Working with the Washington Forest Law Center, NWEA submitted extensive comments on the federal government’s proposed disapproval of Oregon’s Coastal Nonpoint Pollution Control Program. The comments support the proposed disapproval, focusing primarily on Oregon’s failure to control pollution from logging activities, including logging roads, and agriculture. They point out that current efforts by the Oregon Departments of Forestry and Agriculture are not adequate to remedy the widespread pollution problems in Oregon’s coastal watersheds. NWEA’s letter to EPA and NOAA, which co-administer this program under the Coastal Zone Act Reauthorization Amendments (CZARA), also discusses the lack of protection from pesticides, Oregon’s failure to comprehensively identify impaired waters, and its failure to use the Total Maximum Daily Load (TMDL) clean-up program to reduce nonpoint pollution, despite nearly every coastal TMDL’s having found that nonpoint temperature pollution should be zero. Finally, NWEA’s comments note that Oregon has consistently ignored the recommendations of its own Independent Multidisciplinary Science Team, established by the legislature and Governor Kitzhaber in 1997.
