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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