January 17, 2011
January 17, 2011
Oregon Prepares to Add Big New Hurdle for Manufacturing Jobs – Highest in the Nation
— While most states are attempting to keep or attract manufacturing jobs, Oregon may be heading the opposite direction.
By John Ledger
Associated Oregon Industries
Oregon is the process of adopting the most stringent water quality standards in the nation; in some cases below natural background levels. The proposed levels are so low that many existing Oregon facilities’ ability to compete, expand or even continue to operate will become problematic even they are not adding any pollutants – just removing water for cooling purposes and returning it directly to the river.
The range of pollutant is exceedingly broad. Many are not directly emitted by industrial sources, simply the result of soil erosions or natural background that flows in with the intake water, although there are some important exceptions. Nevertheless, even if a facility adds no pollution to its wastewater stream, the fact that it takes in water that exceeds the standards for any of the listed pollutants means it will likely return those same pollutants back into the river and its effluent will be considered a toxics discharge. Hence, the facility will need a permit variance for each of those pollutants if it wishes to operate.
If you discharge into a municipal system, the system may require more pre-treatment or funding for new construction.
The key to a faculty’s ability to remain in operation will reside with how, if, and under what conditions the DEQ builds in a workable, and not prohibitively expensive, variance process. At this point, it appears problematic; Oregon has issued few, if any such variance. It is unknown if the EPA will even approve variance rules as developed by the state. If a variance is approved by the DEQ, the federal EPA may disallow or simply not act on it. And environmental permitting in Oregon has become increasingly politicized, difficult, and uncertain. Activist third party opposition is an all but given.
For facilities that actually discharge new pollutants, or considering expansion or locating in Oregon, the process will be much more and may be prohibitive, or at least, unattractive.
The proposed standards are the result of environmental group’s legal actions and a determination by the Environmental Quality Commission (EQC) that the tribal fish consumption rate (used to back-calculate in-stream standards) is about 140 pounds of Oregon-caught fish per year. This results exceedingly low allowable concentrations.
AOI has been in close discussions with the DEQ, participated in workgroups, and is, through its Water and Cleanup Committee, coordinating the business community’s response to the rules.