The Army Corps of Engineers wants to hear from you!
As previously reported (see Riverbend Pursues Wetlands Permit below), the Corps is reviewing a plan filed by Waste Management that would allow dump operators to build a new access road by rerouting the infamous No-Name stream into a 200-foot culvert.
This creek, which is just south of Riverbend Landfill's Trash Mountain, was historically fish-bearing, providing migrating salmon with resting pools and spawning grounds. In recent years, the stream has been degraded by culverts installed beneath Highway 18 and by Waste Management and its predecessors. Waste Management claims the plans it submitted to the Army Corps will "enhance" the stream, but that's hard to imagine as the water plunges into a 200-foot-long culvert just feet after emerging from under Highway 18.
Moreover, the Landfill's plans completely ignore the impact that the Cascadia Subduction Zone earthquake will inevitably have on the landfill and the flood plain it sits in. This quake is already overdue, yet Waste Management continues to promise that the landfill will not be affected -- despite evidence that the existing garbage dump was engineered, at best, for only a 7.25 magnitude quake. The Big One will be magnitude 9.0 at least.
The comment period for the Army Corps has been extended to October 22 -- that's next Thursday. Comments should be submitted to both the Army Corps and DEQ. Contact kinsey.m.friesen@usace.army.mil and 401publiccomments@deq.state.or.us to tell them how you feel!
Professional surveyor Leonard Rydell, who knows more about the landfill than most of us, has drafted a model comment for you to use or to modify in your own words. The important thing is to speak out!
Leonard's model comment:
Subject: US Army Corps of Engineers No: NWP-2015-322
Oregon Department of State Lands No: 07-0733
Dear Army Corps of Engineers, Oregon Department of Environmental Quality, and Oregon Department of State Lands:
We, the undersigned, are writing to request that the Army Corps of Engineers, the Oregon Department of Environmental Quality, and the Oregon Department of State Lands deny Riverbend Landfill’'s Permit Application No's NWP-2015-322 and DSL 07-733.
Riverbend Landfill is the WORST POSSIBLE PLACE in the Willamette Valley to construct and expand a landfill. The site is located in and next to the bottom lands of the South Yamhill River and is subject to meandering river channels. The landfill is situated on liquefiable soils in wetlands, a formerly-designated floodway, and an existing flood plain, in a wet climate that receives 41 inches of rainfall a year, within the Cascadia Subduction Zone that historically has been subject to earthquakes with magnitudes up to 9.09. A CSZ earthquake is overdue, and the existing landfill is not engineered to withstand a subduction quake of anything close to this magnitude. In addition, flood waters annually lap up to the existing and proposed landfill berms at the edge of the re-mapped floodway.
The expanded landfill will be 156 to 166 feet high with the toe of the support berms in the flood plain. After an earthquake, Riverbend’'s leachate will have only a few feet to flow to end up in the waters of the South Yamhill River. Already last year, before expansion, 32 million gallons of toxic leachate were hauled from Riverbend Landfill to treatment plants outside of Yamhill County.
This expansion risk is unacceptable to the health and safety of our environment and watershed. Please deny the permit.
Thank you.
Saturday, October 17, 2015
Sunday, October 4, 2015
Riverbend Pursues Wetlands Permit
In order to expand the landfill, Riverbend must build a new road across the so-called "No Name Creek" on the dump's south side. In order to build that road, the landfill must intrude into a wetland -- in fact, Riverbend needs to bury the creek in a 200' long culvert.
In order to encroach on a wetland, the dump needs a permit.
Actually, several permits: the federal Army Corps of Engineers, the Oregon Department of State Lands, and the state Department of Environmental Quality (DEQ) must all issue permits related to water. The Oregon Department of Fish and Wildlife, the National Marine Fisheries Service, the National Oceanic and Atmospheric Administration, and the Environmental Protection Agency may also weigh in.
Sounds like an impossible course to run, but Waste Management, which owns Riverbend, thinks it has these permits in its pocket because the change they have to make to the wetland is, in their words, an enhancement, not an encroachment.
First up is the Army Corps permit, which you can read about here. The Army Corps wants to know whether the work Waste Management plans to do in the wetland harms or benefits water habitat. However, as you will notice as you take out your magnifying glass, it's impossible to determine what exactly Riverbend proposes to do because the maps are not legible. The Stop the Dump Coalition noticed this, too, and requested readable copies. Contact Stop the Dump to see the actual maps.
You might also notice that the comment deadline is stated as a couple of weeks ago. This has been extended to October 22 and may be extended further yet -- because the Army Corps has yet to make the current "wetland delineation" public. The delineation is a description of the existing wetland area. Decisions about whether a project illegally encroaches on a wetland are based on the current delineation. Waste Management prepared one a couple of years ago that was accepted by State Lands. Because the entire permit application is based on the delineation, comments will make sense only if they can reference the delineation.
The real issue, of course, is not whether channeling a creek in a hugely long culvert "enhances" a wetland. The issue is whether a landfill should be allowed to expand next to a creek, period -- especially one subject to rupture in the big earthquake we are all expecting. Leachate is already leaking from the landfill and may contaminate the creek whether it is enhanced or encroached.
Write the Army Corps. Tell them landfills don't belong in wetlands. Our waste should go to dry Eastern Oregon, where the community actually wants it.
Send written comments to kinsey.m.friesen@usace.army.mil or via US mail to:
Or you may send your comment to DEQ:
In order to encroach on a wetland, the dump needs a permit.
Actually, several permits: the federal Army Corps of Engineers, the Oregon Department of State Lands, and the state Department of Environmental Quality (DEQ) must all issue permits related to water. The Oregon Department of Fish and Wildlife, the National Marine Fisheries Service, the National Oceanic and Atmospheric Administration, and the Environmental Protection Agency may also weigh in.
Sounds like an impossible course to run, but Waste Management, which owns Riverbend, thinks it has these permits in its pocket because the change they have to make to the wetland is, in their words, an enhancement, not an encroachment.
First up is the Army Corps permit, which you can read about here. The Army Corps wants to know whether the work Waste Management plans to do in the wetland harms or benefits water habitat. However, as you will notice as you take out your magnifying glass, it's impossible to determine what exactly Riverbend proposes to do because the maps are not legible. The Stop the Dump Coalition noticed this, too, and requested readable copies. Contact Stop the Dump to see the actual maps.
You might also notice that the comment deadline is stated as a couple of weeks ago. This has been extended to October 22 and may be extended further yet -- because the Army Corps has yet to make the current "wetland delineation" public. The delineation is a description of the existing wetland area. Decisions about whether a project illegally encroaches on a wetland are based on the current delineation. Waste Management prepared one a couple of years ago that was accepted by State Lands. Because the entire permit application is based on the delineation, comments will make sense only if they can reference the delineation.
The real issue, of course, is not whether channeling a creek in a hugely long culvert "enhances" a wetland. The issue is whether a landfill should be allowed to expand next to a creek, period -- especially one subject to rupture in the big earthquake we are all expecting. Leachate is already leaking from the landfill and may contaminate the creek whether it is enhanced or encroached.
Write the Army Corps. Tell them landfills don't belong in wetlands. Our waste should go to dry Eastern Oregon, where the community actually wants it.
Send written comments to kinsey.m.friesen@usace.army.mil or via US mail to:
U.S. Army Corps of Engineers
Regulatory Branch
Ms. Kinsey Friesen
P.O. 2946
Portland, Oregon 97208-2946
Regulatory Branch
Ms. Kinsey Friesen
P.O. 2946
Portland, Oregon 97208-2946
Or you may send your comment to DEQ:
Email: 401publiccomments@deq.state.or.us (if using Microsoft Word, through version 7.0 only)
Mail: Oregon Department of Environmental Quality, Northwest Region 2020 S.W. 4th Avenue, Suite 400, Portland, Oregon 97201-4953, Attn: 401 Water Quality Certification Coordinator
Fax: (503) 229-6957
Mail: Oregon Department of Environmental Quality, Northwest Region 2020 S.W. 4th Avenue, Suite 400, Portland, Oregon 97201-4953, Attn: 401 Water Quality Certification Coordinator
Fax: (503) 229-6957
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