Portland Harbor Community Advisory Group comments to the National Remedy Review Board

The Portland Harbor Community Advisory Group has submitted comments to the EPA's National Remedy Review Board asking for a more vigorous cleanup plan for the lower Willamette River.

Attached here are comments submitted October 19th to the National Remedy Review Board from the Portland Harbor Community Advisory Group.

Our recommendations were announced at a press conference held Cathedral Park.

Below is the prepared comments made at the press conference (actual comments varied):

Statement to the National Remedy Review Board from the Portland Harbor Community Advisory Group.
October 19, 2015
http://portlandharborcag.info/sites/default/files/CommentstoNRRBfromPHCA...

1) Jim Robison, chair of the Portland Harbor Community Advisory Group -
introduction - 2-3 minutes

The Portland Harbor Community Advisory Group represents citizens in the superfund process on the lower 11 miles of the Willamette River. I'll be making a statement about the paper that the Advisory Group is turning in to the EPA National Remedy Review Board today, and then I will introduce two other speakers from the community.
This paper provides detail on a number of key issues of community concern regarding the proposed cleanup plan for contaminated sediments in the river. For thousands of years, the Willamette River provided food for thousands of people. It is relatively recent that it became a health risk to eat the fish from river. The contamination in the river sediment presents risk to humans, river life, wildlife and the environment. These contaminants include heavy metals, PCBs, PAHs, DDTs, dioxins and furans.
None of the cleanup alternatives prepared by the Lower Willamette Group and revised by the EPA, labeled Alternatives B through G, will achieve either fish that are safe to eat or satisfy requirements of the Clean Water Act. We have told the EPA that we want a cleanup plan that says at the end, there will no longer be a need for fish advisories like the sign posted here.
Engineers have a saying; you can do it fast, cheap and right, pick two. Citizen advisers and community partners maintain that getting the cleanup done right is more important than getting it done fast and cheap. We favor maximum removal of contamination from the lower Willamette that will offer a long-term, effective solution.
Contamination left behind is a continuing risk to human health and the environment. EPA needs to address these issues by implementing a more vigorous remedy — an alternative we call G+.
I will now ask Alex Lopez, member of the Portland Harbor Community Coalition, to make a statement.

2) Alex Lopez, Portland Harbor Community Coalition - Environmental Justice and Cumulative Risk of Contaminants Left in the River - 2 min

It is critical to protect underserved members of our community who have suffered exposure to river contaminants for many decades. These effects include direct health impacts, the psychosocial stresses of living with contamination in our community and the loss or reduction of critical community opportunities such as subsistence and cultural fishing, recreation and access to the river. We are particularly concerned about members of the houseless community living in contaminated areas, underserved communities that rely on subsistence fishing for both cultural and economic reasons, and neighborhoods that experience exposure due to being near the river. Minority and Native American communities, and those in the neighborhoods where there is more industrial activity have been exposed to cumulative contaminants and EPA needs to address both Environmental Justice and Cumulative Risk issues.

The end result of any of the options currently offered would continue to be a severely contaminated river. Our underserved communities would remain at risk for generations, fish and wildlife populations would continue to experience significant harm through bioaccumulation of contaminants, and access to the river would remain restricted. The community has already lived with decades of contamination and persevered through a 15-year Superfund process. It is time now to move forward with an effective, vigorous, long-term clean-up strategy that places a significantly higher priority on removing polluted sediments from our river. We call on EPA to implement a more aggressive plan described in more detail in our paper—Alternative G+. This alternative will reduce the acreage of Monitored Natural Recovery, reduce the extent of capping and increase the amount of surface contamination removed.

3) Jackie Calder, Vice Chair, Portland Harbor Community Advisory - It is time to
hear from the Community - 2 min
A clean river could be an integral part of our community, providing recreation, food through fishing, an attraction for development and visitors, and could build our identity as a gateway to nature. We take seriously the goal of a long-term remedy meant to last into future centuries and recognize this process as a unique opportunity. We have persevered though this long process for more than ten years despite delays by polluters, external pressures and the challenges of bringing together a very diverse community. Now it is finally time for the community to be heard.
Communities adjacent to the North Reach of the Willamette have been a historic dumping ground for the negative effects of industry including not just the superfund site, but hazardous materials tank farms, industrial air pollution, diesel exhaust and truck movement. North Portland is also the location for a sewage treatment plant and a major, former dump. As St. Johns activist Ben Poe said, "North Portland is becoming weary of being the repository of everything that stinks, burns or blows up." Alternatives that leave either significant amounts of contamination in the river or which result in a Confined Disposal Facility are inequitable and environmentally unjust, and add to the cumulative effects on community members.
The contamination in Portland Harbor directly undermines long-term investments in the river by the community that is already in the millions. The cleanup is also a revenue and job generator. An EcoNorthwest Study of the lower Willamette showed that every dollar of cost to clean-up will generate more than a dollar’s worth of economic activity.
The river is held in trust for citizens, from headwaters to confluence. It is our river. This is our one chance to make a difference in the lower Willamette River. Let's have the fortitude to ask that the cleanup be done right the first time with Alternative G+.

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CommentstoNRRBfromPHCAGr.pdf1.91 MB