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.

Tabor Reservoir Disconnect - Water source for reservoirs

With our first overview of the construction plans, we aren't seeing an adequate water supply for a water feature at the reservoirs during or after Tabor Disconnect work.  The project's narrative states very clearly: "all inlets...will be capped."  When we stated so at our neighborhood meeting on Wednesday, Feb 19, Water Bureau staffers Tom Carter and Tim Hall asserted there would be water available to the reservoirs. Meeting attendees asked me to confirm the accuracy of that assertion and the adequacy of the supply to which Carter and Hall vaguely alluded.  These are big reservoirs, and we can't just fill them with a garden hose.  So, how does Water Bureau define water?  I'm trying to get that answered, but as of today my inquiry goes completely unacknowledged (5 days and counting).  Update 4-1-14: I still cannot confirm there will be adequate water for the reservoirs post-disconnect.

Here is what I asked Teresa Elliot and Tom Carter by email at 11am on Feb 20:

1. How will water be provided to the reservoirs during disconnect construction?
2. How will water be provided to the reservoirs after disconnect construction?
3. Does Water Bureau currently plan to have water in 1, 5 and 6 during disconnect construction?  If so, how much?
4. Does Water Bureau currently plan to have water in 1, 5 and 6 after disconnect construction?  If so, how much?

Here are the answers Tom Carter sent on Feb 25: 

None of the specifics I asked for were addressed in Carter's response.  The devil is in the details, and PWB is letting us see them yet.  Here is most of Carter's email to me:

In answer to your questions, it’s necessary to drain the reservoirs and keep them empty while we are doing the proposed work. Otherwise, we’d either be working underwater or cutting open pipes full of water. 

When we are finished, the reservoirs will able to be re-filled with pipes that are connected to the water supply system (that is, water coming from Bull Run). They’ll be drained by pipes leading to the sewer system, the same as they are today. And finally, they will be cleaned by the existing wash down system pipes, which are not affected by this project. These connections will be better illustrated in our plans when we apply for the Type III Land Use Review.

The reservoirs will be able to be filled and maintained as City Council directs.

Here are my follow-up questions, seeking more details, sent on Feb 25:

Hello Tom -

Thanks for your response.  I have further questions.  

1. Specifically, please detail the fill-rate of the remaining water source for each reservoir, and compare that to the fill-rate of the current water source for each reservoir.  This information is needed to adequately answer questions in the community.
2. Do you have a schedule for when each reservoir will be drained during construction?  Will they all drain at once, or will they be staggered according to specific work?
3. Do you have a schedule or goal for post-construction re-filling of the reservoirs?

UPDATE April 1: the above questions have not been acknowledged or answered by PWB staff.

Tabor Reservoir Disconnect - Trees being cut

You may have heard by now that as we comb through the Water Bureau's preliminary construction plans, we've spotted many more trees being cut than were mentioned in the publicly issued "Notice". That Notice only mentions one, 24" tree.  We count 81 trees being impacted all together, with 31 trees being cut down and 50 more trees at risk because of work done within their root zone.  You can see the index we've put together by tree number by clicking here.

Tabor Reservoir Disconnect land use cases

The paperwork for disconnecting the Mt. Tabor open reservoirs from the drinking water supply arrived on January 28, 2014 (postmarked Jan 27).  Two, complicated land use reviews are happening at once under case titles: LU 13-236792HR (this is for the Historic Resource Review) and LU 13-240530EN (this is for the Environmental Review).

Click here for the "Notice" from the city.
Click here for "Revised Notice" from 2-14-14
Click here for the plan drawings we obtained.
Click here for the Dec 2013 application narrative we obtained (this doc request took 5 days for PWB to fill).
Click here for the budget (still awaiting document request, 13 days and counting).
Click here for specific approval criteria for Historic Resources review.
Click here for specific approval criteria for Environmental review.

Public meeting
Feb 19, 7 pm:  Water Bureau did not involve our neighborhood in the process of planning this project. Our first notice came on Jan 28.  Water Bureau has done no outreach in our neighborhood regarding this project.  Volunteers with MTNA are pouring through plans and documents now, and discovering this project will indeed have significant impact on park neighbors and users.  At MTNA's regularly scheduled meeting Wednesday, Feb 19th, we will share project drawings and walk meeting attendees through the various disruptions.  Meetings are in the basement of the Mt. Tabor Presbyterian church on the corner of SE 55th and SE Belmont, from 7 - 9 pm.

Public Comment Period
While we were supposed to be given 21 days for public comments, inexplicably, we are only being given 17 days.  Only 13 of those are business days during which we can get documents from city offices, and with storm related closures our public comment period has been whittled down to just 10 business days.  Unless we succeed in our appeal for a longer public comment period, your comments are due to BDS by Friday, Feb 14, at 5:00pm.  Update 2-12-14:  Our appeal was answered by Fish and Fritz's office, we have secured an extension until March 10, 2014 (three extra weeks).  Click here to read the email correspondence for this request.

Challenging the Type II classification
We take issue with the Type II classification this case was given, and believe the facts warrant a Type III classification.  A Type III classification would require Water Bureau to more broadly distribute notice of this project (informing more neighbors) and it would involve the Historic Landmarks Commission at a sooner point in the review process (providing better oversight for this historically sensitive area).  At this point, people immediately effected by this work only know it is happening because neighborhood volunteers are doing outreach.  Update 2-17-14: Tonight we emailed an appeal to Commissioners Fish and Fritz making the case for why this project should have been given a Type III procedure.  Click here to read our argument.  We ask everyone to contact the offices of Commissioners Fritz and Fish, encouraging them to support our request for a Type III classification. Update 2-18-14: At 6pm today we heard from Commissioner Fish that this land use case will be reclassified as a Type III review = good news!  To read the Commissioner's email click here.

MTNA's official comments
MTNA's official comments will be posted here once submitted.  I will write MTNA's official comments for this case, along with a team of neighborhood stakeholders which have agreed to serve as Land Use Committee members and consultants.  They are Dawn Smallman, Kim Lakin, and Mark Bartlett.  If you have particular expertise in land use we could use your help.  We are especially in need of experts in land-use law, and historic landscaping preservation.  All Portlanders have a right to submit comments to hillary.adam@portlandoregon.gov and stacey.castleberry@portlandoregon.gov by March 10.

Other Important Documents:

• National Historic Registration listing for the reservoirs, "Mount Tabor Park Reservoirs Historic District"
• National Historic Registration listing for the park, "Historic Mount Tabor Park" 
• Mt. Tabor is home to multiple protected views, registered in the City Scenic Views Protection plans.  Here is one early listing from the 1988 Scenic Views inventory.

The History of the "What Goes On Top" discussion

You've heard the rhetoric, you're looking at the reservoirs, and now your wondering what happens to this park if we loose the good fight?

Some people have even started to panic, and they are pushing to jump into the discussion about what goes on top because they fear they'll get left out of it.  I assert, this is a very bad decision.  There are STILL viable options that the City absolutely will not bother to work on if they think they can get away with just moving forward with destruction.  And diverting community energy to the what goes on top process will absolutely shut down any other forward motion.

Remember, we've been here before, we had the "what goes on top" public process in 2002.  A design competition was held, beautiful drawings were made, cost estimates were higher than any available budget, and doesn't this sound like a loop?  We don't need to pay for another set of planners and another set of plans.

I will post 2002 DESIGN IMAGES HERE when I find them.  For now, you can reference a blog post on Jack's Blog from 2003.

A Tale of Two Cities' LT2 Victories

and Missed Opportunities

Portlander’s learned this week, from documents obtained directly from the City of Rochester, NY, that Rochester has won a reprieve from LT2 open reservoir requirements.  This reprieve may very well prove to save their reservoirs and their ratepayers millions in needless spending.  But that’s not all we can learn from Rochester.  A look at Rochester’s path to this point highlights how Portland may have missed some meaningful opportunities to do more.

The city of Rochester has three open reservoirs – totaling 233 million gallons --  that fall under the LT2 requirement to “further treat or cover.”  (Portland has five open reservoirs, totaling 170 million gallons.)  The Rochester website nicely summarizes how that city evolved its approach to LT2 compliance for their three reservoirs, stating their goal as this: to “achieve technical compliance at an affordable cost.” (#1)

The original plan was to cover one reservoir with a floating plastic cover, just like citizens proposed here in August; this cover (plus associated work and a liner) would cost Rochester $11 million.  Four members of Portland’s City Council rejected the August proposal for a floating-covers compliance plan (it was supported by Commissioner Fritz).  Based on what Rochester is paying, the floating covers plan likely would have cost Portland an estimated $25 million, netting ratepayers over $100 million in savings.

Rochester planned a different approach for the other two reservoirs named Cobbs Hill and Highland.  Cobbs Hill Reservoir holds 144 million gallons, Highland holds 26 million gallons, and both are imbedded in parks in urban settings similarly to our Mt. Tabor and Washington Park reservoirs.  (For comparison, see Portland’s reservoir sizes in the endnotes.)  Operating under the impression that the “further treat” option in the rule was impossible because it would be too expensive and it would require a large plant in a historic park, the city originally planned to “cover” or build new tanks to replace the 170 million gallons served by Cobbs Hill and Highland reservoirs.  Their replacement reservoirs would cost them $29 million dollars.  Our Water Bureau also seemed to operate under this too-big-too-expensive assumption and thus dismissed the UV option seemingly without any formal data collection.  Instead they planned to replace Portland’s 132 million gallons of open reservoirs with 75 million gallons of new buried tanks.  This plan is estimated by PWB to cost us $400 million.  (Rochester appears to be getting new water storage for $1.45 a gallon, while Portland is paying $2.65 a gallon.)

In 2009 the citizens of Rochester pushed back against the plan to spend millions of dollars on projects that provide their city no benefit.  And remember, they were going to spend 1/10th of what the Portland Water Bureau wants to spend.  The citizen outcry in Rochester (matched by a similar outcry in Portland) was met with positive action and the Rochester water guys went back to the drawing board to come up with more options.  It turns out they examined 125 different compliance options in one study alone.   The Portland Water Bureau has never laid out a suite of compliance options for the city to choose from.  In fact, since 2009 they have steadfastly insisted there is only one option = spend and build.  Rochester discovered that their first assumption about UV’s cost and size was wrong, and that they could fit mini-Ultraviolet reactors into the historic gatehouses at the reservoirs –-- these are 24” UV reactors set in line to treat the water as it leaves the reservoir, reaching a treatment capacity of as much as 100 million gallons in the case of the Cobbs Hill reservoir. (#2)

When local large businesses requested a look at PWB’s detailed analysis of the micro-treatment option, they were provided three non-technical paragraphs (#3).  Inquiries for the specific study of the UV option are always met with vague facts that don’t seem to inform the discussion.  For instance, PWB starts all responses with a quote that Rochester has fewer citizens.  True, but they have larger open reservoirs with more water needing to be treated.  They state that Portland’s chemical cocktail is different than Rochester’s, and that ours would necessitate a “larger” facility.  They follow this statement with different assertions in different publications.  In one, PWB claims a UV plant at the reservoirs would necessitate a building spanning 5 acres.  Without access to the specific technical study that would draw this conclusion it is difficult to see how Rochester could build 24 inch treatment facilities while Portland would need a 5 acre plant.  It seems as though PWB may be stubbornly standing by their first assumption, digging in their heels in favor of staying the course.

Rochester’s second plan scrapped the buried tanks in favor of building UV reactors and this cut the city’s LT2 compliance bill in half.  They asked for and were granted a plan revision with the EPA in 2009, and another in 2010.  In 2009 citizens and businesses in Portland had to fight the Water Bureau to accept a compliance plan that would save ratepayers $200 million dollars on the source water side of the Rule.  Leonard and Water Bureau staff reluctantly conceded defeat in the face of vanishing Commissioner support, and the most expensive Bull Run treatment plant option (chemical filtration) was thrown out in favor of the cheaper Bull Run treatment plant option (UV filtration).  Unlike in Rochester, no conciliation happened on the open reservoir side of the rule, despite the public outcry here in Portland.  Portland’s Water Bureau has held fast that nothing else will bring compliance, that Portland must spend big and build big.

Still not satisfied that limited public resources were being properly respected by the LT2 Rule, Rochester’s Mayor stuck out his neck and wrote a letter to the EPA in September of 2011.  He said, “this regulation imposes expenditures that are too onerous and benefits that are, at best, difficult to measure …  the City needs to make major investments in its aging infrastructure by implementing already identified system upgrades with clearly quantifiable benefits…”  Our mayor could have written those very words, but he did not write the EPA on behalf of Portland in 2011 or ever.

Rochester got a response from Nancy Stoner, EPA's Acting Assistant Administrator for Water, and they recognized that in her phrasing Stoner was clearly opening a door and guiding their argument.  Stoner wrote “… there may be specific, articulable facts that warrant compliance schedule adjustments.  Many public water systems face multiple challenges in managing, maintaining and operating those systems.  Infrastructure construction projects can also present challenges.  It is entirely appropriate for primacy agencies to consider these system specific facts when evaluating a request to adjust a compliance schedule.  If a schedule adjustment is appropriate, the public water system should have in place robust interim measures to ensure public health protection…”

Rochester took her lead.  Their argument focused on “articulable facts” like maintenance and operating challenges.  They argued the Rule is overly burdensome financially.  The Portland Water Bureau has always claimed that the EPA would not look at budgetary constraints when considering timeline or compliance options (they appear to be wrong).   Rochester made a request for a compliance schedule delay to New York’s version of the Oregon Health Authority and in that request they  spent a respectable amount of space talking about the “robust measures” they have in place that have historically ensured their city safe drinking water (i.e. security equipment, bird wires, etc).  Our Water Bureau’s request for a delay to the Oregon Health Authority mentioned our “robust” measures mostly in the foot notes.  The Portland Water Bureau’s proposal for a delay didn’t look like Rochester’s proposal and it didn’t win approval like Rochester’s did.  In fact, OHA’s response to the Portland Water Bureau seemed to all but beg them for a more solid argument.  Interestingly, the Portland Water Bureau met with officials from Rochester’s water bureau after Rochester won their reprieve.  One must question why it is Portland’s request did not more closely mimic Rochester’s winning model when it most surely could have been at their disposal.

Since OHA’s June 2012 denial of this city’s plea for a time-out in reservoir projects, Commissioner Fritz (in collaboration with State Rep. Alissa-Keny Guyer and stakeholder groups) has asked Commissioner Leonard to direct the Portland Water Bureau to file another proposal, with more substantial data included in it.  Leonard has refused to file again, his most notable refusal was point blank and it happened when Commissioner Fritz publicly pressed him at a Council Work Session in July.

Endnotes:
#1 http://www.cityofrochester.gov/article.aspx?id=8589937472
#2 a power point slide show from the City of Rochester entitled “Reservoir Study”.  March 18, 2010.
#3  http://tinyurl.com/4szgfq9

Portland Open Reservoirs in millions of gallons:
Tabor 1 = 12 million
Tabor 5 = 49 million
Tabor 6 = 75 million
Washington Park 3 = 16.4
Washington Park 4 = 17.6
Total = 170 million gallons

Rochester's Open Reservoirs in millions of gallons:
Rush Reservoir = 63 million
Cobbs Hill Reservoir = 144 million
Highland Reservoir = 26 million
Total = 233 million gallons

Testimony at Council Hearing Sept 5, 2012

For the Record, Agenda Item 997 - September 5, 2012

Today I voice a position supported by the full MTNA by unanimous vote at our neighborhood meeting last month.

Hypalon-like covers are one of EPA’s approved methods of LT2 compliance.  They are cheaper and they make us fully compliant. 

At this moment it is Common Sense vs. Over Engineering.  It is Preservation vs. New Construction.  Always before, in the LT2 conversation you’ve been forced to align yourselves counter to Portland’s culture.  You’ve had to choose Over Engineering and New Construction when what you’ve wanted was Common Sense and Preservation.

But not anymore.  There is no reason to continue on with Kelly Butte, or any other part of PWB’s current compliance plan for LT2.  You have a new option, one that’s not been on the table before.  The groups that have opposed this option in the past, support it today.  Business, public health, environmental, equity, and neighborhood groups are all on board.  The groups that oppose your current compliance plan SUPPORT this plan.  Even the groups that have opposed compliance on principle, SUPPORT this plan.


We ask you to reject Water Bureau’s attempts to muddle the conversation at the last minute with untested claims that these structures are unsafe and too old.   These are tired arguments, they’ve been addressed before in other forums and we can address them again if the community so desires.

LT2 is a Federal beast that has stripped us of local power.  We dare not mix into our relationship with LT2  any other project, or we unnecessarily hand over local control of those issues too.  Every other, non-LT2 project should be staged, costs and approach, in a way that best suits our community without the LT2 gun to our heads.

MTNA supports a change in our compliance plan to include Hypalon-like covers.

Letter Wins Sweeping Community Support

August 8, 2012
(updated Sept 5, 2012 with new signatories)

Mayor Adams and Commissioners
1221 SW 4th Avenue
Portland, OR 97204

Dear Mayor Adams and Commissioners,

We support a change to the City's LT2 compliance strategy for open reservoirs. We support the City submitting to the Oregon Health Authority a new reservoir compliance strategy which involves Hypalon-like covers at Reservoirs 1 and 5 (Mt. Tabor) and Reservoirs 3 and 4 (Washington Park).

We support this Hypalon-like, cover compliance strategy because it protects the recent $40 million ratepayer investment in open reservoir upgrades and would provide the greatest opportunity for Portland to benefit from the LT2 rule revision process currently underway. This is the only option that preserves the functionality of our historic open reservoirs. This option also provides the best opportunity for the Mayor and Commissioners to actively engage in discussions with our federal representatives to secure permanent relief from onerous LT2 requirements for Portland's open reservoirs and our Bull Run source water.

This new Hypalon-like cover compliance strategy will save ratepayers upwards of $138 million in the near term and much more in the long term when debt service is considered.
Please connect community will to LT2 compliance strategies.

Sincerely,

Stephanie Stewart for Mt. Tabor Neighborhood Association                                       
Jeff Boly for Arlington Heights Neighborhood Association

 

Further Supported By:

Floy Jones for Friends of the Reservoirs

Peter Stark and Barbara Schwartz - Members, Hillside Neighborhood Association Board

Regna Merritt for Oregon Physicians for Social Responsibility

Kent Craford for Portland Water Users Coalition Members:

   ALSCO, American Linen Division
   American Property Management
   Ashland Hercules Water Technologies
   The Benson Hotel
   BOMA Portland
   Darigold
   Harsch Investment
   The Hilton Portland and Executive Tower
   Mt. Hood Solutions
   New System Laundry
   Portland Bottling
   SAPA Inc.
   Siltronic Corp.
   Sunshine Dairy Foods
   Vigor Industrial
   Widmer Brothers Brewing
   YoCream

Juliana Lukasik for Central Eastside Industrial Council
Portland Business Alliance
Mayor’s Small Business Advisory Committee
Thomas T. Ward, M.D.
Alissa Keny-Guyer, State Rep District 46
Bob Sallinger for Audubon Society of Portland
Sean Stevens for Oregon Wild
Olivia Schmidt for BARK
Maxine Wilkins & Michael Meo for Eastside Democratic Club
David Delk for Alliance for Democracy
Julie DeGraw for Food & Water Watch
Ron Carley for Coalition for a Livable Future
Andy Maggi for Oregon League of Conservation Voters

Anne Dufay for SE Uplift Neighborhood Coalition:
   North Tabor Neighborhood Association
   Mount Tabor Neighborhood Association
   Montavilla Neighborhood Association
   Sunnyside Neighborhood Association
   Buckman Neighborhood Association
   Hosford Abernathy Neighborhood Association
   Richmond Neighborhood Association
   South Tabor Neighborhood Association
   Foster Powell Neighborhood Association
   Creston - Kenilworth Neighborhood Association
   Brooklyn Neighborhood Association
   Reed Neighborhood Association
   Eastmoreland Neighborhood Association
   Sellwood Moreland Neighborhood Association
   Woodstock Neighborhood Association
   Mount Scott Arleta Neighborhood Association
   Brentwood Darlington Neighborhood Association
   Ardenwald - Johnson Creek Neighborhood Association
   Kerns Neighborhood Association
   Laurelhurst Neighborhood Association

Scott Fernandez for Citizens for Portland's Water
Franklin Gearhart for   Citizens Interested in Bull Run, Inc.               
Nancy Newell for Oregon Green Energy Coalition

Watchdogs worth watching

A new group formed this Fall, and they plan to spotlight wasteful (to the point of illegal) spending by the utlity bureaus.  Interestingly, this group's research and commitment is largely an outgrowth of the movement to protect our water system from a wasteful and useless federal regulation called LT2.  The very well read citizens who have for years combed through Water Bureau documents related to water safety and LT2, have in the process earned an honorary degree in local Water Bureau politics and budgeting practices.  The best read citizens can shock you with what they've found. 

It is a group worth watching: www.waterreform.blogspot.com

Join Senator Schumer. Pretty please.

Early this summer, Mayor Blumberg of New York City blasted the EPA for failing to reform the reservoir mandate, known as LT2, even after an Executive Order directed EPA to evaluate the cost and burden of its regulations. The Wall Street Journal reported on this letter from Blumberg’s office to EPA in an article titled “City Lashes Out at EPA” (read it here).

On July 20, Senator Charles Schumer of New York ardently criticized the senselessness of LT2, its costs, and its public health value as he called on the EPA to urgently reform this piece of regulation. You can see the letter he sent the EPA, and the press release around that letter here.  A quote from Senator Schumer, about the mandate to cover reservoirs:

New Yorkers have seen their water bills rise year after year after year, and the last thing they should be forced to do is pay more for a hugely expensive, questionable project when more cost-effective alternatives exist. While we must ensure that our city’s water supply remains pure, there is more than one way to skin this cat, and the EPA’s rigidity here would impose an unnecessary burden on New York City rate payers without improving public health in a significant way.

The coalition of businesses, public health leaders, environmental advocates, and neighborhood associations that joined together this year to press local officials for a logical approach to LT2 compliance, has now written a letter to Senator Wyden calling on our Congressional delegation to join Senator Schumer in his efforts to secure reform to this unnecessary mandate... when this letter is public, I'll link to it.

Actions
Concerned citizens are encouraged to contact their Congressional delegations this week; press them to follow suit supporting Schumer's efforts at LT2 reform.  It could save us.

Senator Ron Wyden:
Portland phone: 503-326-7525
DC phone: 202-224-5244
DC Fax: 202-228-2717
Online form: http://wyden.senate.gov/contact/

Senator Jeff Merkley:
Portland Phone: 503-326-3386
Portland Fax: 503-326-2900
DC Phone: 202-224-3753
DC Fax: 202-228-3997
Online form: http://merkley.senate.gov/contact/

Representative Earl Blumenauer:
Portland Phone: 503-231-2300
Portland Fax: 503-230-5413
DC Phone: 202-225-4811
DC Fax: 202-225-8941
Online form: https://forms.house.gov/blumenauer/webforms/issue_subscribe.html

Convincing the Public

We have a water bureau administrator that doesn’t feel the need to conserve public dollars as acutely as he should. Shaff’s response to drain the reservoir was an overreaction that he himself admitted was not scientifically inspired but rather based on something he called, “the yuck factor.” This characterization is unprofessional, irresponsible, and frankly, almost unbelievable coming from a bureau director charged with managing a resource whose management is supposed to be wholly based in science. The water bureau has seized an opportunity to play on unfounded fears that will help them gain public support for unnecessary and expensive reservoir burial projects.

Several public health professionals, including one from OSU have made clear statements that there really is no public health impact from 6-8 ounces of an unwanted fluid landing in 7.8 million gallons of water. From what I saw of the surveillance video (in news reports online) it looked like the water level was low, low enough that the urine would have landed on the wall, not anywhere near the water (and likely it evaporated). It is my belief that this was a non-story, and a non-public health issue made into one to suit the PR plan.

It is now or never

Indeed, it's D Day tomorrow.  Make your voices heard.  Council must refuse item #532 and item #537 on the Council agenda Wednesday, or it will be hardly worth turning back.  Don't spend another dime, until you give the state Drinking Water Program a CHANCE to accept the variance applications for the reservoirs and the watershed treatment plant.  Don't.

Hell does not have to freeze over

Over 100 people turned out for Wednesday morning's water rate hearing, which ran over its allotted 30 minutes by almost 5 hours. Forty-five people signed up to speak on behalf of protecting our open reservoirs from senseless LT2 projects, including Siltronics, Portland Bottling Co., Yo Cream, Alsco Linen, and Physicians for Social Responsibility.

KBOO's Joe Meyer ran a 4 minute piece which holds several interesting quotes from Fritz, Saltzman, and Adams (they begin at minute 2:45). But if there is one thing I absolutely don't want you to miss it's the quote from Dave Wagner, formerly of EPA's Office of General Council, stating there is a legal path to both a variance and a timeline extension for the reservoirs (minute 1:52). It seems Hell does not have to freeze over, as Shaff has claimed.

Testimony brought out at least two new points worth passing along to all of your friends. 

Most importantly, there is a NEW legal opinion now in our possession (many thanks to the Portland Water User's Coalition) from Dave Wagner of Reed Smith (a large firm specializing in regulatory issues, including EPA regulation).  Wagner's expertise was brought in to review Portland's legal options for saving our reservoirs, because concerned citizens in the business community thought this moment in our city's history called for action more robust than what the city was willing to do on their own.  Not to put too fine a point on it, but this really does seem like the kind of homework the city bureau should have done by now on our behalf. 

Secondly, just in case you were still wondering if Portland Water Bureau had their heart in this fight to save our city from senseless LT2 expenditures...   Just last month at the invitation of the EPA (and by Executive Order), PWB had the chance to comment on specific regulatory flaws found in LT2 and other EPA regulations, and from what I can tell PWB submitted just a few disjointed paragraphs in which only 3 sentences were dedicated to LT2.  Compare that with NYC’s response to this invitation – they submitted a 23 page argument with 33 pages in supporting data about their Hillview Reservoir.  That’s what committment looks like.

Wow.

KBOO's Joe Meyer ran a piece on LT2 and the open reservoirs this week titled Open Reservoirs and Government.  It contains a number of good interviews with Dr. Gary Oxman (county health), Dr. Thomas Ward (an infectious disease specialist), Kent Craford (business - Portland Water Users Coalition) and Floy Jones (Friends of the Reservoirs).  You can even hear Joe Glicker's voice (ex-PWB employee turned cozy consultant; he has profited hardily off of LT2). 

While I hope lots of people will listen to the whole thing, I have two highlights that actually leave me a little speechless.

Minute 36 - Dave Leland with the state Drinking Water Program indicates that his organization has jurisdiction over the LT2 issue now and that it is within their authority to grant a deadline extension, but PWB would have to ask first.

Minute 6.29 - Dr. Gary Oxman with Multnomah County Health, indicates he does not expect to see any reduction in disease incidence with the new reservoirs because they aren't seeing any disease incidence now (in other words, they can't get any cleaner than clean).

Shaff is talking out both sides of his mouth...

How do you keep your customers convinced they are getting the purest water in the world all the while convincing them they need to spend billions of dollars to improve it? By pretending your hands are tied. Let me put the finest point on this: PWB has not done everything it can and should do to legally avoid construction of mind-bogglingly expensive projects we don't need.

In March of 2009 I directly asked EPA for the deadline to cover reservoirs. EPA replied quiet clearly: the rule doesn't name a deadline, each city sets their own deadline. Our water bureau negotiated a fast-tracked compliance schedule and handed it to EPA in March 2009 with only 24 hours notice to City Council. PWB does not want to save us money, they want to grow the bureau on our backs.

While PWB was gearing up to party with their consulting buddies, NYC was diligently compiling data and building a case to argue for an extension on the deadlines. To anyone that has read the NYC documents, it is clear that they plan to leverage their research into an alternative to unnecessary projects. They haven't just won a delay, they've won.

PWB hasn't put forth the kind of effort you or I would put into finding a legal alternative. My uncle used to say, when it comes to breakfast the hen, she is involved, but the pig, the pig is committed. PWB's acting like a bunch of chickens at a time when what we need is something more akin to a boar.

Portland Water Bureau still spending, now to disconnect Tabor

If you haven’t kept up with the flurry of reporting about our drinking water, the fate of our reservoirs, or questionable Water Bureau spending… visit the “Press Room” page of www.foresttofaucetpdx.blogspot.com for a fairly comprehensive list of links to the latest reads across media outlets.

The Community Ask
A broad range of community and business leaders are supporting the letter written by Oregon Physicians for Social Responsibility (dated March 10, 2011, read it here) which requests Commissioners immediately intervene to delay LT2 projects. The list of signed supporters grows daily, and at this point includes organizations like the Portland Business Alliance, Widmer, Sierra Club, Oregon Small Business Association, and the Oregon League of Conservation Voters. Watch this list grow by clicking here.

As of yet, Council hasn’t taken any action to slow LT2 spending or to follow New York City’s lead and ask for a delay in deadlines.

Disconnecting Tabor
Despite the recent groundswell of community and business support for a time-out on LT2 projects, Portland Water Bureau is still spending money. Just a few weeks ago Water Bureau selected a contractor to disconnect the Mt. Tabor reservoirs -- a project estimated to cost $500,000 that will likely go before City Council sometime in the next six weeks. You’ll note that this half-a-million dollar project to shut off the Tabor reservoirs comes shortly on the heels of another contract wrapping up millions of dollars in reservoir “upgrades.” If you’d like to see a description of this disconnect project, read the Request For Proposal here (especially page 2 “Part I, Section A, 2. Background”).

A Rally – this coming Friday
The word is several stakeholder groups are calling for a rally in front of City Hall this Friday over lunch. Show up and inspire Commissioners to get moving on the Community Ask. April 22, 12 noon, outside City Hall at 1221 SW 4th Ave.

Water Rate Hearing – May 18, 10:15 am
A tentative date has been set for Council to hear the Water Bureau’s request for rate increases that will drive up your bill 85% over the next 5 years. Attendance is essential if you want Council to insist on something more sensible. Council Chambers in city hall. Check on the agenda as it develops here.

Oregonian Recognizes the Safety of our Water, and the Peril of Debt

In this Sunday's editorial piece, the Editorial Board at the Oregonian declared our drinking water safe and our financial health in peril.  Their willingness to finally recognize the data that verifies Portland really does serve clean water from Bull Run through both open and closed reservoirs, is in part inspired by a letter written by Dr. Thomas Ward (an infectious disease specialist at OHSU) to Commissioner Leonard and others this week.  Ward's letter is highly educational, and I can't recommend it enough: read the Ward Letter. 

The editorial also refers to the Portland Waters Users Coalition's opinion that Portland is barrelling towards a precipice.  (PWUC is a coalition of businesses which depend heavily on affordably clean water; you'll note that Widmer Brewing is a member).  A letter drafted this week by the Physicians for Social Responsibility (and signed on to by many groups, including Widmer, PWUC, Sierra Club, and Food &Water Watch) adamantly urged our Commissioners to take immediate action to stop LT2 contracts and seek a delay in the compliance timeline.

In the last few weeks, reporter Scott Learn has produced two substantive articles on our water system and how EPA's LT2 seems an inappropriate mandate here.  Read the first article here, and the second article here.  This issue is finally getting the attention it deserves.

What can be done? Stop the LT2 insanity.

Here is what Portland CAN do to save money on open reservoir projects they don’t need (read below how to stop the Bull Run treatment plant we don't need):

1) Don’t throw good money after bad = KILL THE CONTRACTS. When David Shaff says, “Hell will freeze over,” before the reservoirs will be saved, he’s employing a tactic to maintain your apathy. My house catches on fire and I don’t just walk away and say, oh well, it’s burned now. No, I employ the fire department to stop the damage. Even if the Water Bureau has blown through $200 million on tanks we don’t need, that’s still $500 million (with interest) less than what this will cost us if we just sit back and take it. This bureau has mastered justifying cost over-runs, stop the bleeding wherever you can and the savings will grow exponentially.

2) Look at Rochester (NY) – The good folks in Rochester, New York, are in the same “cover or treat or disconnect” dilemma as Portland is with regard to open reservoirs. They originally dismissed the idea of adding a micro-treatment facility right at the open reservoirs, but have since discovered it is possible to retrofit their existing small, historic structures to house the equipment they need to “treat” the finished water once again. This will allow them to keep their reservoirs open at a FRACTION of the cost. Compare their $25 million compliance plan to the $400 million compliance plan cooked up by our local contractors. And you can see why cozy relationships between PWB staff and outside contractors are sinking our ship. If you want, read some of Rochester’s plan: http://tinyurl.com/4r35uuh

The Portland Water Bureau only gave the micro-treatment facility idea the smallest of glances, which never got any more technical than “preliminary thinking” (PWB’s own word choice) -- thinking that was crafted by the contractors that want the lucrative buried tank projects.  When community members and large businesses recently requested a look see at PWB’s detailed analysis of the micro-treatment option, they were provided three non-technical paragraphs written several years ago (http://tinyurl.com/4szgfq9 ). That’s less analysis than I ran when I chose my hot water heater. (When a business coalition pushed for more details, they were informed they'd be charged for any information released -- none has been released yet). 

Call David Shaff and Randy Leonard and insist they complete a thorough technical/cost analysis of a micro-treatment option. Of course, if you ask the well paid PWB engineers to do it, they’ll sit on their hands and whine that it can’t be done. Here’s the trick, tell them they can hire one of their consulting friends to do the work. They always love funneling money out that revolving door into the hands of their future employers.

3) Consider all compliance options.  There are multiple ways to "comply" with a regulation set forth under the Safe Drinking Water Act. 

• Seek a timeline extension, or "deferral."  The science has evolved significantly since this rule was written and in all likelihood the LT2 Rule will be substantially revised when the rule comes up for review in 2015.  The winners will be any water bureau that managed to hold on until the rewrite, and of course the big contractors that got their expensive projects in before they were clearly made unnecessary.  Portland Water Bureau set an aggressive timeline, and that was a disservice to our people.  New York City spent their time and money seeking more time and they won it... they don't have to build until 2028.
• Challenge EPA and seek a "variance."  Regulation issued under the Safe Drinking Water Act must by rights allow for a municipality to argue that they've found an alternative means of meeting the standards set forth in the regulation.  EPA asserts that they do not have to honor the "variance" rights of municipalities (set forth in the Safe Drinking Water Act) because they have already determined that there is no other technology that works as well as a lid for protecting finished drinking water.  But, EPA has no science to support that finding.  And, all of the available science EPA can quote clearly shows covered water systems are subject to contamination.  Every major public health outbreak due to microbial contamination on record with EPA has happened in a covered system (like in Gideon Missouri), or in a system with sewage, industrial, and cattle runoff (like in Milwaukee, Wisconsin -- which, incidentally, also had an expensive treatment plant).  Lids are not the pinnacle technology, and they should not be treated as such.  Portland should be allowed to make its own argument for how it effectively manages contamination and serves clean water from Bull Run through both closed and open reservoirs.
• Evaluate an in town UV system designed to process the smaller flow rates exiting our open reservoirs.  This flow rate is smaller than that of Bull Run, so the plant should be smaller and cheaper.  You'll notice, in Rochester they've discovered they can create adequate UV facilities in their small historic structures already next to their open reservoirs.  Why can't Portland?
• Seek legislative relief in D.C.  The landscape has changed considerably in D.C. in recent months.
  Republicans on both the House and the Senate side have introduced extremist LT2 relief bills that endanger public health (HR 6393 and S 3038; also see the Cordova Times article).  Given the shifting balance of power, there may be an opportunity for moderate legislation to gain influence.  Only our delegation can read those tea leaves, however, they aren't likely to do anything on Portland's behalf as long as City Council sends mixed signals regarding this community's current commitment.  When I sat in on a meeting with community stakeholders and Senator Merkley in November,  Merkley noted a lack of leadership from Portland’s City Council regarding the reservoirs.  He wondered aloud why there seemed to be so little fight in this Council.  Senator Merkley reminded us that his federal efforts need to be in support of a meaningful effort at the local level.  

4) Demand a whole council approach. A wide swath of citizens and businesses alike have called for LT2 issues to be handled by the entire City Council, and not just left to Randy Leonard. As educated citizens highlight the important facts about LT2 projects, Commissioners have repeatedly deferred to Commissioner Leonard in the face of their own confusion. This is not acceptable; demand that every Commissioner be accountable for each LT2 related step made within our water system.

5) Hold David Shaff and Randy Leonard accountable. Don’t let unreliable labor keep the job.


Here is what Portland CAN do to save money on a treatment plant Bull Run doesn't need:

1) Contact every Oregon Health Authority Board member, which now holds jurisdication over the decision to either accept or deny our "variance" application regarding the plant at Bull Run.  Be relentless.  Make sure they understand the entire issue, and press them to side with public health and financial stability.  One verdict can insure the public's health AND secure our pocket books (how often does that happen?).

2) Demand a whole council approach. A wide swath of citizens and businesses alike have called for LT2 issues to be handled by the entire City Council, and not just left to Randy Leonard. As educated citizens highlight the important facts about LT2 projects, Commissioners have repeatedly deferred to Commissioner Leonard in the face of their own confusion. This is not acceptable; demand that every Commissioner be accountable for each LT2 related step made within our water system.

3) Hold David Shaff and Randy Leonard accountable. Don’t let unreliable labor keep the job.

The Kelly Butte tank teaches us a lesson about big consultants

On March 17, 2010, Portland's City Council gave the go ahead to the Portland Water Bureau to start the uber-expensive and unnecessary new water tank at Kelly Butte. The contract is going to Montgomery Watson Harza (MWH). MWH has secured most of the largest PWB contract awards over the last decade, MWH employees were involved in writing the LT2 Rule that Portland is now citing as the reason they must build this new tank at Kelly Butte, and reportedly, it was MWH that originally conceived of this idea to build a tank we don't need at Kelly Butte almost a decade ago. One might also note, MWH constructed the famously faulty buried tanks in Seattle which have contaminated that city's water supply.

There were two companies on the official “short list” to get the Kelly Butte contract; one was MWH and the other was a company called AECOM. AECOM is another mammoth global engineering firm. This year, Friends of the Reservoirs and I have found CH2MHill and MWH bidding on contracts, such as the Powell Butte contract, under other names. For instance, with the Powell Butte project we saw two bids come in: one from CH2MHill and one from Tetra Tech. The Tetra Tech bid turned out to be a consortium of multiple players, including MWH and Black & Veatch. AECOM has a history of working with CH2MHill on lucrative contracts. (Note the consortium called “Transcend” that was developed this time last year for a large rail project in the UK).

Also note on the Kelly Butte meeting sign in sheet, CH2MHill listed itself as a “SUB” or subcontractor for this project and AECOM listed itself as a “PRIME” or the prime contractor for this project. Which means AECOM was planning on submitting its bid under its own name, and CH2MHill is/was planning on working under some other company on this project.

As citizens become more alarmed at the influence particular firms have over large projects in Portland, we should expect to see those firms occasionally mask their participation in large contracts so as to lesson appearances of impropriety. Something to be aware of as more contracts move forward. The top name does not necessarily tell you who the real players are behind the contract. The only way to know which companies are truly benefiting from these large contract awards is to request to see every bid -- a costly prospect given the Portland Water Bureau's refusal to recognize fee waivers for community organizations and their insistence on charging for every form of access to these bids.

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