petition!!! Go here:  https://docs.google.com/forms/d/1hagzRy2Ko3ZNdHNsZTUDkg6lnrCSPobARGBWfEveEuY/viewform?usp=send_form

Monday, November 17, 2014

HLC comments

Comments for Case File # LU14-218444 HR EN
January 26, 2015 - to read a debrief from the hearing this date, click here.

January 20, 2015 - MTNA's third set of comments submitted to the Historic Landmarks Commission (following the January 12th hearing and the Jan 8-12 documents submitted by Portland Water Bureau) are available by clicking here.

January 12, 2015 - To read a debrief from the hearing this date, click here. 

January 8, 2015 - MTNA's second set of comments submitted to the Historic Landmarks Commission (following the December 1st hearing and the December 23rd document from Portland Water Bureau) are available by clicking here.

January 7, 2015 - land use attorney Ty Wyman addresses the legal failures of this application from Water Bureau, and cites case law.  Click here.

December 1, 2014 - To read a debrief from the Dec 1, public hearing in front of the Historic Landmarks Commission click here.

November 20, 2014 - MTNA's first set of comments submitted to BDS and the Historic Landmarks Commission regarding the Tabor Disconnect are available by clicking here.