July 28, 2000

Linda Rankin
Department of Ecology
Olympia, WA 98504-7600

RE: CZMA Concurrence Decision for U.S. Army Corps of Engineer's Columbia and Willamette Channel Deepening Project

Dear Ms. Rankin:

Northwest Environmental Advocates (NWEA) submits these comments on the proposed Coastal Zone Management Act (CZMA) consistency for the Channel Deepening Project (the Project) on behalf of its members, many of whom reside, work, and recreate in the Lower Columbia and Willamette Rivers, and on behalf of the Northwest Environmental Defense Center (NEDC). NWEA has worked to bring attention to and solve the environmental problems facing the Lower Columbia River since 1988, including advocating for National Estuary Program designation, co-chairing the Bi-State Lower Columbia River Water Quality Study, preventing new pollution sources to the river, publishing the educational map Columbia River: Troubled Waters, taking the public on RiverWatch educational boat tours of the Columbia and Willamette Rivers, and using legal advocacy to implement the water quality-based regulatory programs of the Clean Water Act.

The Corps seeks a coastal concurrence from the Department of Ecology (DOE) for deepening the Columbia and Willamette channels by three feet, concurrent deepening of six turning basins (three in each river), and disposing of sediments from the Mouth of the Columbia River (MCR) project and upriver dredging operations in ocean disposal sites for 50 years, based on the project description in the Final Environmental Impact Statement (FEIS). However, in its Coastal Zone Management Act Consistency Determination (Consistency Determination), the Corps does not mention the Willamette, avoids discussion of the 50 year Ocean Dredged Material Disposal Site (ODMDS) plan, and fails to adequately discuss coastal zone consistency compliance in several areas.

NWEA and NEDC find that the Corps' project as outlined in the FEIS is inconsistent with Washington's Coastal Zone Management Plan (CZMP) and:
· Ignores resource agency comments and concerns that surfaced during the Draft EIS comment period;
· Includes no mitigation for aquatic impacts;
· Includes no beneficial use of dredged material slated for ocean disposal;
· Is inconsistent with water quality standards affecting the Coastal Zone; and
· Negatively impacts the current efforts to restore threatened and endangered salmon populations in the Columbia Basin.

These conclusions lead us to dispute the Corps' finding of no significant impacts. The Project as outlined in the FEIS will have substantial negative impacts to the natural resources and economy within the Coastal Zone. For the following reasons, we advise the Department to disagree with the Corps' Consistency Determination and delay issuing permits until these issues are resolved. Furthermore, these issues warrant the Department to request a Supplementary Environmental Impact Statement (SEIS). At the very least, the Department should demand a new consistency determination that is both accurate and complete and includes adequate supporting material with references to support its conclusions.

DOE must act on its responsibility to protect Washington's natural resources.

We trust that DOE is well aware that its interests and responsibilities differ from the Corps'. It is not the Corps' job to protect Washington State's resources. That responsibility, by law, falls to DOE:

State to represent its interest before federal agencies, interstate agencies and courts. The state, through the department of ecology and the attorney general, shall represent its interest before water resource regulation management, development, and use agencies of the United States, including among others, the federal power commission, environmental protection agency, corps of engineers, department of the interior, department of agriculture and the atomic energy commission, before interstate agencies and the courts with regard to activities or uses of shorelines of the state and the program of this chapter. Where federal or interstate agency plans, activities, or procedures conflict with state policies, all reasonable steps available shall be taken by the state to preserve the integrity of its policies.

RCW 90.58.260. Consistency with state coastal zone management goals and water quality criteria are matters of state sovereignty. DOE is charged with representing the interests and concerns of two other state agencies, the Department of Fish and Wildlife, and the Department of Natural Resources. All three agencies are responsible for protecting and enhancing the state's natural resources. The Corps' unsubstantiated finding of no significant impact is not a valid argument against DOE asserting regulatory authority over activities taking place outside of Washington's coastal zone that will have direct effects on the coastal zone. The Corps's mission is fundamentally different from DOE's. The two cannot mingle in closed-door negotiations that have characterized this process since the FEIS was released.

DOE's decision to delay review of this project until the last minute will have severe consequences on Washington's natural resources unless the agency rejects the Corps' Consistency Determination at this time. Until it can devote adequate staff time and expertise to the task of assessing the impacts of the Project on Washington's natural resources, the only responsible action is only to deny the Corps Consistency Determination.

The Coastal Zone Management Act Consistency Determination is not reflective of the project as outlined in the FEIS.

The project describes the use of ocean disposal sites for the 50-year life of the project. Nowhere in the Consistency Determination does the Corps mention and request such certification. This is a point which deserves special consideration, as coastal zone consistency would be granted for the life of the project: 50 years, and beyond.

In addition, the Corps makes absolutely no mention of the Willamette portion of the project in the Consistency Determination, although the project being authorized includes both rivers in the FEIS. Its deepening would violate the Clean Water Act and statewide water quality standards. We incorporate our comments to Oregon Department of Environmental Quality on the matter of Clean Water Act Section 401 attached, by reference. A DOE approval of the Consistency Determination would be an approval of all actions that are included in the FEIS, including those proposed for the Willamette.

In particular, we are concerned with the Corps' assertion that: "The Corps proposes to use the ODMDS's (Ocean Dredged Material Disposal Sites) to dispose of sediments dredged from the federally authorized navigation project at the Mouth of the Columbia River and in the future to dispose of sediments from the other Columbia River projects. The North Jetty Site could also be used for those same dredged materials. These could include the Columbia and Lower Willamette River Federal Navigation Channel and future channel deepening projects if authorized." FEIS, Appendix H, Vol. I, p. H-21 (Emphasis added) In this statement, the Corps leaves all of its options open for sediment disposal, from any location, to any location. Therefore, DOE could very easily approve an action for which there is no analysis or determination: the impacts that the Willamette project can have on the health of the estuary and coastal zone.

These oversights make it extremely unclear to the reviewer which actions DOE is actually being asked to certify. The confusion is rooted in the fact that DOE is being asked to issue a coastal concurrence on three distinct actions: 1) Deepening the Columbia and three turning basins, 2) Deepening the Willamette and three turning basins, and 3) Disposing of over 250 million cubic yards (mcy) of sediments in 15 square miles of ocean sites over the next 50 years.

The Corps Requests Coastal Concurrence Before Sufficient Documents Are Available for DOE's Review.

At present the Corps has released no Record of Decision selecting an alternative. Legally, then, no alternative has been selected. Which alternative is DOE officially being asked to approve? Furthermore, the project may undergo significant changes during the Planning and Engineering phase. Will DOE have opportunity to make any revision to its coastal zone certification decision if significant changes are made? Moreover, the states have not yet issued their Clean Water Act Section 401 Water Quality Certifications. DOE cannot fully evaluate the impacts to the Coastal Zone from this project in the absence of these documents.

The Corps Does Not Validate the Scientific Integrity of Its Conclusions

Without the previous mentioned documents, DOE has only the Corps' FEIS and federal agencies' Biological Opinions to work with while determining coastal zone consistency. The FEIS is self-contradictory, vague, and presumptuous. During public review of both the Draft EIS and FEIS, substantial concerns were raised about the science behind the Corps' conclusions. In response to one comment letter, the Corps claims to "have no legal obligation under NEPA to 'ensure the scientific integrity of [its] studies.'" Furthermore, the Corps stated that it was "entitled to rely upon [its] own experts' studies, and under no circumstances need it affirmatively defend those studies' 'scientific integrity.'" According to the Corps, even if comments "had produced some evidence that the Corps' experts lack proper qualifications or relied upon flawed scientific methods, …that evidence would not discredit or otherwise render the Corps' studies unreliable or its EIS legally inadequate."

Surely, this does not reflect positively on the Corps' overreaching conclusion that "no significant impact would result from this action." Consistency Determination at page 1 For example, upon consulting its science advisors, the Corps concluded that Portland Harbor Sediments are clean and clear for "unconfined in-water disposal." Yet the Corps has no grounds to assert that the deepening will not reveal any contaminated sediments in the Willamette reach, regardless of what "science" the agency relies on to make such claims. Deepening of the Willamette will impact the current overall toxic contamination of the estuary, as discussed in our attached comments to Oregon Department of Environmental Quality on Clean Water Act Section 401 Water Quality Certification.

In the just-released All-H paper, Habitat Program Objectives state that the overarching objectives of the federal program include preventing further degradation of water quality and habitat in estuaries. The matter is of such great importance that George T. Frampton, acting chair of the Council on Environmental Quality, stressed the critical nature of estuary habitat because all endangered salmon rely on its resources for survival in a recent interview. Despite the increasing national awareness of the critical need for estuary habitat, the Corps still plans to conduct construction dredging year-round for two years, regardless of timing windows established by federal agencies to protect our resources, particularly endangered species of fish.

The Project Is Out of Compliance With Washington CZMP

The CZMA states that the Corps must adhere to the state and local coastal zone program to the "maximum extent practicable," meaning that the activity must be fully consistent with the CZMP and local shoreline management plans "unless compliance is prohibited based upon the requirements of existing law applicable to the Federal agency's operations." 15 C.F.R. § 930.32(a) We are not aware of any existing law that shields the Corps' operations from having to be in full compliance with Washington's CZMP which includes the Shoreline Management Act and associated county shoreline management master plans, the State Environmental Policy Act (SEPA), the Clean Water Act, and the Ocean Resource Management Act (ORMA), along with four other state laws. These laws contain provisions intended to protect the very resources that will be destroyed by the channel deepening project. Furthermore, the Corps' Consistency Determination does not evaluate consistency with each county's Shoreline Management Master Plan. Had the Corps done so, it would have found that the Project does not comply with goals and objectives of those plans.

State law (R.C.W. 43.143.030) also dictates that uses or activities that require state or local government permits and that adversely impact natural resources, marine life, fishing, water quality, or other ocean or coastal uses be permitted only if these criteria are met or exceeded:

• There is a demonstrated significant local, state, or national need for the proposed use or activity,
  
• There will be no likely long term significant adverse impacts to coastal or marine resources or uses,
  
• All reasonable steps are taken to avoid and minimize adverse environmental impacts, with special protection provided for the marine life and resources of the Columbia River,
  
• All reasonable steps are taken to avoid and minimize adverse social and economic impacts, including impacts on fishing,
  
• Compensation is provided to mitigate adverse impacts to coastal resources or uses,
  
• Plans and sufficient performance bonding are provided to ensure that the site will be rehabilitated after the use or activity is completed, and
  
• The use or activity complies with all applicable local, state, and federal laws and regulations.

A. Ocean Dredged Material Disposal Sites

The Corps is intent upon designating a new ocean disposal site in biologically productive waters upon which commercial crabbing and fishing communities up and down the coast depend, despite concerns raised by agencies and stakeholders. The Corps has asserted that the project will not have adverse affects, despite proven losses to the crab industry from prior disposal operations. However, under ORMA, DOE must address the impacts of the proposed Deep Water Site (DWS) on coastal crabbing and fishing industries and communities. Washington's Guidelines for Ocean Management apply 200 miles seaward from the coast. RCW 43.143.020; WAC 173-16-064(2) According to those guidelines, DOE must consider ocean uses such as commercial, recreational, and tribal fishing as well as shellfish harvesting. WAC 173-16-064(3) The DWS not only falls within the 200 mile jurisdiction laid out in the Guidelines but will also impact Washington communities and commerce. Moreover, the public notice itself states that "This project is located within or will have a direct effect on Washington's coastal zone."

There have been major deficiencies in the site designation process. Contrary to the legal requirements of NEPA, concerns like those identified below have gone unanswered. An SEIS on Ocean Dredged Material Disposal Sites (ODMDSs) off the mouth of the Columbia River is required. For these reasons, we request that DOE not seek designation of the ocean water site until proper studies have been done, the site size meaningfully reduced, and impacts quantified and mitigated.

1. A demonstrated need for the Deep Water Site size and buffer zone has not been provided.
The Corps' FEIS does not demonstrate the need for a 225 million cubic yard (mcy) capacity disposal site, as is required by state law. RCW 43.143.030 The Corps has not offered any explanation for the 3,000 foot buffer zone which adds an additional 4,700 acres to the 4,300 acre disposal site, doubling the site size. Since the Corps limited mound height and mound height analysis to 40 feet, it will not analyze wave action over 60 foot mounds, even though 60 foot mounds could be found safe for navigation and reduce the footprint of the DWS. The ocean disposal sites cover 20 times more acreage than upland disposal sites. This strongly illustrates the Corps' complete disregard for the value of the ocean environment.

2. The Deep Water Site has not been characterized.
The FEIS implies that the DWS is well characterized, even though the management and monitoring plan acknowledges that little is known about the biological activity at the site. At H-5, FEIS Appendix H, Volume I. Even on the eve of official site designation, the Corps has not yet conducted baseline studies to characterize the biology of the bottom habitat in the area. Six benthic sampling stations in the DWS are single-point locations on the shallow edge (150 foot depth); no sampling on remaining 8,000 acres, which reaches depths of 300 feet. Sediment from the channel is known to be coarser than that on the ocean floor. No fish survey data exist for any portion of the site. Surveys are necessary to identify mud bottoms and key habitat for halibut populations. "Pre-project environmental baseline inventories and assessments and monitoring of ocean uses should be required when little is known about the effects on marine and estuarine ecosystems, renewable resource uses and coastal communities." WAC 173-16-064 (7)(v) The site should not be designated as a disposal site until this information is collected and the impacts of long-term disposal on natural and commercial resources are evaluated.

3. Devastating impacts to crab and groundfish habitat and commercial crabbing and fishing industry would result.

Despite the Corps' unsubstantiated finding of no significant impacts, the proposed DWS could mean losses of up to 87,230,000 pounds of crab over the 50 year life of the project, according to Columbia River Crab Fisherman's Association calculations. Such losses disproportionately levy negative economic impacts to coastal communities and state law requires that those losses be compensated.

Studies done to determine impacts of disposal events on crabs were extrapolated beyond the limits of the experimental data. In addition to the inaccurate testing conditions, further impacts like food and habitat loss will continue to impact populations of crab and other benthic organisms. Entrainment, habitat carrying capacity, and impacts to total population were not considered in the FEIS. The FEIS claims that Dungeness crab populations rebound from disposal events within one year. However, prior experience of crab fisherman on previous disposal sites have proven them to be incapable of supporting crab populations for commercial harvest. The impacts of the excessive 15 square-mile DWS on commercial resources were not quantified and no mitigation or compensation is planned. Marine Protection, Research and Sanctuaries Act (MPRSA) requires quantitative analysis of adverse impacts (ie. percentage of commercial resources lost). 33 U.S.C. § 1412(a)(B), (C), (D), and (H).
"The administrator shall establish and apply criteria for reviewing and evaluating such permit applications, and . . . shall consider . . . the following: (B) the effect of such dumping on human health and welfare, including economic, esthetic, and recreational values. (C) The effect of such dumping on fisheries resources, plankton, fish, shellfish, wildlife, shore lines and beaches. (D) The effect of such dumping on marine ecosystems, particularly with respect to (ii) potential changes in marine ecosystem diversity, productivity, and stability, and (iii) species and community population dynamics. (H) The effect on alternate uses of oceans, such as scientific study, fishing, and other living resource exploitation, and nonliving resource exploitation. RCW 43.143.030(2)(f)
At this time, no timing windows to protect soft-shelled crabs from entrainment or disposal events are outlined in the plan. These should be required. Furthermore, no studies gauging contamination levels in crab are proposed to monitor impacts of ocean disposal of potentially contaminated sediments on commercial resources.

4. EFH requirements
According to 16 U.S.C. § 1802(10), Essential Fish Habitat (EFH) mean "those waters and substrate necessary to fish for spawning, breeding, feeding or growth to maturity." It is commonly believed that flatfish nursery exists at the DWS, though its location has not been confirmed. Baseline studies including biological surveys have not been completed. Such a nursery would constitute EFH under the Magnuson Fisheries and Conservation Act U.S.C. § 1801. EFH consultation with NMFS is required, though the Biological Opinion resulting from consultation with the Corps did not include impacts to EFH. DOE should not approve current disposal plans without NMFS having reviewed EFH impacts.

The Corps has stated that it will control dumping locations to avoid the most sensitive habitat within the site. However, the Corps cannot avoid biologically sensitive areas without plans to look for them. Furthermore, disposed sediment must drift through 200'- 300' of water before reaching the ocean floor, making the Corps plan to "avoid" sensitive areas ridiculous, particularly given the track record of previous contractors disposal practices.

5. Proposed ocean disposal would destroy unique and irreplaceable habitat.
Past Corps disposal practices have inarguably caused permanent alteration to the estuary and has greatly contributed to its degraded state (e.g. Rice Island, Site B). The cumulative impacts of sediment disposal over the 50 year life of the project were not addressed comprehensively, nor peer-reviewed in the FEIS and must be assessed prior to designation. The Columbia River Plume supports irreplaceable and unique habitat the likes of which is found nowhere else along the Pacific Coast. The Corps considers the marine impacts of ocean disposal to be insignificant compared to regional economic benefits. The FEIS argues that the environmental impacts at the mouth of the Columbia River would not be significant because the species there occur coast wide. We disagree with this illogical and unreasonable justification for the damages.

6. No mitigation for marine impacts planned.
The Corps and EPA claim that mitigation has already been accomplished via the site selection process, through avoidance, thus no mitigation is planned for damages caused by disposal of sediments in the DWS. State law requires mitigation for unavoidable losses to habitat and natural resources. RCW 43.143.030(2)(f)

Since mitigation techniques to re-create unique ocean habitat like the one slated for destruction by this project are not developed, avoidance should be the prime goal. Yet the Corps has not seriously considered the use of Benson Beach for beneficial use of dredged sediment and subsequent reduction of ODMDS size, nor alternatives to deepening the entire channel in order to reduce the volume of sediment requiring disposal locations in the first place.

According to state law, WAC 197-11-768, mitigation means
1) Avoiding the impact altogether by not taking a certain action or parts of an action;
2) Minimizing impacts by limiting the degree or magnitude of the action and its implementation, by using appropriate technology, or by taking affirmative steps to avoid or reduce impacts;
3) Rectifying the impact by repairing, rehabilitating, or restoring the affected environment;
4) Reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action;
5) Compensating for the impact by replacing, enhancing, or providing substitute resources or environments; and/or
6) Monitoring the impact and taking appropriate corrective measures.

Importantly, guidelines for implementing the Ocean Resources Management Act (RCW 43.143.005 - 43.143.030) state that "the sequence of actions described in WAC 197-11-768 (7)(e) should be used as an order of preference in evaluating steps to avoid and minimize adverse impacts." WAC 173-16-064 Monitoring is listed last in WAC 197-11-768, yet that is all that the Corps plans to do. Furthermore, DOE's guidelines state that "Impacts on commercial resources, such as the crab fishery, on non-commercial resources, such as environmentally critical and sensitive habitats, and on coastal uses, such as loss of equipment or loss of a fishing season, should be considered in determining compensation to mitigate adverse environmental, social and economic impacts to coastal resources and uses." WAC 173-16-064(7)(f) Yet, the Corps' FEIS does not include compensation for impacts, plans to reduce the impact over time or repair or restore the affected environment, and the Corps refuses to compromise on the "buffer zone" which doubles the size of the site and was not agreed to nor even introduced to the ocean disposal working group.

7. Sediments in the Columbia and Willamette Rivers contain toxins, unfit at any level, for disposal at sea.
Appendix H of the FEIS still contains language stating that materials from upriver current, proposed, and future Corps projects, including the Willamette, could be disposed of in ODMDSs. Federal law does not allow materials containing known or suspected carcinogens to be placed in the ocean. 40 C.F.R. § 227.6 Sediments in the Columbia and Willamette Rivers have shown evidence of toxic contamination, including dioxin and DDT, and should not be disposed of in ocean sites.

8. Alternatives
The Corps has continually avoided serious consideration of placing dredged sediments at Benson Beach. Now, Pacific County has stepped forward as the project sponsor for this alternative. The use of Benson Beach, combined with strategic use of Site E and the North Jetty Site, provide means of reducing the size of the DWS, which the Corps has refused to consider. The benefits of the use of Benson Beach include combating erosion and avoiding burying biologically productive, fine grained sand habitat as well as Dungeness crabs. The Corps should be required to seriously calculate the potential for beneficial use of sediment at Benson Beach prior to the designation of the excessively sized DWS, and use the results of such study to appropriately size the DWS. The Corps' plans to establish an enormous ocean disposal site for unrestricted quantities of dredged sediment from this and future deepening projects should be halted by DOE until beneficial uses and alternatives are planned.

B. The Corps' plan will significantly impact natural resources in the estuary.

The strategy outlined in the All-H paper prioritizes the protection of productive habitat. "Federal agencies put high priority on protecting habitat that is currently productive, especially if at risk of being degraded. Restoring degraded habitat is of lower priority, Undertaking difficult and expensive efforts to restore degraded habitat while losing existing productive habitat would be a poor bargain." Yet this is exactly what is being planned for the Columbia River Estuary and the DWS. Dredging equipment will entrain migrating endangered species, in-water disposal of dredged material will wipe out benthic populations that support migrating fish, further loss of wetlands will continue the course of estuary habitat degradation, increasing the size of dredged material islands will further exacerbate current problems with Caspian Terns, constant year-round dredging will harass migrating salmon and other aquatic species, under-water blasting will kill and harass endangered species, and dredging and disposal activities will permanently alter flow patterns in the estuary.

The FEIS does not comply with County Master Shoreline Plans

CZMA requires that the Corps meet with Washington State's Coastal Zone Management Program to the maximum extent possible, as it applies to coastal resources. 15 C.F.R. § 930.30. State management programs as supplemental regulations to be adhered to in addition to existing agency mandates. 15 CFR § 930.32(a) The Project is not consistent with shoreline management mast plans and should be changed to become consistent.

A. Pacific County Shoreline Master Program

Pacific County outlines 42 shoreline policies in its Shoreline Master Program. The project is not in compliance with the County's economic development, aquatic environment, and saltwater habitat policies. The project will cause irreparable harm to the quality of the site's environment or adjacent shorelines, substantially degrade the existing character of the aquatic environment, and jeopardize critical rearing and nursery areas for valuable recreational and commercial species and ecologically significant marine plants, fish and animals.

The County's Permit Review Criteria reads: Pacific County may permit ocean and associated upland or coastal uses and activities if the criteria listed below are met or exceeded. a) There is a demonstrated significant local, state, or national need for the proposed use or activity; c) There will be no likely long-term significant adverse impacts to coastal or marine resources or uses, d) All reasonable steps are taken to avoid and minimize adverse environmental impacts, with special protection provided for the marine life and resources of the Columbia River … estuar[y]; e) All reasonable steps are taken to avoid and minimize adverse social and economic impacts, including impacts on aquaculture, recreation, tourism, navigation, air quality, and recreational, commercial, and tribal fishing; f) Compensation is provided to mitigate adverse impacts to coastal resources or uses; and g) Plans and sufficient performance bonding are provided to ensure that the site will be rehabilitated after the use or activity is completed. The project does not meet these criteria.

B. Wahkiakum Shoreline Management Master Program
The Project is not in compliance with many sections of Wahkiakum County's Shoreline Management Master Program regarding adverse effects of construction and maintenance dredging, fill, timing of dredging operations, and minimization of adverse short-term effects of dredging and disposal operations. The Consistency Determination does not address these policies.

C. Cowlitz County Shoreline Management Master Program
We are concerned with the fill of wetlands and the deforestation of previously used disposal sites on Cottonwood Island. Corps operations should come into compliance with Cowlitz County Shoreline Management Master Program goals.

Conclusion

The Corps did not support its findings of no significant impacts. This leaves DOE with the responsibility of protecting Washington's natural resources through independent analysis of the impacts. We request that DOE deny the Corps Consistency Determination at this time and request a Supplemental EIS. We have learned at the last minute that this public notice includes Clean Water Act Section 401 Water Quality Certification. We strenuously object to the lack of such notice in the documents DOE sent announcing the CZMA comment period and request that a public comment period for 401 certification be held separately.

Sincerely,

.

Nina Bell
Executive Director

.

Allison LaPlante
Northwest Environmental Defense Center
cc:

Tom Fitzsimmons, Director, WA Department of Ecology
Carol Jolly, Executive Policy Advisor to Governor Locke
Secretary of State Ralph Munro
U.S. Senator Slade Gorton
U.S. Senator Patti Murray
Mike Desimone, Pacific County
Charles J. Beyer, Wahkiakum County
Kathy Harnden, Cowlitz County
John Malek, Sediment Management, Environmental Protection Agency
Nora Berwick, National Marine Fisheries Service
Margaret Barrette, Washington Department of Natural Resources
Ted Benson, Washington Department of Natural Resources
Curt Leigh, Washington Department of Fish and Wildlife
Bob Burkle, Washington Department of Fish and Wildlife
Christine Valentine, OR Department of Land Conservation and Development
Charles Clark, Regional Administrator, Environmental Protection Agency
Austin Perez, Small Business Administration
Senator Syd Snyder
Senator Karen Fraser
Representative Mark Doumit
Representative Brian Hatfield
Representative Thomas Mielke
Representative John Pennington
Representative Debbie Regala

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