March 19, 2008

Bob McDonald

Project Lead

Bureau of Land Management

Tillamook Resource Area

4610 3rd St.

Tillamook, OR 97141

RE: Protest to the Roaring Creek Decision Rationale as they relate to
the City of Hillsboro’s Slow Sand Filter Plant

Dear Mr. McDonald,

The City of Hillsboro Water Department submits this protest regarding
the Roaring Creek Projects Decision and Decision Rationale. The City of
Hillsboro Water Department submitted comments on the EA expressing
concerns of inadequate drinking water protection.  As indicated in those
comments our Slow Sand Filtration Plant (SSFP) is extremely susceptible
to turbidity events in the Upper Tualatin River Basin.  

The SSFP is located on the Tualatin River west of Haines Falls,
approximately ½ mile downstream from the proposed density management
treatment areas in section 29, and just over a mile from the nearest
proposed road work. The SSFP is the sole water supply source for the
community of Cherry Grove and the primary source for Dilley, LA Water
Cooperative, and the City of Gaston. 

BLM’s proposed actions threaten to disrupt or severely degrade the
capability of the plant to serve those communities. Due to the limited
nature of the treatment process at the SSFP, it is very sensitive to
additional sediment loads. The EA points out that the treatment plant
has experienced high turbidity and nutrient problems in the past (page
57) yet no accommodating changes were made in the Decision Rationale
[were no changes made or were there changes that just aren’t adequate
to address high turbidity and nutrient problems]. The Water Department
is concerned that implementation of the proposed actions could result in
significant impacts to our drinking water supply. It is for these
reasons that we are particularly concerned about the impacts the Roaring
Creek project may have on sedimentation and turbidity. This sole
drinking water source has not received sufficient management
considerations.

We want to be clear that the Water Department is supportive of [or not
opposed to] timber harvest that ensures full protection of our public
water supply sources that provide drinking water to the more than
300,000 Oregonians that we serve.  We also recognize that BLM has a
unique responsibility under the Oregon and California (O&C) Act to
provide a sustainable supply of timber.  However, In addition to
sustainable production of timber, the of O&C Act mandates that timber be
sold, cut, and removed “in conformity with the principal of sustained
yield for the purpose of providing a permanent source of timber supply,
protecting watersheds, regulating stream flow, and contributing to the
economic stability of local communities and industries, and providing
recreational facilities . . .(43 U.S.C. §1181a)”.   Given potential
impacts from roads and timber harvest we do not believe that BLM’s
proposed decision adequately protects a watershed that is the sole water
supply source for the community of Cherry Grove and the primary source
for the communities of Dilley, LA Water Cooperative, and the City of
Gaston. Further, we believe that impacts to public water supply from
BLM’s proposed actions will have adverse economic and destabilizing
effects on local communities and industries served by Hillsboro’s Slow
Sand Filter Plant.  These mandated O&C Act requirements for protecting
watersheds and contributing to the economic stability of communities
have not been adequately addressed by the proposed action, nor in the
responses to our comments.

We also note the Clean Water Act and Safe Drinking Water Act are federal
laws which require full protection of water quality and beneficial uses
such as municipal water supply.  The O&C Act does not obviate the need
to meet these federal laws. 

In the EA’s scoping letters [whose letter(s)?] a comment was made that
commercial harvest activities and road construction in municipal
watersheds should be avoided. The BLM responded that no such municipal
watersheds existed in the project area. Since this information is
incorrect we are asking for a reconsideration of the proposed actions to
increase protections to the City of Hillsboro’s municipal water supply
source. 

Please respond to our additional questions about proposed treatements.
What is the current relative density in riparian areas and upland areas
in the harvest units?  Will trees in the 60’ no cut zone count towards
calculation of the post-treatment relative density targets for riparian
areas?  Why were proposed relative density targets chosen that will not
maximize forest stand vigor and growth and canopy closure levels?  

Multiple-objective thinning research on Olympic National Forest has
found that a relative density of 35 to 50 maximizes forest stand vigor
and growth.  The relative density of mature stands inventoried in
Washington State ranged from approximately 60 to 87 (see Study on
Riparian Desired Future Condition Performance Targets for Forests and
Fish Program 2004).  BLM’s proposed action would result in stands with
a relative density of 25on upland sites and 30 in riparian stands. 
While we understand that BLM wants to accelerate the growth of
individual trees it is not clear how treatments would meet Aquatic
Conservation Strategy (ACS) objectives 4 and 5 which focus on
maintaining and restoring water quality and sediment regimes.  Proposed
ground based skidding on over half the area, new roads, and the level of
tree removal do not support BLM’s affirmative findings for these two
ACS objectives.  We believe that the proposed harvest methods and
intensity levels are not appropriate given the public water supply
concerns.  We suggest that post treatment relative density targets
towards the high end of the range for maximizing forest stand vigor and
growth would be appropriate. We are not certain how this would relate to
BLM’s basal area targets but note that the above referenced inventory
of mature stands in Washington found mean basal area levels ranging from
approximately 300 square feet/acre to 368 square feet/acre depending on
site productivity. Removal of no more than a third of the basal area on
stands in BLM’s sale units would help maintain a higher canopy level
and result in less ground disturbance. We would be agreeable to
eliminating harvest and new roads on slopes above 50% in section 29 and
on units where there are steep headwall areas or high to moderate
erosion potential.

Sedimentation due to timber yarding, hauling and road construction and
maintenance.

BLM’s argument that the only increase sediment will result from the
removal of an existing culvert in Section 29 is not supported.  We
believe that the high level of ground based skidding, new road
construction, and the relatively high level of tree removal will
exacerbate sedimentation and stream turbidity which are already a
periodic problem at the SSFP.  We support planning operations during the
summer season and agree that increased sedimentation will occur during
the first rainfall event.  However, the effects of topsoil disturbance,
roads, reduced canopy levels, soil compaction, and disturbance of steep
headwalls will be seen in subsequent winter seasons.

Review of analysis determining road construction affects on water
quality.

BLM comments that any increases in sedimentation and turbidity would
occur over a three year time period. Our municipal water supply must
deliver water every hour of every day. The turbidity increases for three
years will require major operational and maintenance adjustments by
means of increasing staff time to monitor turbidity levels and the
increased capital costs of filtration materials. 

As implied by the EA, road use alone causes increases in sedimentation.
The mere presence of an improved road can increase the sedimentation
delivery (Jones). We do acknowledge and support BLM efforts to
decommission decaying roads. We object to BLM’s reluctance to
acknowledge that even well constructed roads can increase sedimentation
delivery, particularly in a watershed that provides such a sensitive
municipal water supply source.  

Based on our discussions with the Oregon Department of Environmental
Quality and the Environmental Protection Agency it is our understanding
that other Oregon municipalities are dealing with high turbidity levels
as a result of forest practices attributed to roads and harvest levels
and methods.  Water quality impacts from forest practices on private and
State lands and management associated with other land uses makes a
conservative approach on BLM lands even more important from a cumulative
effects perspective. 

City of Hillsboro coordination with BLM

The City of Hillsboro is very appreciative of the assurances BLM has
made to keep our staff involved. We will be required to increase staff
presence at the SSFP to track turbidity levels to prevent a total plant
shut down. The COH Water Department requests to be informed of all
pending land use activities including harvest, fertilizer and herbicide
application. 

Sedimentation

The Decision Rationale claims to accommodate the Upper Tualatin/Scoggins
Creek Watershed analysis. According to this document a key water quality
recommendation is to “expand the Best Management Practices to reduce
sediment discharge to streams and revegetate eroding areas.”
Sedimentation is impairing the biological function of the watershed
(Upper Tualatin Watershed Analysis). The reduction of erosion and mass
flow events is also a major management goal of the Upper Tualatin
watershed analysis. It recommends increases in riparian vegetation to
reduce erosion and filter pollutants.

Currently the BMPs for erosion reduction have not been adequately
assessed for the Upper Tualatin basin (watershed analysis). However, the
NW Forest Plan Preliminary Assessment has shown that riparian reserves
of this magnitude have been successful in maintaining watershed
conditions. These riparian reserves are 180 feet along intermittent
streams and 360 feet along fish bearing streams. We ask that the BLM
consider increasing the riparian reserves to meet these NW Forest Plan
requirements. It has been shown that an effective buffer width is 300ft
for overland flows, but that sediment can be transported 4500ft if
channels are formed (Belt and O’Laughlin 1994). Given the steep
topography and highly erodible soils we request an increased buffer
width.

We ask that the BLM create BMPs to control erosion. BMPs and erosion
control measures on roads- newly constructed and decommissioned- and
surrounding any harvest activities affecting the SSFP at least one year
after operations. Coordinating the implementation of these BMPs with the
COH is the best method. This has been successful in coordinating with
private forestry operations adjacent to COH’s municipal water supply
sources.

The limited buffer size proposed by the BLM is not congruent with the
recommendations of either the watershed analysis, or the NW Forest Plan.
We ask that the BLM aggressively consider increasing the size of the
stream buffer width, especially in section 29.

Mass Wasting

Pg 64 of EA “Most of the eroded material in the upper Roaring Creek
appears to originate from natural sources, mainly from deep-seated mass
wasting.” Pg 49” A few additional, small fragile areas will probably
be identified and removed upon closer examination during the timber sale
layout” We implore the BLM to be overly cautious when selecting these
areas especially in area 29. 

Additionally, all activities in riparian areas must not retard or
prevent attainment of NW Forest Plan aquatic conservation strategy
objectives. Including maintaining and restoring the sediment regime
composed of timing, volume, rate and character of sediment input,
storage and transport. We feel that the currently proposed actions put
the soil at high risk for major alterations to the sediment regime and
the increase of mass wasting events. 

Since, the primary interest is to increase the growth rate of individual
tress the RD should be increased even further from 30 to a minimum of 35
or more agreeably to 50. An RD of this magnitude will minimize soil
displacement and maximize precipitation interception. The proposed RD of
30 in this highly sensitive area is deemed inadequate in our opinion.

No-Harvest Areas

Riparian no harvest buffers may have yarding corridors cut through if
necessary. Trees cut in the buffer will be left on site to augment CWD
(Pg 25). Yarding corridors expected to be 12 feet wide and 150 feet
apart.

Cumulative Impacts

In the past decade the Upper Tualatin watershed has been heavily logged
by private industrial and non-industrial owners. Combine these recent
logging events with the planned BLM and ODF ones and it becomes obvious
that the SSFP has been placed in a precarious environment. 

Nonmarket values

Impacts to nonmarket values are not well described or quantified in the
EA analysis. These values affect the economic well-being, health, and
resiliency of these local communities served by the COH SSFP. Clean
drinking water is a highly valued commodity produced by BLM lands. The
valuable commodity of the clean drinking water entrusted to BLM’s
hands of economic well-being, public health, and resiliency of these
local communities. The increased value of the BLM’s fiduciary
responsibility to protect the health, safety and welfare of the public
would.  

Even if full SSFP shut down is not a direct result of the actions taken
by BLM, even minor increased sedimentation loads will increase the
operational and maintenance cost including staff time, filtration,
monitoring

Protection measures

As administrators of the Clean Water Act, the DEQ regulates water
protection measures. Although the State of Oregon does not have a water
quality standards specifically for protection of municipal water sources
(pg 57) a turbidity water quality standard does exist. Water quality
standards not only include a numeric and narrative criteria, they also
include designated beneficial uses which must be fully protected, and an
anti-degradation policy.  We note that municipal water supply is one of
if not the most sensitive beneficial use which must be protected.  All
waters within Oregon regardless of whether they pass through public or
private lands must not increase turbidity levels more than 10% of
background levels. All BLM operations must meet this standard of the
Aquatic Conservation Strategy. The SSFP closely monitors turbidity
levels, should the level increase more than 10% the DEQ will be notified
of the violation. Should turbidity levels become higher than 5 NTUs we
will need to shut down the SSFP. 

Recommendations

Eliminate logging on slopes above 50% in section 29 [see earlier text
for other areas].

Increase harvest buffer to meet NW Forest Plan standards, including
180ft buffers along intermittent streams and 360ft buffers along fish
bearing streams. Or at least 100 ft buffers along intermittent. [are you
sure these aren’t the buffers proposed]

	BMPs and erosion control measures on roads- newly constructed and
decommissioned- and surrounding any harvest activities affecting the
SSFP at least one year after operations. 

	Minimize number and potential impact of corridors needed for operations
within no harvest buffers and riparian reserves.

	If considering no harvest buffer and/or riparian reserve within the RD
calculation, then increase RD to 0.4.  If these areas are not included
in the RD calculation, then increase the RD to 0.35. [see earlier
discussion]

Make sure recommendations are conistent with earlier text or change
earlier text.

	

Please call if you have any questions at (503) 615-6585

Sincerely,

Kevin Hanway

Director, Water Department

City of Hillsboro

(503) 615-6585

kevinha@ci.hillsboro.or.us

CITY OF HILLSBORO

150 E. Main Street, Hillsboro Oregon 97123	                Office: 
503-615-6702

	                   Fax:  503-615-6595

Water Department

