Implementation of LT2 threatens historic protections and creates expensive reliance on energy-intensive infrastructure.

• Due to generations of citizen advocacy, the Bull Run Management Unit is one of the most stringently-protected, federally-protected watersheds in the United States.
• It is a unique, green, elegant, gravity-fed water system with no carbon footprint.
• Strict limits on human entry have been in place for over 100 years and, even today, unregulated entry and activity by members of the public and by domestic animals is       completely prohibited.
• There is no sewage exposure from agricultural, industrial, recreational or municipal sources.
• A cryptosporidium outbreak has never been caused by Bull Run drinking water.
• The general prohibition on entry into the Bull Run Management Unit by humans or domestic animals ensures that cryptosporidium will not pose a public health threat. Consistent water purity is a direct result of the watershed’s isolation from human entry and development and the exclusion of livestock.
• The only possibility of cryptosporidium exposure in the watershed is through wildlife. But the incidence of crypto caused by wildlife habitation is so low that it has never before interfered with the City’s ability to meet or exceed local, state and federal drinking water standards.
• The isolated and protected nature of the BRMU limits the occurrence of crypto to levels that are so low that they are not a “measurable source of exposure.” City of Portland White Paper, Long Term 2 Enhanced Surface Water Treatment Rule at 7 (June 2005)  (EPA-HQ-OW-2002-0038-0719)
• The major outbreaks of cryptosporidiosis that the EPA cites as examples of the danger from drinking water actually resulted from sewage leaks, not the natural occurrence of crypto in closed and protected watersheds.
• To insist that the City install costly new facilities to combat a pathogen occurring so rarely in the Bull Run that it poses no measurable health threat would waste scarce public resources and potentially divert them away from the protection of the source watershed, in direct contradiction to the goals of the 1998 Safe Drinking Water Act Amendments.
• Bull Run federal legislative protections of 1996 and 2001 were put in place in part to ensure that residents of the City could ensure the safety of our water through watershed protections and avoid the costs of additional treatment, including filtration.
• Once water filtration infrastructure is put in place, pressure will dramatically increase to open the Bull Run to logging, development, and other human activities – all of which will bring people and pollution, including but not limited to cryptosporidium, into the watershed.
• Additional Impacts – There are a number of uncertainties regarding the environmental and health impacts of various water treatment technologies.  Among these are concerns regarding potential leachates from membranes that are made from petroleum products, a continuous waste stream of sludge generated by filtration systems, and possible hazards related to mercury in ultraviolet lights. Filtration systems may allow aluminum, iron salts and synthetics to enter the drinking water distribution system. Burying or covering open reservoirs can increase the risk of nitrification in chloraminated systems like ours through the exclusion of sunlight and growth of bacteria.
• Energy- intensive Carbon Footprint – Large new treatment facilities will require significant energy resources to build, operate and maintain.