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Sunday, July 3, 2022

Don't Forget to Comment!

As previously reported here, the state Department of Environmental Quality (DEQ), is accepting comments on its proposed closure permit for Riverbend Landfill. Once adopted, the permit will govern operations at the landfill for the next eight years.

Comments should be sent to DEQWR.SolidWastePermitCoordinator@deq.oregon.gov no later than 5:00 PM Monday, July 11.

Information about the permit as well as the draft permit itself can be found on DEQ's Riverbend web page, https://www.oregon.gov/deq/programs/pages/riverbend-landfill.aspx.

At a public hearing in late June, DEQ accepted some comments orally. These include the following; your comment can echo these or offer new suggestions for requirements to be included in the permit:

1. The permit should prohibit further expansion of the landfill. DEQ officials have already acknowledged that the site, on a bend in the South Yamhill River, is problematic, and have said that the location would not be approved if Riverbend were seeking to establish a new landfill there. If a new landfill would not be appropriate at this site, an expansion should not be appropriate, and the permit should say so.

2. The permit should require public participation in efforts to modify the permit's terms, whether the modification is initiated by DEQ or by Riverbend. As drafted, the permit only requires DEQ to "notify" the public when a "significant" change is made. At the public hearing, DEQ stated that the public would have the opportunity to participate in any modification that allowed the landfill to expand, but that is not spelled out in the permit draft. The public's right to participate must be clearly stated in the permit.

3. The permit should require timely public "notification" of every adverse environmental event at the landfill. Currently, neighbors and regulators find out about leachate spills and methane emissions only long after the fact and often from the press or by incidental direct contact with the federal Environmental Protection Agency (EPA) or DEQ. The landfill should routinely inform neighbors about issues that affect them directly or via air, soil, and water quality pollution.

4. Riverbend should be required to host an annual (or semi-annual) community meeting to update the public on its progress toward closure and also to explain any adverse environmental incidents that have occurred since the previous meeting. The landfill's Air Quality (Title V) permit already requires semi-annual meetings; those meetings could be expanded to cover closure as well. In addition to presentations by landfill personnel, the meetings should also allow the public to make presentations and also require DEQ to present its findings/position on the issues discussed.

5. The permit should require Riverbend to return the land to farming when the dump is closed. This was required in the original permit granted by Yamhill County. The requirement was dropped when the landfill site was rezoned to PWS (Public Works Safety), but the land has been rezoned again, back to EFU (Exclusive Farm Use), so there's no legal barrier to requiring a farm use.

6. Each task involved in closing the landfill needs to be identified in the permit together with its projected cost and an explanation of the method(s) used to determine that cost.

7. The future of the 11 acres that are available for filling with waste should be spelled out in the permit, not left to the whim of Riverbend.

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