Council Vote for Filtration Treatment Includes Cost Containment Oversight

On Wednesday August 2, the Portland City Council met a public health requirement by selecting filtration to treat for Cryptosporidium. CUB supported this decision due to the significant system resiliency benefits of filtration over UV treatment. CUB takes our cue on public health risk from Multnomah County Public Health Officer, Dr. Paul Lewis, who called UV treatment “a one-trick pony”. Yesterday’s unanimous decision also requires the Portland Water Bureau (PWB) to regularly report to the City’s two public utility oversight groups, CUB and the Portland Utility Board (PUB), throughout the ten-to-twelve year planning, design, and construction process. This met CUB’s recommendation to evaluate the size and scope of the project. (Check out CUB’s detailed memo to the City Council that discusses “bronze” and “platinum” filtration plants.)

Crypto is a parasite that can cause gastrointestinal distress, which is particularly risky for infants and people with compromised immune systems. The Environmental Protection Agency (EPA) and the Oregon Health Authority (OHA) has required treatment since 2006. Given the relatively pristine Bull Run watershed, Portland had obtained a Crypto treatment variance. The OHA variance, however, required careful testing, and Crypto levels found earlier this year triggered revocation of the variance. Portland was required to select a treatment option and develop a new compliance agreement on a very tight timeline.

Commissioner Fish and Mayor Wheeler requested an additional ninety days and OHA responded by giving the City sixty more days to hammer out a compliance agreement. But the agreement needed to include the City Council’s treatment choice, and it was clear to CUB that OHA would not accept the much longer delay sought by some community members. It is important to remember that the terms of the Crypto treatment variance were quite clear and OHA revocation was always a possibility.

CUB did urge that the compliance agreement recommend filtration, but retain UV as a backup option pending completion of a scoping period to determine key size and cost parameters for the filtration plant. Our proposed scoping period would have ended no later than June 30, 2018. At that time, the City Council – as allowed under our suggested compliance agreement – could either proceed with filtration with improved information on scope or switch to the backup UV option.

Many testifiers inaccurately suggested that CUB recommended a delay until June 30, 2018. Our testimony and detailed memo to the City Council, however, clearly indicated that we were not seeking an OHA delay. Rather, we advocated for the compliance agreement with OHA to include this scoping period. The inaccurate references to CUB supporting a delay were so numerous that we appreciated Mayor Wheeler and Commissioner Fish allowing us to re-state our position later in the hearing.

The City Council’s response to CUB’s request was to insert into their resolution a requirement for regular reports to oversight entities throughout the planning, design, and construction steps. The first report is due on June 30, 2018. Under any scenario, we would have reviewed this project every step of the way, so the required reports from PWB will be useful in our continued monitoring.

The starting point for this discussion was a recommendation to first build a UV plant, and then collect and set aside money to build a filtration plant in 25 to 30 years when UV facilities require major renovation. Mayor Wheeler was particularly interested in this approach in hopes that PWB could repurpose elements of a UV plant for an eventual filtration facility.

The Mayor accepted CUB’s analysis that a UV plant would not be an appropriate steppingstone to filtration. The Mayor also engaged in a detailed discussion with CUB’s Advocacy Director, Janice Thompson, about why the appealing notion of saving for the future was not consistent with utility financing best practices. CUB pointed out the inappropriate cost burden shift given the long period between collecting money from current customers and construction of a filtration plant that would primarily benefit future customers. There were also inadequate assurances that a future filtration plant would ever be built.

The overall cost of UV first - then filtration approach was higher than filtration-only. In addition, UV treatment only addresses Crypto, while filtration provides additional benefits, particularly addressing turbidity (dirt in the water) due to winter storms or a forest fire within the watershed. The City estimates the value of the additional filtration benefits at $99 million over the next 25 years.

And while Filtration plants also require upgrades, they last significantly longer than the 25 to 30-year lifespan of UV plants. Finally, it was clear to CUB and the City Council that regulators would not extend the variance and that either UV or filtration treatment was required.

Obviously, even a “bronze” filtration plant will be expensive, but the resolution requires improvements in programs addressing needs of low-income Portlanders, a key point for CUB. From a least cost/least risk perspective, filtration is the best long-term investment.

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