Oregon Coastal Drinking Water Protection Planning: A Resource Guide
Initial Review comments from Oregon Department of
Forestry
October 2, 2015

Summary of Key Issues and Concerns
The purpose and audience of the document is unclear. The document does not provide adequate
information to serve Public Water Systems (PWSs), which may wish to update their source water
assessments or perform analysis to increase potential protection of drinking water. At times, the
document seems to be responding to citizen group concerns about forest management, rather
than doing an unbiased analysis of threats to drinking water. The unit of analysis is also unclear.
The document switches focus between PWSs and watersheds as the unit of analysis. The work
flow diagram for updating source water assessments (Aug. 15 Draft) indicates that the unit of
analysis is the PWS, with a subset selected using geographic area or set of similar set of
characteristics/challenges. Given the focus on Coastal PWSs and surface watersheds, one might
expect that Coastal PWSs with surface water sources as their permanent sources was basis for
selection. However, the 50 included PWSs do not consistently follow these criteria, e.g.,
document includes PWS that only use surface water as their emergency sources.
The report states that the document will provide the foundation for updated Source Water
Assessments for each PWS (page 1) and provides the basis for updated assessments of individual
watersheds (page 2). However, the guide does not provide any significant information on source
water protection for ground water sources (e.g., springs and wells), even though nine of the
PWSs use ground water sources. The document does not contain a methodology section on how
to update a source water assessment. The document does provide an uneven mix of information,
data, suppositions, and assumptions without a clear discussion on the methodology, limitations,
and uncertainty for the data and information provided (e.g., limitation of the DOGAMI landslide
data and landslide risk model).
With regards to the landslide susceptibility modeling, it is unclear how the data and information
from the Storm Impacts and Landslides of 1996: Technical Report #4 was used to develop both
the susceptibility rating of landslide potential. The information from that study was not designed
to be used as a predictive model as it was based on individual watersheds with unique

 Oregon Coastal Drinking Water Protection Planning: A Resource Guide
Initial Review comments from Oregon Department of Forestry

characteristics and under a severe storm event. In a comparison of the mapped landslides from
SLIDO 3 and the predictive tool for landslide susceptibility it appears that many of the mapped
landslides did not occur in areas identified as high risk for landslides. It also remains unclear
what the table of landslide risk rating is meant to describe. Does the table represent that 50100% of the landslides will occur in areas with specific landform features or does it mean that
50-100% of the area is more prone to landslides, or something else entirely.

The draft guide contains many statements that might be viewed as value judgements about the
adequacy of current land use regulations and/or risks of private forestland management. It also
reiterates suppositions about causal nature of water quality issues, without supporting scientific
analysis. The most glaring example of the reiteration of presuppositions is the attempt to link
disinfection by products (DBPs) with turbidity. DBPs are formed through the reaction of
chemical disinfectant (chlorine dioxide, chloramines, ozone) with an organic precursor and an
inorganic precursor, most often certain halide ions. The organic precursors include natural
organic matter, algal organic matter, and wastewater effluent organic matter. The report suggests
that the organic precursors may be related to forest management (page 21) or suggest that it is
related to excessive turbidity (page 1). The document provides no analysis (e.g., correlation of
BHPs alerts with periods of high turbidity) for these suppositions and some data contained in the
report suggest the opposite. The report identifies the City of Astoria (PWS 00055) as having the
highest frequency of DBPs alerts, while DEQ’s 2010 Turbidity Analysis for Oregon Public Water
Systems states that the Astoria PWS has low turbidity. There are also several statements that
describe the use of “standard treatment technology” See page 9. “The fundamental goal of
source water protection is this: if the CWA standards are met in source waters, a drinking water
treatment plant using standard treatment technology” should be able to generate water meeting
the safe drinking water standards”. What exactly is meant by “standard treatment technology”?
Does that mean what PWSs are currently using based on existing infrastructure or something
else? A major component of the SDWA (Section 1452) is to provide grants and loans to assist
with drinking water treatment facility development. Watersheds in the coast range are subject to
frequent large storm events during winter months that causes short term increases in turbidity.
These events are outside of the control of watershed management or land use practices and will
require additional technology or storage solutions.
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 Oregon Coastal Drinking Water Protection Planning: A Resource Guide
Initial Review comments from Oregon Department of Forestry

The section on Strategic Restoration and Protections provides an impression that identifying,
prioritizing, implementing a protection plan, and conducting monitoring is a task that most PWSs
can undertake. This appears overly simplistic and could lead to providing a false sense of
expectations of what is required to perform these tasks in rational manner. Even with state and
federal agencies, stakeholders, and the public it is takes time, effective leadership, and dedicated
resources to perform strategic restoration and protection and these accomplishments are not a
trivial task.

The data contained in Appendix 2 Coastal Watershed Land Use and Susceptibility Analysis has
numerous inconsistencies and unclear application of information. The tables in this appendix
need thorough review and revision. In Table 1 Summary of Land Use/Ownership, 15 of the 50
PWS are missing sources, i.e., the PWSs has source not listed in the table. For example, the
table does not list SCR-AB, Little Fat Buck Creek for the Wickiup (PWS 00063), SRC-AA Bay
Hills Reservoir for the Bay Hills Water Association (PWS 00564). Note: for PWS 00564, the
table list an unnamed creek, which is not listed in the PWSs online system information. The
listing of sources, except for a few exceptions, does not identify source type as permanent,
seasonal, or emergency. For example, for the Manzanita Water Department (PWS 00505) the
table lists two of its three emergency sources, but does not include the primary source (Wheeler
Water System, PWS 00952). For Wheeler, the table lists two abandoned surface water sources,
but does not list its permanent or emergency sources. Appendix 2 is also inconsistent with the
level of detail on mapped landslides from SLIDO (Table 2). It is not clear when there are PWSs
with no data on mapped landslides or when there actually may not be landslides. Based on the
disclaimers in SLIDO it may also be inappropriate to use SLIDO for this analysis. There appears
to be incomplete reporting and inconsistencies in the alerts listed in Table 3. While we did not
check all the PWSs included in the Table, spot-checking indicated differences between alerts
reported and the number listed in the online data system. In addition, alerts for many chemicals,
e.g., copper, lead, sodium, are not listed in table. The Table also implies a linkage between the
source water area and the alerts. Given that the many of the sources are missing, this linkage is
misleading as many of the test results (e.g., TTHM and HAA5) are at the output end from
multiple sources or from sources not listed in the table. For example, the alerts for Cannon

October 2, 2015

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 Oregon Coastal Drinking Water Protection Planning: A Resource Guide
Initial Review comments from Oregon Department of Forestry

Beach (PWS 00164) are for ground water sources, but the only sources identified in the table are
surface water sources.
It is also important to note that the original final draft provided very little information on the role
of ODF. Both in regards to day to day interactions with the public and landowners/operators and
FPA implementation by Stewardship Foresters and also the technical and financial resource
programs that are administered by ODF. These sections have been added to in order to capture
these services.

October 2, 2015

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