10/14/1987 - Packet CITY OF TIGARD
UTILITIES AND FRANCHISE COMMITTEE
MEETING AGENDA
Tigard City Hall — Town Hall Conference Room
Members : BENZ JAC0BS MoREYN0LDS GEORGE
MIS0VETZ IRWIN BARRETT ____.
1 . Call to Order and Roll Call .
2. Minutes of September 16, 1987 Meeting.
3 . Tualatin River-
,
iver. John Acker, Assistant Planner
4. Franchises .
5. PNB Recommendation.
6. Other Business .
7. Adjournment.
br/1256D
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MEMORANDUM
CITY OF TIGARD, OREGON
TO: Utility and Franchise Committee October O' 1987
FROM: Wayne Lowry, Finance Direotor,
SUBJECT: Franchise Agreements.
As discussed at our last meeting and at the recent council study session, the committee
has been assigned the responsibility to examine the current Franchise Hgreemuntx with
the various utilities in the City and make specific recommendations to Council an the
committee determines necessary .
You have been given copies of the City' s Franchise Agreements. The following is a
summary of the important aspects of each of the current agreements :
RENEGOTIABLE/ AUTO AUDIT PAYMENT
D�E T�M DATE RATE CLAUSE 0E
PNB 8/73 20 YRS YES 8/83 0 M0. 2% N0 N0 4/1
GTE 3/82 10 YRS NO 8/83 — 3% YES N0 3/15
NNG 5/82 10 YRS YES 5/87 — 3% NO YES 1/2 Cal , YR.
PGE 10/72 20 YRS YES 10/82 — 3 1/2% YES NU 3/15
As discussed at our previous meeting, PNB has exercised its right to cancel the
ordinance and has effectively reopened the agreement to negotiation. In talking with
the City of Eugene, they allowed the exclusion of "competitive services" but raised the
rate from 3% to 5%.
An interesting observation is that both the GTE and PGE agreements stipulate that if the
utility negotiates a higher rate with any City in Oregon in a negotiated franchise, that
higher rate shall become payable to Tigard thereafter. In contacting other cities in
Oregon, I found that the City of Portland charges PNB' CTE, and P(3E all 5% of their
gross revenues . The City of Portland does not have a franchise with these utilities but
charges them based upon their right established by ORS 221 . 450.
All of the above mentioned franchises appear to be open to renegotiation at the
direction of City Council. Three of the four 6o not provide for the City' s inspection
of the utility' s financial records and payments to the City are payable annually or semi.
annually.
If the committee chooses to recommend that these franchises be renegotiated, in addition
to rates, payment schedules and audit clauses should also be examined.
ia/1255D
July 8, 1987
James Blake
(YOFTIOARD
King City Lions Club
12750 SW Prince Albert
King City, OR 97224 OREGON
25 Years of Service
RE: Newspaper Recycling 1961-1986
Dear Mr. Blake:
Thank you for your response regarding the clarification of newspaper recycling
responsibilities within the Summerfield community. This letter, when signed
by you, represents an agreement between the King City Lions Club, City of
Tigard, and Schmidt's Sanitary Service, Inc. , relating to recycling services
pursuant to the City's franchise agreement with Schmidt's Sanitary Service.
The residences to receive regular newspaper recycling service at least once
per month by the King City Lions Club are shown by the shaded area on the
attached address map (Exhibit "A"). The following conditions shall apply to
this agreement:
1. Schmidt's Sanitary Service, Inc. , shall continue to collect all other
recyclable materials a minimum of once per month.
2. Outside of the area noted on Exhibit "A" all regularly scheduled recycling
services, including newspaper, shall continue to be provided exclusively
by Schmidt's Sanitary Service, Inc.
y-
&iefts 1--lob ash-all ee"elntte to be permitte
r
4. King City Lions Club shall notify the City of Tigard 30 daysi prior to
discontinuing regular recycling service.
5. The service area shown on Exhibit "A" shall not be expanded without
written authorization from the City of Tigard.
Please sign both copies of this letter and return one copy to my office.
Thank you again for your cooperation in this matter.
Sincerely,
Rob W. Jean
Cit dministrator
ames Blake _
/King City Lions Club
cn/1953W
cc: Larry Schmidt
13125 SW Hall Blvd.,P.O. Box 23397,Tigard,Oregon 97223 (503) 639--4171 ----- -----------------
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Pint-size elephant
gaining reputation utation as
precocious pachydermMetropolitan Service District MUM'
Chang Dee,Washington Park Zoo's newest •_, . ��
baby elephant,follows on the heels of his
favorite playmate,4 1/2-year-old Sung Surin.
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Born May 24,he has quickly proven to be a
favorite of visitors.And just a bit spoiled— = "
by his mother Me Tu,and his grandmother
Rosy and"auntie"Pet,and the keepers."
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His name means"good elephant"in Thai,
but he's more than earning a reputation as a
precocious pachyderm.And Sung Surin is "=
most often the object of his pranks. -
The 24th elephant born at the Washington
Park Zoo,Chang Dee weighed in at about
175 pounds.He's now approaching 400
pounds,growing at about three pounds a
.ham,
day. Chang Dee trails after his favorite playmate,Sung Surin.
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:District fi Sharon'District-1-91 lft Bogner
District 9 Tanya-Collier-
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ColliMtn 14 Larry CooperOUR BIGGEST WASTE
district 11 David Knowles PROBLEM
43i :12 Gary Hansen
Executive+ofrxer
RIGHT IN YOUR OWN BACKYARD.
l ena Cusma
Convention center pdate: Committee looks proposals
funding package complete, to use money from surcharge
design to include art work on North Portland enhancement
What's the best way to spend$40,000 to Applicants were required to provide
Oro ew
enhance North Portland? information about the organizations/
individuals requesting funds,a brief
1etro News is 9ttY�Y Answering that question is the task being description of the proposed project and
tha metropolitart Service District.
undertaken by the North Portland Rehabili- list of matched funds,if any.
` Vickie Backer tation and Enhancement Committee.
Projects were required to address
1Vfattsan r_ Twenty-one community organizations any of the following:
4' 'otographer, thy Thojr xs St.Johns
�
I II i submitted 23 proposals for funding.TheDm- Kennon
x committee pared the selection to nine increase employment/economic
p _ y�r;,i+ I� Portsmouth
finalists: opportunities
.
etro.t$' Q at' SW 1'1rst AvPr., ersfty Park
�� Univ
North Portland Youth Center—employArbor Lodge • rehabilitate and upgrade residential
F..
= disadvantaged youths to help elderly housing
d t�� 1t:4 with yard maintenance. overlook
1 1�• _ z preserve or enhance existing wildlife and
• St.Johns Review—publish"The Penin- — marine areas
sula and Its Promise,"a 12-page tabloid
$ a ..; ..
promoting North Portland. improve or increase recreational areas
wears The boundary of the North Portland
• Audubon Society of Portland—design enhancement area is between the Willam- improve safety in the area
wa 'pz'ttl�aa€ir i right Sweeping curved entrance and twin glass towers enliven the design of the and print signs and brochures for Smith ette and Columbia rivers and Interstate 5
, '&::ThOVs lhi� Oregon Convention Center. Facility features 150,000 square feet of flexible and Bybee lakes and surrounding prop- to Interstate 405. Neighborhoods include • improve the appearance or cleanliness
i .fir$ y�debt exhibit space,a large ballroom and several meeting rooms. Architects are ertY• St.Johns,Portsmouth,University Park, of the area
Zimmer Gunsul Frasca Partnership of Portland. Strode Eckert Photographic. Kenton,Arbor Lodge and Overlook.
lip in' imity,
Kenton Neighborhood Association— significantly increase the use or
Ift—e-WIV fes, clean up and maintain land near the occupancy of a commercial area
With funding assured,the Oregon Convert- A triangular plaza faces the Northeast Columbia Slough that was an illegal
tion Center is moving ahead toward the next Union/Holladay intersection. Landscaping landfill and is expected to be transferred American Red Cross,Oregon Trail aid residents,non-profit corporations and
phases. Design,public art and marketing around the plaza screens the building from to the city by Simpson Lumber Co. chapter—provide a no-cost program for small businesses as defined by the Small
"latch-key"children home alone after Business Administration
are at the top of the agenda. traffic and provides an attractive entrance • North Portland Citizens Committee, school.
for convention delegates. The plaza can be Neighbors North—coordinate five result in programs such as training
Design update— Since beginning work in used for public events or reserved for private neighborhood cleanup days during the The money comes from a 50-cent-per-ton opportunities to benefit youth and elderly.
March 1987,Portland architects Zimmer convention functions.
Gunsul Frasca have incorporated ideas from next nine months. surcharge on disposal of garbage at the St.
eight public design forums. During that Inside the facility,two lobbies are provided Johns Landfill.The fund was established in Metro Councilor Gary Hansen heads the
time,design progressed from conceptual for multiple use outside the exhibit areas. The Peninsula Senior Center—fund 1985 by the state Legislature to provide committee,which consists of Pamela Arden,
ideas to detailed drawings. Five exhibit halls,totaling 150,000 square activities for the elderly. rehabilitation and enhancement of the area Nick DeNicola,John Fisher,Brian Jeanotte,
feet, are designed to open onto the lobbies. in and around the landfill.By the time the Linda Krugel and Steve Roso.All are North
Shaping 490,000 square feet into flexible Facing the exhibit area,29,000 square feet River East Progress,Inc.—identify and landfill closes in 1991,the fund is expected Portland residents.
space,the design features five adjoining of meeting rooms are arranged in three help small businesses in North Portland to total$1.5 million.
exhibit halls,up to 28 meeting rooms and a clusters,each with an entrance corridor. that are interested in expanding and By mid-October,the committee will recom-
25,000-square-foot ballroom on three creating more jobs. The estimated annual income from the mend projects for funding;Metro,which is
separate levels. Food service,mechanical On the upper level,the ceremonial ballroom surcharge is expected to be$300,000 but the responsible for collecting the surcharge at
equipment,storage and support facilities provides 25,000 square feet of flexible space Columbia Boys and Girls Club— employ committee has voted to spend only the the landfill,will approve the projects.Funds
occupy the remainder of the building. that can be used for plenary sessions, youth to clean up litter. interest generated by the fund—$40,000 for are expected to be available after Nov. 15.•
Parking for up to 1,000 cars is planned south banquets,receptions and other large-scale fiscal year 1987-88.
of the facility. events. It can also be partitioned into
additional meeting rooms. A separate lobby
jhk
� g�p Twin glass towers,250 feet high,establish opens onto a terrace and the entrance plaza.couWas
8729Gthe building's location for out-of-town By the end of October,final design will be
visitors and provide a"gateway"to the city. completed. A series of design forums will 7
. ,. _
fCouncil votes to move
ahead with negotiations
on
fuelgostincomp , Plants
The Metropolitan Service District Council mass incineration plant.A proposal from solicit public comments. Formal action by Marketing update—In August the Metro The state,city and county provide the
Fluor/Southern Electric International,also the Metro Council to a ove the convention Council approved a$200,000 90-da remainder of the funding. On Jul 8,the
voted Sept.22 to move ahead with negotia- ppr pp y g. y
tions for plants to produce fuel and compost for a mass incinerator,was third. center design is expected in late October. contract with the Greater Portland Conven- Oregon Legislature committed$15 million
from approximately half the region's tion and Visitors Association(GPCVA)to from lottery funds during the next four
garbage. The vote means Metro will begin prelimi- One-percent-for-art update—Works of art kick-off the marketing effort. GPCVA will years. Also in July,the Portland City
3 t nary contract negotiations with Combustion will enhance the design of the convention compete for bookings by associations that Council approved a local improvement
We Ve aot some Engineering,based in Windsor,Conn.The center,thanks to anew 1-percent-for-art typically plan trade shows and conventions district assessment which will raise$5
The council voted 7 to 3 to move into
6 Wild ideas negotiations for a refuse-derived fuel plant to resolution reserves the option of negotiating program approved by the council last spring. years in advance. In September,a$225,000 million from businesses surrounding the
be built by Combustion Engineering at a site with the second-ranked proposer if a contract was approved with the Exposition- convention center site. Business owners
A" about recycling in St.Helens.Some 350,000 tons of waste satisfactory arrangement cannot be reached The convention center art advisory commit- Recreation Commission for Memorial will pay a one-time assessment of approxi-
A. would beprocessed at the plant annually. with Combustion Engineering.Metro staff tee,headed by Councilor David Knowles, Coliseum staff to market the convention mately$2.75 per thousand dollars of
Recycling Awareness Day After removal of ferrous and non-ferrous will also start negotiations with Riedel selected six artists and artist teams in August center to local and regional consumer shows property value99 .
at the Zoo r metals,the plant would make a fuel to be Environmental Technologies of Portland. to collaborate with the architects on propos- and special events. Their efforts also
E Saturday,October 3 m' burned to create electricity and steam. Preliminary negotiations with both firms are als for integrating art into the building support GPCVA's national convention On-going operations and marketing of the
loam.-4 p.m. scheduled to take 60 to 90 days. design. Later this fall,an open competition marketing. convention center are funded by a 3 percent
a special games;recycling displays;entertainment The council also voted to continue negotia- will be held to produce art works for certain Multnomah County hotel/motel tax. This
Recycling saves energy,natural resources and = tions with Riedel Environmental Technolo- Once successful negotiations are completed, areas of the completed facility. Funding update—Funding for the tax currently yields approximately$2
wildlife habitat
gies for a composting plant that would the Metro Council would have to authorize building's construction is complete. The million per year.
Recycling Information:224-5555 final contract negotiations with either Based on the estimated construction budget broad-based funding package includes a
process 160,000 tons of garbage a year ata g g g p g
METROsite on Northeast Columbia Boulevard. Combustion Engineering and/or Riedel at the time the program was approved,the i- $65-million bond measure,passed by the When completed,the center will"launch
Metals and other recyclables would be before bonds are issued and construction percent-for-art program is slated to receive region's voters in November 1986. The Portland into the major league of conven-
removed from garbage and a compost would begins. $475,000 for art projects. In addition,a bonds were sold on July 9. An AA+bond tion cities,"said Metro Executive Officer
r v u be produced that would be marketed as a soil $50,000 grant from the National Endowment rating by Standard&Poor resulted in a Rena Cusma. The construction contract is
r amendment. Also as part of the resolution,the council for the Arts was received for the architect/ lower-than-expected 7.37 percent interest expected to be awarded in June 1988 and
voted to begin an independent health-risk artist collaboration phase of the building rate on the bonds. the building opened in September 1990.
m s n r In the resolution authorizing Metro staff to assessment of the impacts of the refuse- design.
continue negotiations for a waste-to-energy derived fuel process.The assessment is
gufacility,the council ranked second a pro- scheduled to take approximately 90 days.
EF poral from Schnitzer/Ogden Martin fora cti�t ei
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Interest growing
in ways to solve yard
debris dilemma
"Our biggest waste problem is right in your , The goal of a citizen task force formed in The city operates its own collection and
own backyard"—that's the message Metro's West Linn aggressive 1982 is to reduce the city's solid waste by composting site.The site,actually the
emphasizing during Recycling Awareness50 percent.In June 1983 the committee parking lot of a local park,is open Satur-
Week Oct.3-10.Bus ads and advertisements In keeping yard debris made 15 recommendations which it felt days.For a nominal charge,residents can
in community newspapers will spread the out of region's landfills could meet the goal if aggressively pursued. deposit their yard debris.Woody material
_ ,,
word. 1< ti ' :' The recommendations fell into four catego- is chipped and mixed with non-woody
y. a•' lc ries:implementing programs,education and yard debris to be composted.The compost
Yard debris makes up 10.5 percent of the - _ Alta What makes a successful recycling promotion,funding and supervision. is sold to residents or is used by the city in
waste entering the landfill. Portland area TRII& program? parks and public works projects.City
residents produce more than 1.2 million West Linn also has developed an aggressive departments also use the site for the
cubic yards of recyclable yard debris eachAccording to Ed Druback,recycling coordi- Yazd debris program to deal with the disposal of yard debris.
year. nator for the city of West Linn,success Department of Environmental Quality
depends on three elements: city commit- burning ban and to keep the material out of In 1986 the community's 13,000 residents
The good news is that interest is growing in ment,highly motivated residents and an ag- the landfill. contributed 10,000 cubic yards of debris to
composting or alternate ways of keeping gressive promotional campaign. the compost program,more than double that
_
yard debris out of the landfill. Ways that t The program is three-fold: of 1985.Druback expects 12,000 to 15,000
} cubic yards this year.also provide an answer to backyard burning We dont rely on just one method to the
Home composting is the most economi-
word out, he said. We want to et the p g
Composting is one good way to deal with ✓ word into the home in as many ways as cal solution to disposal.Four how-to The city will soon have a new site on
yard debris and return nutrients to the soil. possible.The person who opens the water seminars taught by the staff of the Envi- Willamette Falls Drive that will accept all
Leafy material can be composted at home > e bill is not necessarily the one who takes care ronmental Learning Center at Clackamas recyclables,in addition to yard debris.And,
and used as a soil amendment,mulch or top �` _ `- of recycling,"he said. Community College are held yearly. with an eye always on recycling,the city is
dressing. ` reusing fence,pipe and buildings from a
The hauler in the cit provides on-call sewage treatment plant being torn down.
The how-to of recycling is featured on bill Y P g P g
Woody branches can be ground into small inserts,direct mail flyers,can stickers,in- collection of source-separated yard debris
chips with mechanical chi " „
p chippers or by a f✓ ,� school programs,door hangers,cable TV, for a charge that is less than if the yard
chipping service.Chippings can be spread as slide shows and displays. debris were disposed of as garbage.
ground cover or composted into mulch.
Other alternatives include taking the yard
On the first Saturday of the month residents
debris to commercial yard debris collection -�"� � Y � �
centers. Beaverton, hauler can take yard debris to the parking lot in
x back of the old City Hall at Southwest Hall11
join forces for monthly
d ��
y Boulevard and Fifth Street.The yard debris
Some cities are beginning to establish drop _ flt '
y
centers and some haulers provide pick-upard debris drop-off is loaded into garbage trucks and hauled to a
service.The yard debris is chipped and
A. local processing center.
composted and,in some cases,sold back to Participation has averaged 130 vehicles
consumers for use in gardens or yards. On the other side of the region,the city of since the service started in March 1987.
" Beaverton and West Beaverton Sanitary
For the do-it-yourselfer,Metro offers a free "�� T=��
Y Service have joined forces to offer a
One of the goals of the task force was that
booklet,"The Art of Composting." monthly drop-off location for yard debris. the service be self-supporting."We're not -
doing too bad;we're breaking even,"said - ps
For a copy of the booklet or the answers to It's the out owth of the cit 's annual
� Y Dave Tonges of West Beaverton Sanitary. �
all your questions about how to deal with "Clean Sweep Week"and a desire of the
yard debris,call Metro's Recycling Informa- * ° city's recycling task force to have a regular "The service does a great deal for the city,
tion Center at 224-5555 or write to Metro, drop-off place for yard debris,according tothe community and the hauler,"said Soth.
■ 2000 SW First Ave.,Portland 97201-5398. Forrest Soth.Soth,a member of the Beaver- "It's a good example of the kind of thing A
ton City
Some people will go to any lengths to keep yard debris out of the landfill. Council,heads the task force. that can be done with yard debris."
Unloading this craft are Forrest Soth(center,with cap),Beaverton City Council; Don Johnson and Rod Wilson unload
and Rod Wilson,Brian Johnson, Dave Tonges and Don Johnson of West Beaverton trailer at Beaverton's monthly yard
Sanitary Service. debris drop-off.
4 5
• Monday, Se tember 28-3:30 to S30 p.m. and 7 to 9
TUALATIN RIV�FACT SHEET #2
%!n, Rock reek Sewage Treatment plant, 312S SE �
River Rd.,Hillsboro.
Open houses are a chance for people to ask questions
and make suggestions before the decision has been made. . t
THE FINAL DECISION 811 SW Sixth Avenue
The public hearing will be held near the end of 1987, Portland, OR 97202
giving citizens a chance to give input on the final
recommendation. The Environmental Quality Commission
will make the decision on whether to approve the updated
management plant in the spring of 1988. THE T UALAT I N
HOW CAN YOU HELP?
Citizens can help government agencies deal with the RIVER• SEARCHING
problems in the Tualatin basin. The river's problems are
partly the result of human activities in the watershed. �O R A SOLUTION
People who degrade the river's water quality can help
reduce pollution by changing their habits.
Individuals are difficult to regulate. Currently, DEQ
and the Soil and Water Conservation District rely on Who uses the Tualatin River? Can it meet the needs of
voluntary efforts. Eroding soils, fertilizers and toxic an ever-growing population in Washington and Clackamas
chemicals all cause water quality problems. Counties? How much pollution is natural? How much is
Urban storm drains run into culverts which release to the result of people living and working in the Tualatin
the river. This "urban runoff' carnes oil, sediments and River Basin?
fertilizers from residential lawns and gardens, making the
Tualatin a dumping ground for these pollutants.
Phosphorus from fertilizers, organic waste and soaps also The Department of Environmental Quality (DEQ)
reach the Tualatin,encouraging algae to grow. wants answers to these questions before deciding how to
manage the Tualatin River and its tributaries for better
These problems are not unique to the Tualatin River. water quality in the future.
Overuse of fertilizers and pesticides is common where
people take pride in green lawns. Oil leaks can be found IS THE RIVER DIRTY?
wherever there are many cars. People may dump oil or Over the last 20 years, Washington-County grew from
chemicals down storm drains rather than recycle them 50,000 to 250,000 people. The growing population
because they dont realize it will drain into the river. overwhelmed existing sewage treatment facilities. In the
Phosphorus from detergents may keep clothes looking 1970's, DEQ and Washington County closed inadequate
brighter,but phosphate-free detergents will also clean your sewage treatment plants, transferring wastewater to the
laundry. The detergent label will say if it contains highly-sophisticated Unified Sewerage Agency (USA)
phosphates. The use of low-phosphate detergents, and plants at Durham and Rock Creek. Today, USA meets
careful application of pesticides and fertilizers can aid in the strictest limits for wastewater treatment in Oregon.
the cleanup of the Tualatin River Basin. But even the best treatment isn't enough when pollution
FOR MORE INFORMATION from a large population becomes more than the river can
handle.
DEQ welcomes public comment and ideas on how to
manage the Tualatin River Basin for the future. If you
have questions or want more information, contact Shirley
Kengla,Public Affairs Representative,229-5766.
WHAT IS WRONG WITH THE'TUALATIN? quality throughanagement plans in coordination with
The most obvious problem is the way the river looks. In other state agencies. Because of public concerns, DEQ
P y wants public input before recommending an updated basin
the summer, algae--a simple plant that grows in lakes and management plan to the Environmental Quality
slow-moving rivers--gives the river a murky green color. Commission. Advisory committees, open houses, and a
Rain-mixed sediments make the water look brown in the public hearing are all part of DEQ's effort to hear the
winter. Both algae and sediments make the Tualatin less public's concerns and ideas.
appealing for recreation.
Another problem is invisible to humans, but is felt by As Part of the management plan, DEQ will set new
fish. In summer, low levels of dissolved oxygen upset limits on pollution levels for the Tualatin River. These
limits will improve water quality to meet the needs of the
aquatic life. This drives fish to other areas in search of people who use the river for water supply, recreation and
oxygen. fishing. Both a citizen and a technical advisory committee
The nature of the river compounds problems. Partway are assisting DEQ with management decisions. The
through its journey to the Willamette River, the Tualatin citizen committee members represent competing uses for
river slows way down when it reaches a 2-inch-per-mile the Tualatin River as they discuss strategies to limit
slope. The nearly still waters encourage algal growth pollution. The technical committee serves as a scientific
which causes erratic swings in oxygen. Near the Lake peer group for technical decisions.
Oswego Diversion Dam, the river resembles a lake by
separating into layers of different temperatures. WHAT CAN BE DONE?
WHAT CAUSES ALGAE TO GROW? Before money is spent on solutions, DEQ wants to be
certain that any efforts will improve water quality.
DEQ launched an intensive study of the river in June, Among the options being considered:
1986. Two pollutants, phosphorus and ammonia, have been
identified as contributors to the summer problems of algae • Better control of "noupoint", ppollution. The
and low dissolved oxygen. unregulated pollution from many md'ividuals can cause
problems. Nonpoint sources of pollution in the
Phosphorus--a nutrient naturally present in food, Tualatin River Basin include runoff from urban and
fertilizer and detergents--enters the Tualatin through agriculture areas.
sewage treatment plants, and runoff from urban and • Increasing summer-time water flows for the basin.
agricultural areas. With the right combination of
nutrients, sunlight and warm temperatures, algae will grow. • Diverting treated wastewater discharges to either the
Algae is not a health threat, but is unpleasant for people Willamette or Columbia Rivers.
who use the river and Lake Oswego for summertime • Improving wastewater treatment beyond what is
recreation. currently required.
Ammonia, released into the river by sewage treatment • Irrigating treated wastewater on land during the
plants, robs the water of oxygen. DEQ's study showed critical summer months.
that, in the summer, dissolved oxygen dips below the level • Removing the splashboards from the Lake Oswego
needed to support trout and salmon. Diversion Dam to increase the river's movement.
The sewage treatment plants introduce nearly all of the These are only a few options. The management plan
ammonia. No single group is responsible for all of the may combine several of the options to improve water
phosphorus. DEQ's study shows that heavy rains wash the quality. DEQ is seeking any ideas that the public may
majority of the nutrients from urban and agricultural areas have.
into the river during winter. The sewage treatment plants
add the most phosphorus in summer. By the study's end OPEN HOUSES-MEET THE EXPERTS
in June, 1988, DEQ wants to know how much of the The public has several opportunities to meet experts on
winter's nutrients remain in the Tualatin to promote the the Tualatin River. Open houses will be held on:
summer algal growth.
• Thursday, September 24-330 to 530 pm. and 7 to 9
Y?
WHO CONTROLS THE RIVERS DESTINp.m. Tigard High School cafeteria, 9000 SW Durham
d.,Tigard.
The Tualatin River Basin is considered public waters, R
managed by several state agencies. DEQ protects water
THE TUALATIN RIVER BASIN STUDY
FACT SHEET
Background
The Tualatin River Basin, located southwest of Portland, is an important
natural resource used for drinki�g, irrigation, industry and recreation.
The basin is made up of the Tualatin River and its tributaries which
include Scoggins, Gales, Dairy, Rock, Fanno and Beaverton Creeks. The
Tualatin winds through Washing on county past the cities of Gaston, Forest
Grove, Hillsboro and Tualatin, and flows into the Willamette River. Lake
Oswego draws water from the Tualatin.
The Tualatin's water quality is a growing concern. Low dissolved oxygen
caused by ammonia discharges from sewage treatment plants threatens aquatic
life. Heavy algae growth in the slow-moving river is "fed" by nutrients,
such as fertilizers, and discourages recreational use. There is also a
concern about toxics in the river as new industry moves into the area.
Population in the Tualatin River Basin has increased dramatically in recent
years from 60,000 in 1950 to 250,000 today. Population is projected to
reach 350,000 by the year 2000.
Rapid population growth created an overload of wastewater in the Tualatin
during the 1950's and 601s. In the early 1970's many small, inefficient,
overloaded and outdated sewage treatment plants closed for public health
reasons. The plants began transferring their waste to Unified Sewerage
Agency's (USA) Durham and Rock Creek wastewater treatment facilities.
USA's plants were built using the best available technology. This improved
treatment reduced the amount of bacteria and other materials being
discharged into the Tualatin River Basin.
Before the construction of Hagg Lake Dam in 1974, the Tualatin River would
almost dry up during the summer. The low water levels led to warm
temperatures, low oxygen and an inadequate water supply for fish,
irrigation or sewage dilution. Today, Hagg Lake Dam on Scoggins Creek
stores water during the winter for release in the summer. This increased
flow enhances water quality in the Tualatin River.
A study conducted by DEQ and USA between 1970 and 1979, showed improvement
in the water quality of the Tualatin, despite a 40 percent population
growth in the basin area. The study, however, warned that water quality
will deteriorate as population and industrial growth continues.
FR1311 -1-
Why Study The Tualatin Basin?
The Tualatin River serves as an important resource to a growing
population. Industries use the river for manufacturing. Farmers use the
river for crop irrigation. Anglers and boaters use the river for
recreation. The Tualatin provides drinking water to Forest Grove,
Hillsboro and Beaverton. These uses depend on good water quality.
The problem of low dissolved oxygen is an immediate concern that will
require action. The nuisance of hard-to-control algae growth in the lower
Tualatin and Lake Oswego has heightened public concern. Rapid population
and industrial growth will continue to affect the river's water quality.
DEQ must plan carefully for the future.
Currently, DEQ is studying water quality in the Tualatin Basin in
cooperation with the Unified Sewerage Agency of Washington County (USA)
and the Lake Oswego Corporation. This study will review current water
pollution control standards. in order to develop a long-term water quality
management plan.
What Will Be Studied?
• Aquatic Life
Fishing is a popular sport in the basin. Trout and bass need adequate
levels of oxygen to live. Low levels of dissolved oxygen can
eventually kill off fish and other aquatic life. The stretch of the
Tualatin River below Rock Creek violates dissolved oxygen standards
during the summer, when the river level is low and temperatures are
warm. A study can pinpoint what causes the violations.
By taking an inventory of pollution sources and discharge points,
DEQ can fully understand the relationship between dissolved oxygen
levels and oxygen-demanding ammonia. Data has already been gathered
from a series of studies conducted between mid-June and mid-September,
1986. With this data, DEQ will develop a plan to eliminate the
dissolved oxygen violations.
• Uses of the River
The Tualatin River is used by area residents for many purposes --
drinking water, irrigation and recreation. These uses may be
threatened by deterioration of the Tualatin's water quality. Levels
of fecal coliform bacteria in the lower Tualatin system sometimes
exceed water quality standards. Nutrient "enriched" water flowing
into the lower system stimulates algae growth.
FR1311 -2-
i
A sampling program will estimate the level of pollutants coming from
industrial and sewage treatment plant wastewater, agricultural
activities, and storm drains or ditches that discharge into the
river. The uses study will examine the effect of these pollutants
on water quality, making it possible to identify actions needed to
protect the Tualatin River system.
• Toxics
For this study, the term "toxic" is very general, meaning any
"foreign" substances that degrade the river's water quality. Lawn
fertilizers, herbicides, pesticides, motor oil, and metals, etc. fall
under this category. Toxic materials come from both human and
industrial sources.
More and more high-tech firms are moving into the Tualatin Basin.
Manufacturing equipment for computers, electronics, and communications
use large volumes of water. Discharge of heavy metals in industrial
wastes could increase toxic concentrations in the Tualatin River.
As industry expands, more people are expected to move into the area.
Toxics such as yard fertilizers and motor oil increase with
population. These toxins wash from the streets into storm drains
which flow into the river. Pesticide and herbicide runoff from
expanding agricultural activities also drain into the Tualatin.
Little data exists on the occurrence of toxins in the Tualatin basin.
A study can evaluate the impact of continuing development on water
quality.
DEQ will focus its sampling program on herbicides, pesticides and
heavy metals which are used in the basin. After assessing current
levels of toxics and their effects on the river, DEQ will begin
designing methods to protect water quality.
What Is The Next Step?
The ultimate goal of the Tualatin River project is to develop an updated
plan which identifies water quality concerns and management strategies
that will best protect the basin.
Beginning September 30, 1986, DEQ will compile progress reports every three
months until June 30, 1988. A final report which includes basin planning
options will be prepared by June 30, 1988.
FR1311 -3-
Complex and varied issues surround the Tualatin River Basin study. DEQ,
USA, and the Lake Oswego Corporation are attempting to address the major
issues. However, critical factors may have been overlooked. Basin area
residents should be involved in the process to ensure that their concerns
and needs are covered in the study. DEQ is forming a citizen's advisory
committee to provide valuable input on study findings, as one way of
involving residents.
The Department encourages and welcomes public comment. To comment or
obtain additional information please write to:
DEQ Public Affairs
811 S. W. Sixth Avenue
Portland, OR 97204
To obtain specific or additional information or be included- on the mailing
list regarding this study, contact Shirley Kengla at 229-5766 in Portland.
Oregon Department of Environmental Quality
January 9, 1987
FR1311 -4-
a
i
911 MVV' 'SIXTH AVENUE. PORTLAND, OR 91 PHONE (503) 2- 5596
MEMORANDUM
To: Environmental Quality Commission
From: Director
Subject: Agenda Item O, March 13, 1987, EQC Meeting
Informational Report: Proposed Approach for Establishing
Total Maximum Daily Loads as a Management Tool on Water
Quality Limited Segments
Background
Considerable discussion has occurred over water quality management in
Oregon during the past several months. The Department has prepared this
staff report in response to that discussion and to describe several water
quality management activities required by Federal law. The report provides
the Commission with background information on the issue of total maximum
daily loads (TMDLs) and proposes recommendations for Department action.
Historically, the Department of Environmental Quality has implemented water
quality control activities in accordance with a general management plan.
This plan sets forth an overall program to preserve and enhance water
quality statewide and to provide for the beneficial uses of the water
resource. It is intended to fulfill the policy of the State of Oregon
regarding water pollution control as expressed in the Oregon statutes.
This management plan is also designed to satisfy water quality planning
and management activities identified in the Federal Clean Water Act (CWA)
of 1972.
Section 303 of the CWA (Attachment I) contains the basic Federal
requirements for water quality management planning. This section deals
specifically with water quality standards and implementation plans, and
introduces the concept of a total maximum daily load (TMDL) . According to
the CWA, total maximum daily loads are to be developed on those waters
where minimum treatment controls for point sources are not stringent enough
to meet the established water quality standards. These waters are said to
be "water quality limited". Attachment A provides specific details on the
requirements of Section 303, including the issue of total maximum daily
loads as they relate to water quality management in Oregon. Further
background information on Oregon's present water quality management plan is
presented in Attachment B.
EQC Agenda Item 0
March 13, 1987
Page 2
Among other requirements, Section 303(d) specifies the timing for each
state to submit a list of identified "water quality limited" segments and
established loads. The first submission is required within 180 days after
the EPA Administrator publishes the "identification of pollutants suitable
for maximum daily load measurement correlated with the achievement of water
quality objectives" pursuant to Section 304(a) (2) . This notice was
published on December 28, 1978 (Attachment J) . In a literal sense, the
state was not required to submit anything to EPA until June 26, 1979.
In 1973, the Department classified stream segments to satisfy the first
requirement identified in Section 3O3(d) (Attachment C) . Basically,
the Department was faced with the choice of designating waterways as being
either "effluent limited" or "water quality limited" as required in the
Act. An "effluent limited" segment is a reach where water quality
standards can be met by the application of technology based minimum
controls for all dischargers. In contrast, a "water quality limited"
segment is a reach where greater than technology based/secondary treatment
requirements are needed to continually achieve water quality standards.
The "water quality limited" label better conveyed the impression that the
loading capacity of stream segments is limited; that case-by-case analysis
of the effect of a proposed new or expanded discharge is necessary; and
that highest and best practicable treatment and control is needed to
minimize adverse effects on water quality. Thus, for these and other
advantages, the label of "water quality limited" seemed to best serve
Oregon's interests and was applied to all water bodies of the State.
This label seemed appropriate because Oregon (via limitations established
in discharge permits) had achieved waste load allocation for degradable
organics (BOD) which resulted in substantial water quality standards
compliance statewide. Remaining standards violations were related mostly
to the effects of diminished stream flows, higher than desirable
temperatures due to solar heating, seasonal turbidity from stormwater-
induced soil erosion, bacteria from occasional sewage bypasses and land
runoff, and natural conditions. The use of total maximum daily loads and
waste load allocations to address these problems did not seem logical at
the time.
The primary disadvantage of labeling streams "water quality limited",
however, was the need to establish TMDLs. The Department believed the
process necessary to establish TMDLs would require substantial resource at
the expense of other priority water quality issues. A total maximum daily
load is basically equivalent to the loading capacity of a water body. This
loading capacity is the greatest amount of pollutant loading that a water
can receive without violating water quality standards. The 1985 EPA
regulations (Attachment K) defined a TMDL as the sum of the individual
'waste load allocations (WLA) for point sources plus the load allocations
(LA) for nonpoint sources and natural background. EPA further defined WLA
as the portion of a receiving water's loading capacity that is allocated to
existing or future point sources of pollution. Similarly, the LA is the
r
r
FQC Agenda Item O
March 13, 1987
` Page 3
portion of a receiving water's loading capacity that is attributed to
existing or future nonpoint sources or to natural background sources.
On December 12, 1986, the Northwest Environmental Defense Center (NERC)
filed a suit in the Federal District Court of Oregon against Lee Thomas,
Administrator of EPA, to require him to ensure that TMDLs are established
and implemented for waters within Oregon identified as being "water quality
limited" (Attachment D) . That suit specifically identified the Tualatin
River and generally other streams in Oregon that are designated as water
quality limiting. Subsequently, NEDC filed a "Notice of Intent" to sue,
naming 27 other water bodies requiring TMDLs be established (Attachment E) .
The pending law suit contends that Section 303 requires EPA to establish
TMDLs on "water quality limited" stream segments and that this is a non-
discretionary function. Therefore, EPA is obligated by statute to
establish TMDLs. The Department has reviewed the suit with the State
Attorney General's office to establish our legal position. Essentially,
the Department has two alternatives:
1. Develop the TMDLs and WLAs itself consistent with a state
developed process and available resources, or
2. Have EPA develop the TMDLs and WLAs.
The Department believes that establishing TMDLs and, particularly, WLAs
will be quite controversial. There will be a number of different alter-
natives for achieving the WLAs including flow augmentation, modified
treatment method, no discharge, land application, or a combination of these
or other alternatives. If for example, phosphorus levels are of concern, a
ban on detergents containing phosphorus may be considered. Because of
this, the staff would like to use a process that involves as much public
participation as practicable so that all potential alternative WLAs and
potential implementation strategies are given appropriate evaluation.
EPA's approach, as established by Federal guidance and regulation, does not
allow for more than minimal public participation.
The Department feels that it is more consistent with the overall approach
of the state's environmental control program that we take the lead in
establishing TMDLs and WLAs. Therefore, we have been an active participant
in the negotiations between EPA and NEDC to develop an acceptable approach
to settle the suit.
On February 10, 1987 the Department met with the U.S. Justice Department
and EPA to finalize a settlement proposal. The Justice Department and EPA
presented the proposal developed to NEDC on February 11, 1987. The
Department has not heard officially from the U.S. Justice Department and
EPA, but apparently the settlement offer was rejected by the plaintiffs.
Consequently, the Department has decided to move forward in a positive
fashion to propose to the Commission that we proceed to implement the TMDL
process contained in the settlement offer.
4 l
EQC Agenda Item 0
March 13, 1987
Page 4 VOW
Proposed Approach
The following section describes how the Department proposes to address the
issue of TMDLs on "water quality limited" segments. For these segments,
the allowable pollutant loadings need to be determined so that water
quality standards will not be exceeded. Once established, the allowable
pollutant loading needs to be allocated to individual point sources as well
as nonpoint sources.
The proposed approach to establish and implement TMDLs and WLAs consists of
the following key elements: -
1. Identify the water quality limited stream segments on which
TMDLs and WLAs will be developed and describe how other
waterbodies will be assessed and additional "water quality
limited" segments will be identified, ranked, and addressed
in the future.
2. Describe how TMDLs/WLAs will be developed.
3. Establish a generic process to be used by the Department to
develop and adopt the TMDLs/WLAs for each "water quality
. limited" segment.
4. Describe how the Department will address applications for
discharge permits during the period from the time a water
quality limit segment is identified and the time TMDLs/WLAs
are adopted.
S. Describe the basic procedure for developing strategies which
will be used to implement the TMDLs/WLAs through the NPDES
Kr2
permit process.
Department staff have evaluated the 1986 305(b) report, the NEDC suit, and
the NEDC "Notice of Intent" to file suit to determine what "water quality
limited" segments may be due to point sources. These segments represent
those most appropriate for the initial establishment of TMDLs.
These point source affected segments are listed in Attachment F. For each
waterboO.y, the table presented in Attachment F includes the water quality
parameter (s) of concern, a proposed date for completing the initial steps,
and a list of NPDES permits which discharge to the stream.
Attachment F is intended to be a starting point for initiating the TMDL/WLA
process in Oregon. The recently amended Federal CWA contains provisions
under which the Department will conduct an evaluation of segments where
nonpoint sources or toxics could lead to the non—attainment of water
quality standards. The Department will conduct a nonpoint source
assessment_over the next 18 months_.and a water quality status assessment
over the next twelve (12) months. These assessments will determine whether
TMDLs are appropriate for other segments within the State. As these
assessments are completed and new information becomes available, other
{
EQC Agenda Item O
March 13, 1987
Page 5
segments may be identified as "water quality limited". The schedule for
conducting new TMDL/WLA work will be negotiated with EPA annually
during the development of the State/EPA Agreement. As further assessment
work is completed on remaining waterbodies, presently considered non-point
source limited and any other waterbodies identified in 305(b) efforts may
be added to the "water quality limited" segments list. This approach will
provide the Department the flexibility to add new "water quality limited"
segments and to prioritize TMDL and WLA development annually through the
State/EPA Agreement.
After the "water quality limited" segments have been identified the
Department must develop appropriate TMDLs and WLAs. This process begins by
evaluating the standard(s) being violated and determining what factors
contribute to these violations. Attachment H describes how the Department
conducted this evaluation on the Tualatin River. This approach will be
used on the other "water quality limited" segments, with appropriate
modifications, to address different standard violations and their
associated causes.
The Department proposes to divide the total allowable pollutant loadings
among the point sources, nonpoint sources, and natural background sources.
The natural background sources can be separated from the nonpoint sources
' through carefully designed monitoring surveys. Attachment L provides
potential strategies for allocating the point source load among the
permitted dischargers within a segment.
Once the allowable pollutant loadings have been allocated, various
strategies for achieving these loadings will have to be evaluated and
selected. These strategies may include utilizing flow augmentation,
modifying treatment methods, eliminating discharges, utilizing land
application, or a combination of these or other alternative. If for
example, phosphorus levels are of a concern, a ban on detergents containing
phosphorus may be considered as a potential strategy for meeting the TMDL.
The Department has identified a generic process which can be used to
develop TMDLs and WLAs for "water quality limited" segments. The process
has been divided into four phases as follows:
Phase I:
1. Department staff will develop TMDLs for "water quality
limited" segments and associated problem parameters.
2. Director proposes TMDLs and presents the evaluation and
hearing process schedule to EQC as an informational item.
3. Place TMDLs on 30-day public notice for public review and
Ia comment.
4. Respond to public comment and Director issues list of TMDLs.
EQC Agenda Item O
March 13, 1987
Page 6
Phase II:
1. Establish a local Water Users Advisory Committee.
2. Advisory Committee reviews TMDLs and considers various
alternatives to achieve TMDLs, exploring strategies for
point and nonpoint sources, and for allocating the point
source load among the permitted dischargers within a segment
(Attachment L) .
3. DEQ prepares staff report proposing a revision in the river
basin plan rules to establish TMDLs, waste loads and
implementation strategy.
4. Staff presents report to EQC with a request for
authorization to hold a rule-making hearing.
5. DEQ holds public hearing; local advisory committee formally
presents their findings at the hearing (30 days' public
notice for hearing) .
Phase III:
1. DEQ prepares staff report responding to hearing testimony
and proposing final basin plan rule revision to the EQC for
adoption.
2. EQC meeting for rule adoption.
3. Department submits TMDLs/WLAs to EPA for approval.
Phase IV:
1. DEQ implements rule via NPDES permit program and NPS
activities after it is adopted and approved by EQC.
Interim Period
There has been some question over how the Department will address
applications for discharge permits for sources within a water quality
limited segment before TMDLs and WLAs are adopted. Applications could be
for permit renewal for existing sources, or a permit request for new
sources.
For permit renewals where no increase in discharge is requested, the
Department intends to reissue without modification of permit limits.
For new sources and existing sources that propose expansion, the Department
would propose to accommodate increased discharges providing that in our
judgment there would be no conflict with what might be the ultimate control
strategy for the basin.
EQC Agenda Item 0
March 13, 1987
Page 7
TMDL/WLA Implementation
After the TMDLs and WLAs have been adopted, it will be the Department's
responsibility to address point source permits consistent with the
implementation strategy adopted. Current administrative rules (OAR 340-45-
055) allow the Department to modify existing permits and to include new
limits for complying with established waste loads if the implementation
strategy would so dictate. Should reduced limits be placed in permits,
compliance schedules for reaching those limits would be specified and would
be consistent with the adopted implementation strategy.
Tualatin Basin
In November 1985, the Department began an intensive assessment of water
quality and pollution sources in the Tualatin Basin. One purpose of the
Tualatin study is to develop water quality management tools to be used in
other Oregon basins. Consequently, the Tualatin River is the most
appropriate area for initiating TMDLs in Oregon. The process proposed
by the Department indicates that a hearing process schedule for
establishing TMDLs/WLAs on a particular segment will be presented to the
• Commission. Attachment G presents this schedule for completing TMDL work
in the Tualatin Basin.
In addition to a hearing process schedule, a TMDL is also being proposed
for the Tualatin River. The technical evaluation for developing the TMDL
is presented in Attachment H. Ammonia and phosphorus are the two water
quality parameters initially addressed. The stretch of the Tualatin River
below Rock Creek currently violates the dissolved oxygen standard during
summer low flow. The dissolved oxygen depression in the river is due
primarily to the nitrification of ammonia. Concerns have also been raised
about nuisance algal growth in the lower Tualatin and Lake Oswego.
Although phosphorus is not the only factor which stimulates algal growth,
studies indicate it can have a major effect on the abundance and type of
algae produced. At this time, pending review of public comments, the
Department believes that ammonia and phosphorus are the two critical
parameters that are directly related to water quality problems for the
point sources in the basin.
Table 1 presents the proposed TMDLs for ammonia and phosphorus in the lower
Tualatin River. These loads are based on flows for the Tualatin River at
Farmington gage.
The recommended approach for the Tualatin is to identify a set of loads for
varying flow conditions. This technique will better address the dynamic
nature of the river. This approach will also allow a range of options to
be considered in the process of establishing WLAs that meet water quality
standards. Alternatives could include permit conditions specified in terms
t
EQC Agenda Item 0
March 13, 1987
Page 8
Table 1. Proposed Maximum Allowable Pollutant Loads
for the Tualatin River
Tualatin River Maximum Ammonia Maximum Total Phosphorus
at Farmington, Load in River Load in River
Discharge (cfs) (lbs/day) (lbs/day)
100 - 150 540 80
150 - 200 810 120
200 - 250 1080 160
250 - 300 1350 200
300 - 350 1620 240
350 - 400 1880 280
of receiving water flows. Another option might be to identify the use of
upstream reservoir storage capacity to augment stream flows.
Summary
• The Department has identified water quality limited segments on several
rivers in Oregon.
• The Federal Clean Water Act under Section 303 requires the establishment
of total maximum daily loads (TMDLs) for stream segments identified as
"water duality limited".
• TMDLs have not been formally established in Oregon.
• The Northwest Environmental Defense Center (NEDC) has sued EPA requiring
them to establish TMDLs.
• NEDC has also filed a Notice of Intent to sue, identifying 27 water
bodies requiring TMDLs.
• EPA is obligated by statute to establish TMDLs; this is a non-
discretionary function.
• The Department can choose to develop the TMDLs and WLAs. If DEQ chooses
not to, EPA will have to develop the TMDLs and WLAs.
• The Department has developed a process and schedule for establishing
TMDLs on water quality limited segments.
• TMDLs are proposed for ammonia and phosphorus in the lower Tualatin
River.
EQC Agenda Item 0
March 13, 1987
Page 9
• The Department intends to place the proposed TMDLs for the Tualatin
on public notice for public comment in April.
• The Department will be working until April to refine the technical
information provided in Attachment H. Refinements will include input
from a technical advisory committee being established for the Tualatin
project.
Director's Recommendation
It is recommended that the Commission:
1. Approve the process identified by the Department for
establishing TMDLs including the proposed schedule for
completing Phase I for those stream segments listed in
Attachment F, Table F-2.
2. Concur with the Department's intent to place the Tualatin
TMDLs on 30-day notice for public review and comment, thus
initiating the entire TMDL/WLA process for the Tualatin
River.
Fred Hansen
Attachments: (6)
A. Total Maximum Daily Loads and Water Quality Management in Oregon
B. Background for Oregon's Present Water Quality Management Plan
C. Oregon's Initial Stream Classification Submittal to Satisfy
Section 303(d)
D. Federal District Court Civil Complaint 86-1578-PA: NEDC and
John R. Churchill vs. USEPA
E. Notice of Intent Dated January 6, 1987: NEDC to USEPA, et.al
F. Proposed List of Waterbodies Needing Total Maximum Daily Loads
G. Proposed Schedule for Establishing TMPLs/WLAs/LAs on the Tualatin
River
H. Technical Evaluation for Proposed Tualatin TMDLs
I. Section 303 of the Clean Water Act
J. EPA Guidance on Total Maximum Daily Loads - 1978
K. EPA Water quality Planning and Management Final Rules - 1985
L. Point Source Waste Load Allocation Methods.
R. Nichols/N. Mullane:h
WH1650
229-5284
February 10, 1987
d
'SWI?✓ ;�`;
ATTACHMENT A
TOTAL MAXIMUM DAILY LOADS AND WATER QUALITY MANAGEMENT IN OREGON
FEDERAL REQUIREMENTS FOR TOTAL MAXIMUM DAILY LOADS
The Federal Clean Water Act (CWA) sets out planning and management
activities to be undertaken by States and local governments. The
activities described establish the water quality goals and standards (as
was done in Oregon prior to passage of the CWA) and develop programs to
meet those goals. The water quality management program is defined in
Sections 106, 205(8), 205(j), 208, 303, and 305 of the CWA.
This Federal legislation was initially passed by Congress and signed into
law in 1972. Section 303 of the CWA deals specifically with water quality
standards and implementation plans. Section 303(d) introduced a concept
referred to as a total maximum daily load (TMDL). According to the CWA,
total maximum daily pollutant loads are to be developed on those waters
where minimum treatment controls for point sources are not stringent enough
to meet the established water quality standards.
The process identified by Section 303(d) requires each state to perform
several tasks. These include:
1 . Identify waters where "Best Practicable Control Technology" (BPT) for
industrial point sources and "Secondary Treatment" for municipal
sources are not stringent enough to implement established water
-quality standards, and establish a priority ranking for such waters.
(The EPA administrator is required to define BPT and Secondary
treatment by rules.)
2. For the waters identified and in accordance with the priority ranking,
establish the "total maximum daily load" (TMDL) for those pollutants
which the EPA Administrator identifies pursuant to Section 304(a)(2)
as suitable for TMDL measurement correlated with the achievement of
water quality objectives.
3 . Identify waters where controls on thermal discharges required in
Section 301 are not stringent enough to protect aquatic life and
estimate the total maximum daily thermal load required to assure
protection of aquatic life.
4. From time to time, submit priority lists and established TMDLs to the
Administrator for approval. The Administrator must approve or
disapprove within 30 days. If disapproved, the Administrator shall
within 30 days identify the waters and establish TMDLs as necessary to
implement water quality standards.
5. For the purpose of developing information, identify all other waters
of the state (not included in the above requirements) and estimate
TMDLs for pollutants identified by the EPA Administrator pursuant to
i
ATTACHMENT A
Page 2
Section 304(a)(2) at a level to assure protection of a balanced
indigenous population of fish, shellfish and wildlife.
The first submission of the waters identified and loads established by each
state is also defined in Section 303(d). It is required within 180 days
after the EPA Administrator publishes the "identification of pollutants
suitable for maximum daily load measurement correlated with the achievement
of water quality objectives" pursuant to Section 304(a)(2). This notice
was published on December 28, 1978. In a literal sense, the state was not
required to submit anything to EPA until about June 28, 1979•
Specific guidance from EPA regarding the implementation of Section 303(d)
was initially vague and sparse. A 1973 policy statement from EPA placed
the greatest water quality management emphasis on the issuance of NPDES
permits for industrial and municipal sources. Permit limits were to be
based on effluent limits (BPT or secondary treatment) if such limits were
adequate to meet water quality standards. More stringent controls were to
be implemented if the technology based effluent limits would not assure
compliance with water quality standards. At that time, the establishment
of TMDL's was a low EPA priority.
DEPARTMENT ACTIVITIES RELATED TO SECTION 303(d)
In 1973, the Department classified streams segments to comply with Section
303(d). This list was initially submitted to EPA on February 15, 1973 and ,
approved by them on July 17, 1973 (Attachment C). The classification was
subsequently refined in 1976. The Department was faced with the choice of
designating waterways as being either effluent limited or water quality
limited. The Department considered the advantages and disadvantages as
follows in making its choices:
1 . Effluent Limited Segments
a. Definition
An effluent limited segment is a reach where water quality
standards can be met by the application of technology based
minimum controls for all dischargers.
b. Advantages
1 ) Less cost to dischargers
2) Easier to operate plants
3) Less solids to dispose
lwooe
ATTACHMENT A
Page- 3
c. Disadvantages
1 ) The "effluent limiting" label would give the impression
that increased waste loads could be accommodated
without justification or water quality impact
evaluation -- all that was necessary was to meet
effluent guidelines. This was inconsistent with the
Commision policy to protect high quality waters and to
minimize discharges to streams.
2) A classification of "effluent limiting" might have
limited the ability of Oregon to require controls more
stringent than federal minimums -- or at least make it
more difficult to require more stringent controls to
protect high quality waters. The focus of the federal
law was the clean up of dirty water. Abatement was the
issue. Prevention programs were ignored. Oregon felt
continually frustrated in efforts to protect existing
high quality waters.
3) There was concern that construction grant assistance
for municipal facilities might be directed to "water
quality limited" segments. This could have hampered
Oregon's efforts to protect high quality waters. In
addition, Oregon was expecting a better level of
performance of secondary treatment technology than that
defined by EPA (20/20 vs. 30/30). Again, there was
concern that cities would be disqualified from
receiving grants if 20/20 treatment was required on
effluent limited streams. Oregon did not want to relax
state treatment requirements to prevent diminished
water quality over time as growth occurred. Also,
minor plant upsets at a 30/30 plant would more severely
affect uses, especially during critical summer flows.
2. Water Quality Limited Segments
a. Definition
A water quality limited segment is one where greater than
technology based/secondary treatment requirements are needed
to continually achieve water quality standards.
b. Advantages
1 ) The "water quality limited" label better conveyed the
impression that the assimilative capacity of the stream
is limited; that case-by-case analysis of the impact
of a proposed new or expanded discharge is necessary in
each case; and that highest and best practicable
ATTACHMENT A
Page 4
treatment and control to minimize adverse impact on
water quality is necessary and appropriate.
2) There would not be any major change in the existing
Oregon program or requirements. Oregon had all sources
under State Waste Discharge Permits. These permits
contained effluent limits consistent with Oregon
requirements of a minimum of secondary treatment or
control equivalent to secondary treatment (highest and
best practicable treatment and control). For instance,
conventional technology is capable of routinely
achieving 10/10 effluent quality in larger plants with
the full time attention of operators.
3) Grants would continue to be available to all
municipalities
4) Better able to limit discharge loads to maintain and
enhance water quality. By going this route, Oregon
would get a significant jump on maintaining high
quality waters and would, in addition, provide a
greater cushion to accommodate new industry and growth.
5) Minor upsets at treatment plant not likely to severely
stress water quality of receiving streams.
C. Disadvantages
1 ) Requires better trained operators because of operation
complexity.
2) More solids to dispose
3) Need to establish TMDL's which was predicted to be
resource intensive.
3. Total Maximum Daily Loads (TMDL)
a. Definition
A total maximum daily load is essentially equivalent to the
loading capacity of a water body. The loading capacity is
the greatest amount of pollutant loading that a water can
receive without violating water quality standards. In 1985 ,
EPA published regulations governing water quality planning
and management activities. These regulations state that a
TMDL shall be expressed as the sum of the individual waste
load allocations (WLA) for point sources plus the load
allocations (LA) for nonpoint sources and natural
background. EPA further defined WLA as the portion of a
receiving water's loading capacity that is allocated to
existing or future point sources of pollution. The LA is
the portion of a receiving water's loading capacity that is ,
ATTACHMENT A
Page 5
attributed to existing or future nonpoint sources or to
natural background sources.
b. Advantages
1 ) In those streams or sub-basins where stringent
requirements set by EQC are not enough, a mechanism is
available to establish higher requirements
2) Concept is valid in basins having:
a) Limited water quantity
b) Pollution problems caused by existing point
sources
c) High density population and industrial growth
potential
c. Disadvantages
1 ) Provides opening for request to relax treatment
requirements if TMDL limit is higher than existing
loads. In order to maintain high quality waters a
strong anti-degradation policy must be included and
adhered to.
2) Time consuming to establish reasonable TMDL without
being challenged by regulated community regarding
database used.
3) 'Value or usefulness of TMDL on nonpoint source water
quality limited segments is questionable.
Based on the above, the Department classified all waterways in the state
of Oregon as water quality limiting in 1973• The classification was
reviewed and refined in the 1976 water quality management plans. This
designation was made because certain desirable water quality levels are not
always met even if highest and best practicable treatment (30/30) of point
source wastes is achieved in the basin.
Oregon has already implemented waste load allocations for degradable
organics (BOD) necessary to achieve water quality standards where point
sources were involved. In 1972, substantial water quality standards
compliance had been achieved statewide. Water quality had been improved in
the Willamette to meet the dissolved oxygen standard. Planning and
construction was underway in the Tualatin Basin to provide new facilities
that, when completed, were expected to achieve compliance with standards,
(10/10 or better treatment on the mainstream, phosphorus reduction,
dilution, 5/5 or better on tributaries).
Standards violations remaining were related mostly to the effects of
diminished stream flows, higher than desirable temperatures due to solar
heating, seasonal turbidity from stormw ater induced soil erosion, bacteria
from occasional sewage bypasses and land runoff, and natural conditions.
( ;
ATTACHMENT A
Page 6
None of these conditions were considered appropriate for total maximum
daily loads and waste load allocations.
Thus, by 1976, the Department viewed load allocation to be necessary and
appropriate only in the case of BOD. The existing allocations in permits
were deemed to be adequate. EPA expected future submittals to be included
in the State/EPA Agreement for each fiscal year. The implication was that
approval of the State/EPA Agreement and award of program grants included
approval of revisions of segment classification and new or revised
TMDL/WLA's. If EPA had assumed otherwise, approval of the State/EPA
Agreement would have been denied and program grant funds would have been
withheld.
In summary, classification as "water quality limiting" seemed to cause no
extra work, seemed consistent with the existing program, and seemed to best
serve Oregon's interests.
FUTURE WATER QUALITY MANAGEMENT DIRECTION
Water quality management in Oregon must continue to evolve in order to
respond to emerging needs. Most major point sources already apply the best
technology available for conventional wastewater treatment. Additional
treatment, to address pollutants of concern in the 1980 's and beyond (e.g.,
nutrients and heavy metals) will be expensive and require major
investments. Decisions regarding treatment requirements must continue to
protect the uses dependent on water quality and must continue to be
supported by a sound technical basis. Also of concern is the threat of
legal challenges regarding water quality management decisions made by the
Commission and by the Department.
To address terms of Section 303(d), the Department has proposed an orderly
approach in updating the Statewide Water Quality Management Plan. First, a
set of key terms needs to be clearly defined which relate to the
development of total maximum daily loads. These definitions should be
incorporated into the Oregon Administrative Rules. The terms to be defined
include:
• Water quality limited segment
• Allowable pollutant loading
• Wasteload allocation
Next, a more formal process needs to be established which identifies
waters of the state where application of conventional waste treatment and
control technology for point sources will not result in compliance with
water quality standards established under ORS 468.735 . The Department has
prepared an initial list of these "water quality limited" streams. Water
bodies other than those currently identified will need to be ranked for
more detailed assessment in the future.
a
ATTACHMENT A
Page 7
yam;
In selecting and ranking other basins, streams, or lakes for
setting TMDL's in the future, the Department should at least consider these
criteria:
1 . Projections of growth and new developments
2. Severity of pollution concerns
3. Decisions that must be made regarding permit renewals or new
permits based on Item 1 above.
4. Minimum instream flows set by Water Resources Commission
5 . Other factors which would influence water quality and are unique
to individual stream segments, including the -relative
significance of nonpoint sources.
Once the waters of the state are identified and prioritized, allowable
pollutant loadings need to be defined. These loadings should be set so
that water quality standards will not be exceeded. Then an approach needs
to be developed to specify that portion of the allowable pollutant loading
which would be allocated to point sources. A procedure for allocating
loads among multiple point sources also needs to be established. The
entire allowable loading/wasteload allocation process would be treated much
like water quality standards and would include public participation.
A concern of the Department when TMDL's are established is that the
regulated communities may request relaxation of existing treatment
criteria, especially if streams can accommodate large loads. To address
this concern, the Department will need to:
1 . Re-evaluate present policies
2. Revise, restructure, and cross reference present policies as
appropriate
3 . Add new policies to the Water Quality Management Plan
If total maximum daily loads are limited to truly water quality limited
segments and the corresponding parameters, the concern of relaxation of
treatment criteria should not be a problem.
BC:c
w►a WC1444
OF O
6 '4
" Z Department of Environmental Quality
,859
811 SW SIXTH AVEN!!E. PORTLAND, OREGON 97204-1334 PHONE(503) 229-5690,-
October
29-5690October 5, 1987
TO ALL INTERESTED PEOPLE:
NOTICE OF MEETING CHANGE
The Tualatin River Citizen Advisory Committee meeting normally scheduled for the
second Monday of each month has been rescheduled for October. The change will
make a joint meeting between the Tualatin Technical Advisory Committee and the
Citizen Committee possible.
The new meeting date is Monday, October 26, 7:30 a.m. at Rose's Restaurant,
11995 SW Beaverton Higt way, Beaverton. Please contact Shirley Kengla at DEQ
(229-5577) with any questicins.
r .
a
TUALATIN BASIN PROJECT
QUARTERLY REPORT 6/30/87
I14TRODUCTION
The Department of Environmental Quality (DEQ) initiated an
intensive assessment of pollution sources and water quality in the
Tualatin Basin in July 1986. This is a two year study which will
be completed in June 1988. The study is supported by a section
205(j) grant provided by EPA. Portions of the study are being
conducted cooperatively by the DEQ, the Unified Sewerage Agency of
Washington County (USA) , and the Lake Oswego Corporation (LOC) .
This report summarizes the project status for the fourth quarter.
The project is proceeding as scheduled. Background information,
study objectives and study tasks are outlined in the project
workplan.
PROGRESS TO DATE
The information collected during the first year is being analyzed
by DEQ. An objective of this analysis is to determine where
additional information is required to describe processes affecting
water quality in the Tualatin Basin. Areas requiring additional
information include a description of the variability of
chlorophyll a concentrations in the river, analysis of processes
which affect algal growth, and the magnitude of sediment oxygen
demand.
The sampling program initiated this quarter will provide the data
for refining the assessment of water quality conditions in the
Tualatin River. The Quality Assurance Implementation Plan has
been updated to cover the details of the sampling program.
Data collection will occur through intensive surveys which key in
on a few critical sampling sites and an expanded ambient sampling
network. The information collected at each site depends on the
intended use of the data. The objective of each data collection
activity describes the intended use of the data. The survey types
and objectives are:
1) Ambient Monitoring. The two main objectives for ambient
monitoring this summer are: to maintain ambient background
information, and to distinguish the effect from point and
nonpoint pollution sources in the basin.
2) Chlorophyll Measurement. The objective is to refine the
analytical description of chlorophyll a variation in the
Tualatin and its dependence on nutrient concentration.
3) Depth Profile. The objective is to verify that
stratification occurs in the Lower Tualatin and to assess the
effect of stratification on water quality.
Now
4) Diurnal: The objective is to refine the analytical
description of oxygen variation and to assess the effect of
the thermal stratification, algal respiration, and oxygen
demand the oxygen resource.
5) Sediment Oxygen Demand (SOD) . The objective is to refine
the description of SOD in the Tualatin River.
Table 1 presents the sample sites, sampling agencies, and the
objectives to be fulfilled by sampling a specific site.
Table 1
Activity
1 2 3 4 5
Site ID USA DEQ USA USA USA DEQ
Cherry Grove 402555 x
Dilley 402136 x
Golf Course 402133 x
Jackson Bottom 402132 x
Mitner Bridge 402166 x
Rood Rd. 402131 x x
Farmington 402130 x
Scholls 402129 x x
Elsner 402128 x x x x x x
Boones Ferry 402126 x x x x
Stafford 402125 x x x x x
Scoggins Cr. 402164 x
Gales Cr. 404175 x
Gales (USA) x
Dairy Cr. 404176 x
Dairy (USA) x
McKay Cr. 404177 x
Rock W.U. 402149 x
Rock Hgwy 8 402147 x x
Fanno Cr. 402139 x x
Canal OSWO5-F x
Rock Cr. STP x
Durham STP x
Data from time-of-travel studies relate flow conditions to water
quality and are used to determine reaction rates from field data.
USA has completed two time-of-travel studies under different flow
conditions. Both studies were conducted with the Lake Oswego
diversion darn down. Additional time-of-travel studies will be
conducted with the diversion dam in place. Results of these
studies should help to indicate what effect the dam has on water
quality.
The information collected from these surveys will be related
directly, or indirectly, to the study objectives. The Tualatin
study is divided into three parts which reflect study objectives.
These parts are:
1) Water quality and aquatic life
2) Water quality and human uses
3) Water quality and toxics
Water Quality and Aquatic Life
The focus throughout this portion of the study has been on
dissolved oxygen, a key parameter that directly affects aquatic
life. During summer low flow the Tualatin River below the Rock
Creek Waste Treatment Plant (RCWTP) violates the dissolved oxygen
standard of 6 mg/l. Analysis of data confirms that the oxygen
depletion is due to nitrification of ammonia from RCWTP.
Data analysis by CH2M-Hill and DEQ indicates that sediment oxygen
demand and benthic nitrification need to be considered when
assessing oxygen demand in the Tualatin River. The intensive
depth profile surveys and diurnal sampling initiated this quarter
should provide the information needed to quantify the effect that
SOD, benthic nitrification, and thermal stratification have on
dissolved oxygen concentrations in the lower Tualatin River.
Water Quality and Human Uses
The Tualatin River provides area residents with many uses
including municipal water supply, and irrigation. Other uses such
as swimming and boating depend on aesthetically pleasing water.
Point source discharges as well as nonpoint urban and agricultural
sources affect water quality. To relate these discharges on water
quality, an ambient monitoring network has been established by
USA, by Scientific Resources Inc. (SRI) for LOC and by DEQ.
Results from this quarter's sampling are being used to assess
seasonal water quality patterns. Wet weather surveys have been
completed. These surveys look at contributions resulting from key
activities, such as agricultural and urban runoff, and sewage
bypass in the basin. The entry of pollutants into Lake Oswego
reflects the seasonal variation of pollutant concentration in the
Tualatin River. Pollutants entering the lake during winter high
flows may also be present during the summer.
Water quality data collected during the final wet weather survey
appear to verify the results from previous winter surveys.
Concentrations of nutrients typically increase during winter high
flows. Phosphorus concentrations continue to be higher in
tributaries adjacent to urban areas than other tributaries in the
basin.
On an annual basis the phosphorus load in the Tualatin River below
the major point sources appears to be equally divided between the
point and nonpoint components (Figure 1) . Preliminary analysis
indicates that point sources in the summer account for over 85% of
the total phosphorus load in the lower river (Figure 2) .
The focus of sampling has shifted from wet weather surveys to the
intensive summer sampling program. A key to this summer's
analysis will be to quantify the dependence of algal growth on
nutrient, such as phosphorus and nitrogen, concentrations.
Algal assays are being used together with the field surveys to
quantify the dependence of algal growth on nutrient concentration.
Figure 3 illustrates the results from the first of these assays.
For this assay, river water from above the major point sources was
spiked with sewage effluent containing a range of phosphorus
concentrations. Phosphorus was removed from the effluent by
chemical (Alum) addition. This procedure created an assay which
varies in phosphorus concentration while holding other parameters
constant.
From Figure 3 , algal growth appears to be dependent on phosphorus
at concentrations below 0. 16 mg/1. Above this concentration
increased phosphorus content did not result in increased algal
growth. Spiking the low phosphorus concentration in the control
samples with phosphorus resulted in increased algal growth.
Spiking controls with nitrogen and EDTA, a chelating agent which
acts to increase the concentration of micronutrients, did not
result in a significant increase in algal growth. These results
indicate that phosphorus acts as a limiting nutrient below 0. 16
mg/l total phosphorus.
Similar assays have been conducted in Lake Oswego to assess the
response of algae to changes in phosphorus concentration and to
assess management options. The bioassays were conducted in-situ
with 1, 130 liter polyethylene bags anchored to the Lake bottom.
Final results of these tests are not yet available (SRI, 1987) .
Water Quality and Toxics
Toxins in the Tualatin Basin are associated with urban and
agricultural nonpoint sources, industries, and domestic waste.
Although the toxins in the basin are a public concern, very little
technical information exists.
DEQ has summarized the available information on toxins in the
basin. This summary is used as the basis for reconnaissance
surveys. Ambient water, sediment, bio-accumulation, and
biological assessment surveys will be used to screen for toxins in
the basin. A draft Quality Assurance Plan has been prepared which
describes the toxic screening surveys.
CONTROL OPTIONS
Table 2 presents the control options that are being discussed by
USA, DEQ and the citizens advisory committee.
Table 2
Control Options
Point Sources
Alternative Uses
Out of Basin Transport:
Treatment Procedures
Nonpoint Sources
Stormwater Control
Land Management and Treatment
Point source control options that have been evaluated by CH2M-Hill
for USA include alternative uses, out of basin transport, and
treatment processes.
Alternative uses of sewage effluent are directed at spray
irrigation and land treatment in the form of "duck ponds" in
wetland areas.
The out-of-basin transport option would pump the effluent from the
major discharges to either the Columbia or the Willamette Rivers
where greater dilution is available. CH2M-Hill estimated a cost
of $100 million for the Columbia River option. The out-of-basin
transport option has raised concerns about water quantity in the
Tualatin. Dilution water purchased by USA provides a significant
amount of the flow during summer low flow conditions. Loss of
this water could greatly affect the flow in the lower river.
Dilution flows purchased from Scoggins Reservoir would have to
continue through the life of the contract with the Bureau of
Reclamation.
Treatment processes being reviewed include advanced treatment
options and pretreatment alternatives. The nitrification
processes included in the Rock Creek Waste Treatment Plant
expansion is an example of a treatment process control. The
nitrification process is designed to reduce the ammonia load which
lowers the dissolved oxygen concentration in the Tualatin River
below RCWTP. One pretreatment alternative that has been discussed
is a phosphate detergent ban to reduce influent phosphorus loads.
r
14
Nonpoint source control options include stormwater control and
land management / treatment. Stormwater control is a major
concern in the Tualatin Basin. Washington county, which primarily
forms the Tualatin basin, currently does not have a defined
stormwater control plan.
Control alternatives for Lake Oswego that are independent of those
for the Tualatin River are being evaluated by SRI and DEQ.
One independent control alternative tested was the addition of a
chemical to remove phosphorus and suspended solids from the Lake
Oswego Canal which supplies most of the inflow to the lake.
Public Participation
A major focus of this quarter was to develop the public
participation component of the project. Public participation
takes many forms, including both a Citizens Advisory Committee
(CAC) and a Technical Advisory Committee (TAC) , public comment on
proposed load limits, and public presentations by DEQ.
The advisory committees will play a key role in the development of
a management plan for water quality in the Tualatin basin. The
two committees will work cooperatively to assist DEQ in
establishing Total Maximum Daily Loads (TMDL) 's and Waste Load
Allocation (WLA) for pollutant parameters.
The CAC represents a cross section of interests in the Tualatin
Basin. The CAC will discuss and address public policy concerns
and competing needs. The TAC is composed of professionals in the
water quality field. The TAC will assist the Department in
identifing and reviewing control strategies and proposals from a
technical standpoint. Both committees have monthly meetings and
have developed long-term schedules.
Presentations were given to several groups interested in the
Tualatin study during the fourth quarter. These groups included
the Water Resource Future Needs Committee, Izaak Walton League,
and the Soil Conservation Society of America.
Outputs To Date
Data summaries are available through March 1987, as LOTUS files.
Field data are available as Storet files. Both the Quality
Assurance (QA) Plans, the Updated Tualatin Sampling QA Plan, and
the draft Toxics Reconnaissance QA Plan are available upon
request. The fact sheet which served as a precursor for the two
advisory committees, the minutes of the first three TAC and CAC
meetings, and the long term schedules for the TAC and CAC are also
available upon request.
References
CH2M-Hill, 1987, Interim Report, Tualatin River Water Quality
Modeling Study
DEQ, 1987, Tualatin Drainage Basin Point and nonpoint Assessment
Part 2. 1, Updated Quality Assurance Plan
DEQ, 1987, Tualatin Toxics Reconnaissance Surveys, Quality
Assurance Plan (Draft)
SRI, 1987, Lake Oswego Progress Report
The Need
(Why have this aspanded sission?)
1. Who is currently in charge of those three systems (storm,
sanitary z surface water) ? NOTE: Staff interpreted this
question to include those who impact or are interested in
these systems.
STORM SURFACE
WATER SANITARY WATER
LOCAL
Business Community X X x
Chambers of Commerce X X x
Cities X X X
Counties x X x
CPOs/NPOs X X x
Drainage Entities X x
Metropolitan Service District X X x
Private Property Owners X X x
Tualatin Hills Park i Rec . x
USA Advisory Commission X
USA Board of Directors X
Washington County Commissioners X
Water Districts X x
Tualatin Valley Irrigation Dist X
WC Soil 6 Water Conservation Dist X x
STATE OF OREGON
LCDC x X X
Boundary Commission
Dept of Environmental Quality X X x
Fish i Wildlife x
Water Resources Department x
Watermaster x
Legislators x X X
Division of State Lands X
FEDERAL
Audobon Society/Sierra Club X X X
Bureau of Reclamation x
Corps of Engineers x
Dept. of Agriculture
Dept . of Interior , Bureau of
Land Management
Environmental Protection Agency x X X
HUD
PNPCA/WPCF X X X
US Fish 6 Wildlife X x
US Soil Conservation Service X x
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