After many years of delay, Oregon Department of
Environmental Quality (DEQ) is about to renew the permit that allows Clean
Water Services (CWS) to discharge wastewater and stormwater to the Tualatin
River system.
There are some great innovations in the draft permit.  Clean Water Services will be permitted to use
“natural treatment systems” at Fernhill Wetlands to clean and cool effluent
from the Forest Grove Wastewater Treatment Plant before it enters the Tualatin
River.  The project has also become a
tourist attraction with beautiful Japanese style gardens and wetland habitat
aimed at attracting migratory birds. 
Using wetlands for final treatment saves energy and reduces CO2
emissions.  An extensive monitoring
program will assure that this pioneering approach is working and help inform
changes that could improve the system.

Another significant innovation is allowing Clean Water
Services to produce ultra-pure water from their effluent.  This is happening on a tiny scale for demonstration
that effluent from the wastewater treatment plant can be further treated to
produce water suitable for any domestic use including drinking (and making

Combining all four wastewater treatment plants has allowed
for efficiencies and innovations in treating wastewater.  The permit has also allowed innovative
programs such as Tree-for-All that allow CWS (and partners) to plant native shade trees along
creeks to cool the water, rather than cooling the discharge from their
wastewater plants by energy intensive and expensive methods.  But combining the wastewater permit with the
stormwater permit has delayed implementation of sustainable stormwater
management innovations.  Other large
urban areas (Clackamas County, Eugene, Portland, and Salem) had their municipal
separate storm sewer (MS4) permits renewed years ago.  Because the CWS’ stormwater permit was combined
with the wastewater permit, and DEQ was delayed by litigation that challenged
water temperature standards, the CWS stormwater permit was not renewed on time.

Almost 3 years ago, CWS and its partner cities stopped a
process to revise the Design and Construction Standards that was supposed to be
completed and adopted by the end of 2014. 
Without the permit renewal forcing the issue, city engineers resisted
improvements to the standards and the process was tabled indefinitely.  The cities own and operate their own parts of
the municipal separate storm sewer system.
Now that the renewal of the stormwater permit is finally
happening, Tualatin Riverkeepers are looking for significant improvements that
will protect our neighborhood creeks from polluted, erosive stormwater runoff,

Main Street rain garden with trees in Tigard
Main Street Tigard rain garden with trees.

Using urban
on streets, parking lots and upland areas to reduce stormwater
runoff.  TRK asked that the permit and
Design & Construction Standards adopt urban forestry standards that were
recently developed by the City of Tigard and have received national awards.

impervious surfaces
that generate stormwater runoff don’t allow stormwater
to soak into the ground.  This was called
for in the 2005 Healthy Streams Plan adopted by Washington County and its
cities.  Porous pavement, rain gardens,
green roofs are all techniques that can reduce effective impervious area and stormwater
runoff.  The Riverkeepers have asked that
individual cities be tracked for their effective impervious cover reduction.

water recycling including harvesting
of stormwater for domestic uses.  Cities
in the Tualatin Basin import water from distant rivers including the Trask,
Clackamas, Bull Run and Willamette. 
Pulling water from these rivers impacts these rivers and requires expensive
pipelines and energy intensive pumping. 
Locally stormwater is dumped into the nearest creek, causing significant
erosion and habitat damage.  Capturing
rain and using it where it falls is much more sustainable than importing water
from distant watersheds.

Make land
use decisions
that prevent polluted, erosive, stormwater runoff and accommodate
sustainable natural stormwater management techniques.  Recent land use decisions have focused new
development in areas with shallow slow draining soils, steep slopes and
encourage deforestation.  Cooper Mountain
and River Terrace are areas with slopes and bedrock close to the surface that precludes
stormwater infiltration.  The cost of providing
utilities, including stormwater management is significantly higher in these

trash in creeks

  • Reduce trash
    in the creeks
    .  Urban creeks collect
    a lot of trash.  Stormwater permits in
    Southern California require the cities to prevent this from happening.  We can do better too.

stream temperatures
by modifying small dams on tributary creeks.  These dams spread the water out to act like a
giant solar collector, making the water too hot for our native trout and

Tualatin Riverkeepers is looking forward to an improved
watershed permit from DEQ that will guide improved public policy that cleans and cools our water
and makes our river and neighborhood creeks healthier for fish, wildlife and

Read Tualatin Riverkeepers’ comments to DEQ.