Thursday, June 16, 2011

I'm back

Sorry to have been out of touch and offline recently. With a death in my family, I was out of town and focused only on my family.  Back now and will soon be posting fresh content and press here.

By the way, if you want to hear Commissioner Saltzman discuss his proposal for a new Independent Utility Commission (to help in setting City of Portland utility rates), join us at today's meeting of the Portland Utility Review Board (PURB). This group, charged with advising the City Council on utility rates and other things, meets the
3rd Thursday of every month
Lovejoy Room, 2nd Floor of City Hall
1221 SW 4th Avenue

Wednesday, June 8, 2011

A huge week!

This has been a big week.  On Monday, the Portland Water Bureau submitted an application for a Bull Run treatment variance to the Oregon Health Authority Drinking Water Program. We've been pushing for this for years and are pleased that the formal application has finally been submitted.  Today we reiterate what was stated in our letter sent to the Portland City Council in March:

"We acknowledge and thank you for your efforts to pursue a regulatory variance from Long-Term 2 Enhanced Surface Water Treatment Rule (LT2) water treatment mandates.  We all know that this is a ridiculous one-size-fits-all mandate that fails to take into account the protected, pristine nature of the Bull Run watershed and the purity of our water source, as supported by newly available scientific evidence which conclusively proves that Cryptosporidium does not exist in Bull Run water. We strongly support aggressive efforts to pursue the LT2 treatment waiver. We stand ready to assist you in any way we can."

We're on to a new stage for the Bull Run treatment portion of LT2.  Huge thanks to all those who have helped get us this far!

Next, Oregon's Drinking Water Program responded, in part, by posting this information. This webpage states that the decision process will include a public comment period, likely in October. 

"Public Health is required under federal law to announce its intent to issue a variance by hearing or by serving of a notice. In addition, Public Health intends to provide an opportunity for public comment from water users during its consideration of the variance request, likely in October. People also will have the opportunity to email their comments to Public Health. These comments will be considered during the decision-making process."   

A final decision is expected by the end of December. We will keep you informed of any and all opportunities to defend your drinking water!

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

This morning I read just one section of the Treatment Variance Application Portland Water Bureau submitted to the state Drinking Water Program this week.  LT2 is outlandishly expensive.  Even the variance is going to cost us (testing at high volumes takes money).   LT2 is also completely void of benefit to us, because we don’t have the problem LT2 is trying to fix.  So, to summarize, LT2 is expensive and unnecessary for Portland’s pristine Bull Run Water.  And yet, in section 6.5 of the variance application PWB just filed with the state, PWB makes the case for conducting useless LT2 tests even MORE frequently and at higher volumes than LT2 requires.  Wha?  If a useless test is no good, then doing even more of them is better?  Well, it will funnel a little more money to PWB’s consulting buddies (a.k.a.  their future employers) so somebody is getting something out of this, right?
In section 6.4.2, PWB lets slip that the UV plant design we are paying for right now (to wait on the shelf, just in case we don’t get our variance) will be stale, and possibly need “updating” (cha-ching).  And the land use and environmental permits they are buying now, will likely also have to be redone (cha-ching).  This is good planning?  I don’t generally pack my potato salad the week before the picnic, because, that isn’t actually efficient preparation.  If there is the possibility the UV plant design will be STALE by the time we need it, surely they built a clause into the contract that allows for a brief review for updating.  Oh no, silly me, I keep forgetting.  The principle is “funnel more money” not “conserve limited public resources.” 
But most upsetting of all (it gets more upsetting) is the trigger to build the $100 million UV plant and the flawed testing protocol PWB put on that trigger.  With so much at stake ($100 million dollars + future operating expenses) on the line for just two inconclusive test results, wouldn’t it seem prudent to be particularly careful when negotiating the test method.  We wouldn’t want to choose a test method with well-known flaws, that the scientific community has identified as producing false positives which overstate public health risks.  Yet, rather than make the case  for how much the science of Crypto testing has changed since EPA suggested testing Method 1622/23 as the standard for LT2 tests,  PWB stated in the variance application they would employ flawed testing Method 1622/23.  Almost unexplainable.

Bull Run Watershed