2024-201-Order No. 2024-021 Recorded 7/16/2024REVIEWED Recorded in Deschutes County CJ2024-201
Steve Dennison, County Clerk
.�C Commissioners' Journal 07/16/2024 4:19:39 PM
LEGAL COUNSEL
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2024-201
BEFORE THE BOARD OF COUNTY COMMISSIONERS OF DESCHUTES COUNTY, OREGON
An Order Adopting the Recommendations of the
Solid Waste Advisory Committee for the * ORDER NO. 2024-021
Development of a New Solid Waste Management
Facility in Deschutes County at the Hooker Creek
"Moon Pit" Site
WHEREAS, the Deschutes County Solid Waste Management Plan adopted by the Board of County
Commissioners (BOCC) in 2019 recommended the development of a new Landfill (Solid Waste
Management Facility) in Deschutes County, and
WHEREAS, the County issued a Request for Proposal in 2021 for consultant services to assist in
development of site selection and screening process and provide technical assistance in site review,
and BOCC approved appointment of Parametrix to provide those services, and
WHEREAS, the BOCC appointed a Solid Waste Advisory Committee (SWAG) of twelve members
representing the four local jurisdictions, franchise waste and recyclables collection service providers, a
Sunriver community representative, an environmental community representative, and at -large
community members to review and recommend a Site Selection Criteria (SSC) Technical
Memorandum outlining the process to assess potential locations. The BOCC approved the SSC on
June 22, 2022; and
WHEREAS, Parametrix, with assistance and direction of the SWAG, utilized the SSC to review over
200 areas of interest, which was narrowed to 33 sites for broad -site screening, further reduced to 12
sites for focused screening, and ultimately reviewing two sites for significant technical assessment; and
WHEREAS, the process received over 1000 written comments, hundreds of attendees at various
meetings, and dozens of public comments at SWAG meetings; and
WHEREAS, after careful review the SWAC was unanimous in their recommendations to the BOCC
for their consideration to move forward with the Moon Pit location for the permitting of a new Solid
Waste Management Facility in Deschutes County.
THE BOARD OF COUNTY COMMISSIONERS OF DESCHUTES COUNTY, OREGON,
HEREBY ORDERS as follows:
Section 1. The Solid Waste Department, in coordination with other County Departments, to
negotiate the purchase rights to the Hooker Creek Moon Pit Aggregate Mine property for the purposes
of securing the necessary environmental permits and land entitlements in pursuit of the development of
a new Solid Waste Management Facility (Municipal Solid Waste Landfill) to serve Deschutes County
for the foreseeable future.
PAGE 1 OF 2- ORDER No. 2024-021
Section 2. The County shall work with stakeholders to develop and implement a robust and
comprehensive mitigation strategy that reflects community values to minimize impacts to area wildlife
and recreation.
Section 3. The Solid Waste Department to prioritize waste prevention and recovery and move
as quickly as possible to implement those strategies to reduce the overall costs and greenhouse gas
emissions of the new landfill.
Dated this of �' , 2024
ATTEST:
IkLlv�
Recording Secretary
PAGE 2 OF 2- ORDER No. 2024-021
BOARD OF COUNTY COMMISSIONERS
OF SCHUTES COUNTY, OREGON
07
PAT I ADAIR, Chair
P
ANTHONY DeBONE, Vice Chair
PHIL CIA G, Cominissioner
Deschutes County Solid Waste
Management Facility (SWMF)
Final Site Evaluation
Prepared for
Deschutes County Solid Waste Department
May 2024
Parametrik
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for double -sided printing
Deschutes County Solid Waste
Management Facility (SWMF)
Final Site Evaluation
Prepared for
Deschutes County Solid Waste Department
61050 SE 27th Street
Bend, OR 97702
Prepared by
Parametrix
150 NW Pacific Park Lane, Suite 110
Bend, OR 97701
T.541.508.7710 F. 1.855.542.6353
www.parametrix.com
May 2024 1 553-2509-011
Parametrix. 2024. Deschutes County Solid Waste
Management Facility (SWMF) Final Site Evaluation.
Prepared for Deschutes County Solid Waste Department
by Parametrix, Bend, Oregon. May 2024.
Deschutes County Solid Waste Management Facility (SWMF)
Final Site Evaluation
Deschutes County Solid Waste Department
1. Executive Summary ...................................................................................................................... 1-1
2. Introduction..................................................................................................................................
2-1
2.1
Background ................................................. .............................................................................
2-1
2.2
Purpose of Study......................................................................................................................
2-1
2.3
County, State, and Federal Landfill Siting Restrictions.........................................................
2-2
2.3.1 Federal.......................................................................................................................2-2
2.3.2 State...........................................................................................................................2-3
2.3.3 County........................................................................................................................2-3
2.4
Moon Pit Site Information.......................................................................................................
2-3
2.5
Roth East Site Information......................................................................................................
2-4
3. Conceptual Facility Layouts.........................................................................................................
3-1
3.1
Landfill Footprint......................................................................................................................3-1
3.2
Perimeter Access Road and Ditch..........................................................................................
3-1
3.3
Excavation Plan........................................................................................................................3-2
3.4
Liner System............................................................................................................................
3-2
3.5
Primary Leachate Collection and Removal System...............................................................
3-2
3.6
Secondary Leachate Collection and Removal System..........................................................
3-3
3.7
Cell Construction and Fill Sequence.......................................................................................
3-4
3.8
Final Configuration..................................................................................................................
3-4
3.9
Closure and End Use...............................................................................................................
3-4
4. Existing Conditions, Impacts, and Mitigation...............................................................................
4-1
4.1 Site Development and Permitting...........................................................................................
4-1
4.1.1 Location and Topography.........................................................................................
4-1
4.1.2 Zoning and Existing Land Use.................................................................................
4-1
4.1.3 Potential Permits.......................................................................................................
4-3
4.2 Transportation System............................................................................................................
4-4
4.2.1 Daily Landfill Activities at Both Sites........................................................................
4-4
4.2.2 Moon Pit Site.............................................................................................................
4-4
4.2.3 Roth East Site............................................................................................................
4-4
4.2.4 Overall Conclusions..................................................................................................
4-5
4.3 Water Infrastructure Assessment...........................................................................................
4-5
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4.3.1
Moon Pit..................................................................................................................... 4-6
4.3.2
Roth East...................................................................................................................
4-6
4.4
Electrical
Power Supply...........................................................................................................4-7
4.4.1
Moon Pit Electrical Infrastructure Needs................................................................
4-7
4.4.2
Roth East Electrical Infrastructure Needs...............................................................
4-7
4.5
Flood Risks...............................................................................................................................4-7
4.5.1
Moon Pit Site.............................................................................................................4-7
4.5.2
Roth East Site............................................................................................................
4-8
4.6
Geology/Hydrogeology.............................................................................................................4-8
4.6.1
Geology............................................................ ..........................................................
4-8
4.6.2
Hydrogeology.............................................................................................................4-9
4.7
Preliminary Geotechnical Feasibility.....................................................................................4-10
4.7.1
Moon Pit...................................................................................................................4-10
4.7.2
Roth East.................................................................................................................
4-12
4.8
Environmental
Site Assessment Phase I..............................................................................4-14
4.8.1
Moon Pit...................................................................................................................4-14
4.8.2
Roth East................................................................................................................. 4-15
4.9
Air Quality,
Weather, and Greenhouse Gas Emissions ............................................. ...........
4-16
4.9.1
Moon Pit...................................................................................................................4-17
4.9.2
Roth East.................................................................................................................
4-18
4.10
Natural
Resources.................................................................................................................4-20
4.10.1
Moon Pit Site Characteristics.................................................................................4-20
4.10.2
Moon Pit Site Protected Species, Habitat, and Permitting...................................4-20
4.10.3
Moon Pit Site Development Compensatory Mitigation.........................................4-22
4.10.4
Moon Pit Site Summary..........................................................................................4-23
4.10.5
Roth East Site Characteristics................................................................................4-23
4.10.6
Roth East Site Protected Species, Habitat, and Permitting.................................4-23
4.10.7
Roth East Site Development Compensatory Mitigation.......................................4-25
4.10.8
Roth East Site Summary.........................................................................................4-26
4.11
Archaeology and Cultural Heritage ..................... ..................................................................
4-26
4.11.1
Archaeological and Historical Resources..............................................................4-26
4.11.2
Cultural Resources Literature Search and Records Review ....... .........................
4-26
4.11.3
Cultural Resources Reconnaissance Survey.........................................................4-27
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Contents (continued)
4.11.4 Cultural Resources Impacts...................................................................................4-28
4.11.5 Cultural Resources Mitigation................................................................................4-28
4.12 Community Assessment........................................................................................................4-29
4.12.1 Site -Specific Community Assessment Summary..................................................4-29
4.12.2 Community Characteristics....................................................................................4-29
4.12.3 Continued Outreach................................................................................................4-30
4.12.4 Siting Evaluation Outreach Summary ....................................................................4-30
5. Cost Analysis................................................................................................................................ 5-1
5.1
Capacity and Projected Life....................................................................................................
5-1
5.2
Population to be Served..........................................................................................................
5-1
5.3
Accepted and Prohibited Wastes............................................................................................
5-1
5.4
Rate of Waste Disposal...........................................................................................................
5-1
5.5
Mineral Resources...................................................................................................................5-2
5.6
Initial Development Costs.......................................................................................................5-2
5.6.1 Moon Pit Site.............................................................................................................
5-2
5.6.2 Roth East Site............................................................................................................
5-2
5.7
Refuse Cell Construction.........................................................................................................
5-3
5.8
Description of Operation.........................................................................................................
5-4
5.9
Daily and Intermediate Cover.................................................................................................
5-5
5.10
Landfill Closure .......... ..............................................................................................................
5-5
5.11
DEQ Permitting.........................................................................................................................
5-5
5.12
Summary of Cost Analysis.......................................................................................................
5-6
6. Conclusion....................................................................................................................................6-1
FIGURES
Figure 1. Final SWMF Sites in Deschutes County.................................................................................. 2-2
Figure2. Moon Pit Site Map.................................................................................................................... 2-4
Figure 3. Moon Pit Site Photograph........................................................................................................ 2-4
Figure4. Roth East Site Map.................................................................................................................. 2-5
Figure 5. Roth East Site Photo................................................................................................................ 2-5
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Contentsd
TABLES
Table 1. Soil Usage Summary for Moon Pit...........................................................................................4-11
Table 2. Soil Usage Summary for Roth East.........................................................................................4-14
Table 3. Public Comments Received by County (December 2022-October 2023)............................4-30
Table 4. Estimate of per acre Cost for Landfill Cell Development at Moon Pit.....................................5-3
Table 5. Estimate of per acre Cost for Landfill Cell Development at Roth East...................................5-4
Table 6. Comparison of Estimated Annual Operating Costs..................................................................5-5
Table 7. Landfill Site Cost Comparison....................................................................................................5-7
APPENDICES
A Site Comparison Summary Table
B Site Screening Report
C Site Owner Solicitation Responses
D Preliminary Design Drawings
E Development and Permitting Evaluation
F Transportation Assessment
G Water Assessment
H Electrical Power Supply Review
I Flood Risk Analysis
J Geology/Hydrogeology Assessment
K Preliminary Geotechnical Feasibility Report
L Phase I Environmental Site Assessment (Moon Pit link) (Roth East link)
M Air Quality, Weather, and Greenhouse Gas Analysis
N Natural Resource Assessment
O Archaeological Reconnaissance Survey
P Community Assessment
Q SMWF Cost Estimates
R Comments from Agencies and Organizations
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#H:#V
horizontal to vertical
pg/m3
micrograms per cubic meter
AAGR
average annual growth rate
AST
aboveground storage tank
ASTM
ASTM International
bgs
below ground surface
BLM
Bureau of Land Management
CEC
Central Electric Cooperative
DCC
Deschutes County Code
DEQ
Oregon Department of Environmental Quality
DOGAMI
Oregon Department of Geology And Mineral Industries
ECSi
Environmental Cleanup Site Information
EFU
Exclusive Farm Use zone
EFUHR
Exclusive Farm Use - Horse Ridge zone
EPA
U.S. Environmental Protection Agency
ESA
environmental site assessment
F
Fahrenheit
FEMA
Federal Emergency Management Agency
GCL
geosynthetic clay liner
gpd
gallons per day
gpm
gallons per minute
HDPE
high -density polyethylene
LCRS
leachate collection and removal system
LF
linear foot
LM
Landscape Management Combining zone
MCL
maximum contaminant levels
MSW
municipal solid waste
NWI
National Wetland Inventory
OAR
Oregon Administrative Rules
ODFW
Oregon Department of Fish And Wildlife
PM
particulate matter
RCRA
Resource Conservation and Recovery Act
REC
recognized environmental condition
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Deschutes County Solid Waste hll,,naaameni E'ac il;ty (SWMF)
Final Site Evaluation
Deschutes County Solid Waste Department
a" ,�; • • •
SF
square feet
SHPO
State Historic Preservation Office
SM
Surface Mining zone
SMIA
Surface Mining Impact Area zone
SPT
standard penetration tests
SWAC
Solid Waste Advisory Committee
SWMF
solid waste management facility
USFWS United States Fish and Wildlife Service
WA Wildlife Area Combining zone
WillametteCRA Willamette Cultural Resources Associates, Ltd
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Final Site Evaluation
Deschutes County Solid Waste Department
®ExecutiVe
Deschutes County is faced with the imminent challenge of Knott Landfill reaching capacity by 2029,
necessitating the selection of a new solid waste management facility (SWMF) that will include a
landfill to serve the County for at least 100 years. As recommended in the 2019 Deschutes County
Solid Waste Management Plan and directed by the Board of County Commissioners, the Solid Waste
Department has been working with the County's Solid Waste Advisory Committee (SWAC) through a
public process to identify potential locations for a new SWMF in Deschutes County. Following a
rigorous site selection process, the Moon Pit and Roth East sites, both situated east of Bend near US
20, emerged as the final candidate sites. The County and its consultant team, led by Parametrix,
commenced an exhaustive multidisciplinary investigation to evaluate the efficacy of each site for
development. This report offers a comprehensive analysis of the findings for each site, aiming to
guide the County in the selection of a preferred location for the new SWMF.
The Moon Pit site property shape results in a complex layout that is less efficient than that at the
Roth East site. Despite a lower capacity -to -acreage ratio, Moon Pit benefits from existing
infrastructure including an access road, gate, scales, and well, potentially reducing some upfront
development costs. However, its active surface mine status and zoning complexities require careful
consideration. The site has an established paved access road with direct access to US 20, but it
crosses through Bureau of Land Management lands which could lead to a lengthy federal
environmental review process for a change in use. Moon Pit also offers existing water supplies,
though securing future water right permits may pose challenges.
Conversely, the Roth East site features a more efficient layout, resulting in a better capacity -to -
acreage ratio. As an undeveloped grazing property, it lacks existing infrastructure, demanding
upfront capital for access road construction. Zoned as Exclusive Farm Use, Roth East faces a
conditional use permit process including a Farm Impact Test which is subject to appeals filed with
the land use board of appeals (LUBA). New water infrastructure and water rights permits would be
needed at the Roth East site to meet anticipated water demands.
Significant geological differences also exist between the two sites. Moon Pit is in a ridge -bounded
valley with shallow bedrock that would require blasting for excavation. As a result, cell development
costs are expected to be substantially higher at Moon Pit. However, the potential aggregate resource
value, established mining operation, Surface Mine zoning, and Oregon Department of Geology and
Mineral Industries permit for the site present the opportunity for aggregate resource extraction to
subsidize landfill excavation costs. Roth East, on the other hand, lies in the Millican Valley with
unconsolidated alluvial deposits that could be excavated with conventional equipment and used
on -site for development and landfill cover needs.
As part of the public process for the siting evaluation, the County received and responded to
comments from community members, public agencies, and other interested parties. Many of the
public comments about the finalist sites note potential impacts to area wildlife and recreation use
that may be caused by landfill development or operations. Comments about the Moon Pit site note
the nearby Badlands Wilderness Area, while comments about the Roth East site raise its proximity to
Millican Valley residents and the Pine Mountain Observatory.
Moon Pit's development is perceived to have fewer visual and residential impacts, given its remote
location and topographic screening by ridges on three sides. It also faces fewer archaeological risks
due to its prior disturbance for gravel mining. In terms of wildlife impact, the Moon Pit site poses
May 2024 1553-2509-011 1-1
Deschutes County Solid Waste Management Facility (SWMF)
Final Site Evaluation
Deschutes County Solid Waste Department
potential impacts to a golden eagle nest and essential habitat for mule deer, elk, pronghorn, and
sage -grouse. Mitigation costs for these potential wildlife impacts are estimated at $700,000, with
additional operations and maintenance costs of up to $800,000 for mitigation sites.
Roth East is expected to endure longer permitting, review, and appeal timelines because it is largely
undeveloped, may possess archaeological resources, and is challenged by public concerns about
potential disturbances to nearby residences and recreational activities. In terms of wildlife impact,
Roth East faces greater potential impacts to mule deer, elk, pronghorn, and sage -grouse habitat
(sage -grouse has a potential for future listing as an endangered species if population declines
continue). The estimated wildlife mitigation costs of $1.5-8.1 million and additional operations and
maintenance costs of up to $2.5 million for mitigation sites.
The Parametrix team prepared planning level opinions of probable cost (costs) for both sites. These
opinions have ranges of -30% to +50%, which is an appropriate level of accuracy for comparison of
sites. Moon Pit initial development costs range between $50 to $64 million, which includes $15.4 to
$15.9 million for land acquisition. Roth East development costs are approximately $36 to $44
million, with $5.5 to $7 million allocated for land acquisition. Moon Pit's landfill cell development
costs range from $705,000 to $1,075,000 per acre, while Roth East's cell development cost is
approximately $394,000 per acre. Moon pit annual operating costs are $7.6 million, with Roth East
higher at $8.4 million. Moon Pit's average cost per ton for disposal (capital plus operations) ranges
between $43 to $48, while Roth East's average cost is just under $45 per ton. The cost ranges
presented here for Moon Pit depend on the extent and cost of cell excavation that could occur as a
part of aggregate mining operations on -site. Initial capital costs are significantly higher at Moon Pit,
which will necessitate higher tip fees for the first 20 years. However, total cumulative costs are
estimated to be similar over the projected lifespans.
The decision between Moon Pit and Roth East hinges on a nuanced evaluation of advantages,
challenges, and costs. Moon Pit provides existing infrastructure and potential cost offsets but faces
zoning and access road complexities as well as substantially higher upfront development costs. Roth
East boasts efficiency and favorable soil conditions, but is challenged by greater infrastructure
needs, water availability risks, wildlife impacts, landowner concerns, recreational concerns, and
longer haul routes (resulting in higher haul costs and related greenhouse gas emissions). Because
the Moon Pit site is already disturbed and will continue to support surface mining (regardless of
landfill siting), development of a new landfill at the Roth East would be expected to cause a greater
incremental disruption to the surrounding area than at the Moon Pit site. Deschutes County's
ultimate selection should prioritize long-term sustainability, environmental protection, and economic
viability, ensuring the chosen site best aligns with the County's waste management goals and
community values.
See Appendix A for the site comparison summary table.
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2.1 Background
The 2019 Deschutes County Solid Waste Management Plan (SWMP) outlined a roadmap for
managing solid waste in the county over the next 20 years. The plan was developed with the input of
various stakeholders, including residents, institutions, businesses, cities, and service providers. The
SWMP evaluated alternatives for managing the county's waste, including new technologies and the
option to transport waste outside the county to other solid waste management facilities.
The SWMP revealed that 84% of survey respondents supported the position that waste generated in
Deschutes County should be disposed of within the county, with 93% supporting the
recommendation to site a new landfill in the county. Two primary options were considered:
1. Transport waste to regional landfills located between 135 and 185 miles from Deschutes County
near the Columbia Gorge.
2. Site and build a new landfill in Deschutes County.
After evaluating these options, the Solid Waste Advisory Committee (SWAC) reached a consensus
that the best approach for providing a long-term and cost-effective waste management system was
to site and construct a new in -county landfill. This decision was based on several key factors,
including the ability to control decisions for managing the county's waste stream, environmental and
other impacts resulting from transporting waste, favorable conditions in Deschutes County for siting
a new landfill, and the cost-effectiveness of building and operating an in -county landfill.
The SWMP also acknowledged the challenges of siting a new landfill and the potential for a
protracted process to successfully obtain permits. However, it was noted that the geographic and
demographic conditions in the county are favorable compared to locations west of the Cascade
Mountains where siting has not been successful.
The goal is to have a solid waste management facility sited, developed, and operational prior to the
closure of Knott Landfill, the County's current solid waste management facility, which is expected to
reach capacity by 2029. The new landfill would meet all regulatory requirements and any new state
and local requirements that supersede previous regulations for environmental protection. The new
landfill will have the capacity to satisfy the County's waste projections for at least 100 years.
In 2023, the Site Screening Evaluation was completed as part of the process to site a new landfill
within Deschutes County, including siting criteria development, site identification, broad site
screening, and focused site screening. This site screening study identified and evaluated potential
landfill sites based on regulatory requirements, environmental considerations, and engineering
considerations. In regular coordination with the SWAC as a part of a public process with
opportunities for public comment, this process initially identified over a hundred potential sites and
narrowed this list down to two final candidate sites through identification of fatal flaws, broad site
screening, and focused site screening. A copy of the site screening report is included in Appendix B.
2.2 Purpose of Study
Two finalist sites for the new County solid waste management facility (SWMF), referred to as Moon
Pit and Roth East, have progressed to the final evaluation stage. See Figure 1 for a map showing site
May 2024 1 553-2509-011 2-1
Deschutes County Solid Waste ManageiTent Facility (SWM -F)
Final Site Evaluation
Deschutes County Solid Waste Department
locations. The County is now in the last phase of selecting the landfill site. During this final phase,
the County will determine which of the two sites is more suitable for developing a sanitary landfill
that complies with all relevant local, state, and federal regulations. A key aspect of this selection
process is to assess the potential for addressing existing conditions that could hinder development.
Other critical factors for evaluation include the projected costs of development and the site -specific
risks that could delay development and initial operations beyond 2029, when Knott Landfill is
projected to reach capacity.
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�� (.. iiEGVs rnuisrfn sir r,�u t
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'\ i Prapt.ty Boundary (Final Setts)
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P"
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Figure 1. Final SWMF Sites in Deschutes County
2.3 County, State, and Federal Landfill Siting Restrictions
In 1989, the Environmental Protection Agency initiated authority under the existing Resource
Conservation and Recovery Act (RCRA) to regulate the siting of new municipal solid waste (MSW)
landfill units. Subpart B of the RCRA Subtitle D (40 CFR 258.60) regulations restrict the siting of new
landfills based on the six federal criteria listed below, followed by state and local criteria also
applicable to landfills.
® ,Airport Safety: Airport safety is not a concern at either of the two sites.
® Floodplains: No floodplains are present on either site.
■ Wetlands: No wetlands are present on either site.
® Fault Areas: Previous studies and the current investigations revealed no faults active in the
past 10,000 years (Holocene period) at either site.
® Seismic Impact Zones: No seismic impact areas are located on either site.
® Unstable Areas: No unstable areas are located on either site.
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Deschutes County Solid Was e. Managentent Facility- (SWMF)
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De -,chutes County Solid Waste Department
® Floodplains: See federal, above.
■ Critical habitat for threatened or endangered species: No sensitive species or habitat are
located on either site.
® Sensitive hydrogeological environments: None are located on either site.
2.3.3 County
■ The proposed site shall not create a fire hazard, litter, insect or rodent nuisance, or air or
water pollution in the area: These hazards will be controlled by final site design and
operations (not part of this report).
® The proposed site shall be located at least 0.25 miles from any existing dwelling, home, or
public road (except the access road): Both sites meet this criterion.
® The proposed site shall be provided with a maintained all-weather access road: The need to
construct an all-weather road is assumed for both sites as part of the cost evaluation.
® The Moon Pit site will require a change to the Deschutes County Comprehensive Plan to
allow a landfill as a reclamation use in the Surface Mine (SM) zone.
2.4 Moon Pit Site Information
Location: Deschutes County, Township 19S, Range 14E, Sections 1-2, 12
Situs Address: 26300 Hwy 20, Bend, OR 97702
Tax Lot Number: 1914000000200
Owner: Moon Pit, LLC (owned by Hooker Creek Companies, LLC)
Area: 440 acres
Existing Use: Aggregate Surface Mine
Terrain: Flat to rolling in the northwest, rising toward the southeast, bounded by ridges
Proximity: Approximately 16 miles southeast of Bend
Nearby Features: Adjacent to the Oregon Badlands Wilderness and its trails, including the
Badlands Rock Trailhead (approximately 700 feet from the site boundary)
See Appendix C for Site Owner Solicitation Responses with terms and prices for acquisition.
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Figure 2. Moon Pit Site Map
Figure 3. Moon Pit Site Photograph
2.5 Roth East Site Information
Location: Deschutes County, Township 2OS, Range 15E, Sections 1, 11, 12, 13, 14
Situs Address: 56200 Pine Mountain Rd, Bend, OR 97701
Tax Lot Number: 2015000000301
Owner: Roth, Stephen F & Clancy R
Area: Approximately 1,706 acres
Terrain: Flat to rolling, gradually rising toward the southern portions
Proximity: Approximately 24 miles southeast of Bend
Nearby Features: Adjacent to a rural residential property in the northeast, OHV trails of the Millican
Valley OHV Trail System to the north and west, Bureau of Land Management
(BLM)-managed land to the south, and Pine Mountain (a paragliding launch area
and observatory site) within the Deschutes National Forest to the south
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See Appendix C for Site Owner Solicitation Responses with terms and prices for acquisition.
Figure 4. Roth East Site Map
Figure 5. Roth East Site Photo
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Final Site Evaluation
Deschutes County Solid Waste Department
Facility
Layouts,
This section describes the design criteria used in the development plans for each site and shows
how these criteria were used to determine the shape of each landfill in its final configuration.
The layouts for Moon Pit and Roth East that were developed for this evaluation are conceptual.
These conceptual layouts represent a level of accuracy that will remain undefined until the actual
landfill is designed. These conceptual layouts are based on regulatory agency requirements, state-of-
the-art standard landfill design practices, typical operating procedures for a municipal solid waste
landfill and site -specific geologic information generated for this evaluation. Conceptual landfill
layouts can be more accurately designed as more information becomes known or made available.
The information gathered for this study is preliminary and does not represent the level of information
necessary to design a landfill beyond a conceptual level.
3.1. Landfill Footprint
Each conceptual landfill footprint was dictated by the following site constraints and design criteria:
® Develop a landfill with at least 100 years of solid waste disposal capacity.
• Provide a 150-foot buffer between the property line and refuse disposal area at Moon Pit.
■ Provide a 550-foot buffer between the property line and refuse disposal area at Roth East.
® Provide an area for leachate (liquid resulting from water flowing through solid waste) and
surface water management at the downstream side of each landfill.
® Continue to maintain the on -site wells at Moon Pit.
Based on these constraints, the footprint for each of the sites was established as shown on
Drawings C1 and D1 (Appendix D).
3.2 Perimeter Access Road and Ditch
Drawings C2 and D2 (Appendix D) show the perimeter access roads that would be constructed as
landfilling progresses. This road would provide access for vehicles hauling refuse to the landfill and
for future maintenance activities.
Located adjacent to the access road would be a perimeter ditch. On Moon Pit, this ditch would
channel surface water flow around the landfill to a discharge point on the west perimeter adjacent to
the landfill entrance. On Roth East, the ditch system would channel surface water flow around the
landfill to a discharge point on the north perimeter.
Design criteria that have been established for the perimeter road and ditch system are as follows:
® Minimum slope of 1.0% to enable the perimeter road ditch to drain.
® Minimum 50-foot bench width for liner, final cover system anchor trenches, and access road.
■ Minimum roadway width of 24 ft.
® Minimum exterior side slope of 2 horizontal to 1 vertical.
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■ Minimum interior side slope of 3 horizontal to 1 vertical.
■ Surface water run-on and run-off control system sized to handle the 24-hour, 25-year design
storm.
3.3 Excavation Plan
The bottom elevation for the landfill at each site was established by the need to provide proper
drainage slopes to the leachate collection system. Drawings C2 and D2 (Appendix D) show the
subgrade plan for each of the two sites.
At Moon Pit, leachate drains by gravity to 8 leachate collection sumps located along the west
perimeter. At Roth East, leachate drains by gravity to 4 leachate collection sumps located along the
north perimeter.
Design criteria used to develop the subgrade plans are as follows:
■ Minimum bottom slope toward the leachate transmission line of 4% to promote drainage.
■ Minimum leachate transmission line slope of 2%.
a Maximum excavated side slope of 3 horizontal to 1 vertical.
■ Ability to access and clean leachate transmission lines.
3.4 Liner System
The design for the primary landfill liner system proposed for both sites is shown in Detail 1 of
Drawings A6 and B6 (Appendix D). Components from top to bottom for the landfill floor area include:
® A separating geotextile used to prevent clogging of the drainage layer and provide additional
protection to the liner system.
® A 12-inch drainage layer used to transmit leachate to the leachate collection system that
maintains less than 1 foot (30 cm) of hydraulic head on the liner.
■ A geonet composite used to transmit leachate to the leachate collection system and protect
the underlying geosynthetics.
■ A 60-mil high -density polyethylene (HDPE) geomembrane which is used to contain leachate.
■ A geosynthetic clay liner (GCL) used as the lower component within the liner system.
® A cushioning layer (1/4-inch minus material) used to provide a stable foundation for the liner
system and protect the overlying GCL from the excavated subgrade.
■ A prepared subgrade that is used to provide a uniform surface for liner system construction.
This liner profile meets the requirements for an alternative liner system under RCRA Subtitle D and
applicable Oregon rules. The GCL is being used in place of compacted soil due to the lack of
availability of fine-grained, cohesive, low -permeability soils at or within the vicinity of either site.
3.5 Primary Leachate Collection and Removal System
The leachate collection and removal system (LCRS) includes the drainage layer within the liner
system, perforated leachate collection pipes and collection trenches. Each landfill has been
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designed with a series of leachate collection trenches, with the collection pipes located within these
trenches as shown in Detail 3 of Drawings A6 and B6 (Appendix D). The LCRS has been designed to
operate by gravity and maintain less than 1-foot (30 cm) depth of leachate over the liner as required
by RCRA Subtitle D. The leachate collection lines extend up both the east and west sidewalls at
Moon Pit and the north and south sidewalls at Roth East as solid pipe to allow for clean -out access
from both ends.
The entire base of Moon Pit slopes toward the west so that both the drainage layer and the leachate
collection lines drain to collection sumps located along the base of the sideslope on the west side of
the landfill (Drawing C2). The entire base of Roth East slopes toward the north so that both the
drainage layer and the leachate collection lines drain to collection sumps located along the base of
the sideslope on the north side of the landfill (Drawing D2). These collection sumps are depressed,
lined areas within the landfill where leachate will be temporarily stored. An 18-inch HDPE riser will
allow a pump to be used for the removal of leachate from the sump. The sideslope riser would be
accessible from the perimeter of the landfill during all phases of the landfill development. Liquid
level sensors would be used within the sumps to detect the depth of leachate on the liner system.
The following design criteria were used in the analysis:
® Granular drainage layer in -place hydraulic conductivity greater than or equal to 1 cm/sec.
® Less than 3% of the granular drainage layer fines passing No. 40 sieve.
■ Collection pipe slope greater than or equal to 2%.
® Drainage layer slope toward the leachate collection trench greater than or equal to 4%.
® Cleanouts would be provided at both ends of all collection pipes with sweep bends used to
allow cleanout equipment access.
Average annual precipitation at both sites is less than 10 inches per year. For the analysis, it is
assumed that a 1-acre double composite -lined leachate pond would be required at each of the sites
for evaporation and/or containment for leachate recirculation.
3.6 Secondary Leachate Collection and Removal System
A secondary LCRS beneath the leachate collection trenches and sumps, as shown in Detail 3 on
Drawings A6 and B6 (Appendix D), is provided in the cost analysis for each of the sites.
Components of the secondary leachate collection and removal system from top to bottom include:
■ A 16-ounce cushioning geotextile.
■ A geonet composite to transmit leachate.
■ A 60-mil HDPE geomembrane.
® A GCL as the lower component within the secondary liner system.
■ A cushioning layer (1/4-inch minus material) used to provide a stable foundation for the liner
system and protect the overlying GCL from the excavated subgrade.
■ A prepared subgrade used to provide a uniform surface liner system construction.
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3.7 Cell Construction and Fill Sequence
The landfill planned for each of the sites would be developed in a series of stages. Each stage, or
refuse cell, would be developed as additional refuse disposal capacity is required. The landfill at
Moon Pit has been divided into 33 refuse cells, and at Roth East into 37 refuse cells. The order of
cell development is shown on Drawings C200 and C200, respectively (Appendix D). Each of these
cells, when combined with previous cells, would generally provide 3 years of landfill capacity.
The following criteria served as the basis for layout of the individual cells and construction
sequencing:
■ To control capital expenditures and minimize leachate production, each cell would provide a
minimum of 3 years of disposal capacity.
■ Each cell would have a minimum dimension of 300 feet in any direction to allow for truck
turnaround.
■ To minimize construction cost, excavation for future refuse cells would be performed as part
of daily and intermediate cover borrow operations, liner system construction, final cover
system construction, or access road construction.
■ To conserve space and minimize costs, on -site stockpiling would be kept to a minimum.
■ To minimize leachate production, each cell would be filled to final closure elevation and
closed with a final cover cap as quickly as possible.
3.8 Final Configuration
The final grading plan for each landfill site when fully developed is shown in drawings C4 and D4
(Appendix D). Filling to these elevations would provide a total of 64 million cubic yards of air space
(capacity) at Moon Pit and 80 million cubic yards of net air space at Roth East. The grading that is
shown is based on the following design criteria:
■ Minimum top of landfill slope of 3%.
■ Maximum final outer side slope of 4H:1V.
■ Match access road grade around the landfill perimeter.
At Moon Pit, the depth of refuse at completion would vary from zero at the landfill perimeter to
240 feet at the landfill center. At Roth East, the depth of refuse at completion would vary from 0 at
the landfill perimeter to 180 feet at the landfill center. Drawings C5 and D5 show the MSW fill
depths when each landfill is completed.
3.9 Closure and End Use
The objective in closing either landfill would be to minimize potential threats to human health and
the environment. RCRA Subtitle D requires at least 30 years of post -closure monitoring and
maintenance activities. In addition, it specifies that a final cover system be installed that:
■ Minimizes infiltration and erosion.
■ Minimizes the escape of waste or waste constituents to the groundwater, surface water or
the atmosphere.
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® Minimizes the maintenance activities that would be required.
The final end use for either site after closure is limited due to (1) potential settlement within the
landfilled area; (2) the generation of landfill gas as refuse decomposes; and (3) the presence of
landfill gas, leachate and surface water control facilities. Consequently, final land uses are typically
passive recreation or open space, including vegetative restoration for wildlife.
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,17
L. Existing Conditions, Impacts, and Mitigation
4.1 Site Development and Permitting
See Appendix E for full reports and more information on site development and permitting.
fir. Locationand 3 1: `f f, .!i . Z
,AA Moon
The Moon Pit site is a 440-acre property located in Deschutes County at Township 19S, Range 14E,
Sections 1-2, 12, with tax lot number 1914000000200. The site is located about 16 miles
southeast of Bend. The site consists of flat to rolling terrain in the northern portion of the site and
gradually rises to the central and southeastern portions.
The northern portion of the site is adjacent to the Oregon Badlands Wilderness (managed by the
BLM) and its hiking and horseback riding trails, including the Badlands Rock Trailhead, which is
located approximately 700 feet from the site boundary.
4.1.1.2 Roth East Site
The Roth East site is located in Deschutes County about 24 miles southeast of Bend at Township
20S, Range 15E, Sections 1, 11, 12, 13, 14. The tax lot number is 2015000000301, and the site is
approximately 1,700 acres. The site consists of flat to rolling terrain that gradually rises to the south.
The northeastern portion of the site is adjacent to a rural residential property that includes a
residence and farm outbuildings. Off -highway vehicle (OHV) trails associated with the Millican Valley
OHV Trail System are north and west of the site. BLM-managed land is located adjacent to the
southern portion of the property. Pine Mountain, a well-known paragliding launch area and the site of
the University of Oregon's Pine Mountain Observatory is located within the Deschutes National Forest
to the south of the site.
The Moon Pit site is zoned Surface Mining (SM) with a Wildlife Area Combining Zone (WA) overlay.
Adjacent zoning includes Exclusive Farm Use - Horse Ridge (EFUHR), Flood Plain (FP) zone, Surface
Mining Impact Area (SMIA) overlay, and Sage Grouse Habitat Area (General and Low -Density). Nearby
zoning includes Open Space and Conservation (OS&C), Landscape Management Combining Zone
(LM) overlay, and WA overlay. There is an area of floodplain located north and northwest of the site.
The existing use consists of an active surface mine. Land disposal sites are listed as a conditional
use in the SM zone (Deschutes County Code [DCC] 18.52.050), with the requirement that a "valid
DEQ permit on the effective date of Ordinance No. 92-066 for a Land Disposal Site," exists for the
use. This means that only Oregon Department of Environmental Quality (DEQ)-permitted landfills in
place prior to the 1992 ordinance are allowed as conditional uses in the SM zone. As there is
currently no landfill in operation at the site, land disposal is not a permitted use in the current zone.
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Three potential land use approval pathways were identified that could provide the necessary zoning
changes that would allow landfill operations on the Moon Pit site. See Appendix E for additional
information.
3. Requesting a zone map amendment to change the base zoning from SM to Multiple Use
Agriculture 10-Acre Minimum (MUA1O). This option requires showing the protected mineral
resource has been exhausted.
4. Proposing a text amendment to the Comprehensive Plan to allow landfill use as an approved
reclamation action to use on a site after mining is complete. This option requires coordination
with the Oregon Department of Geology And Mineral Industries (DOGAMI) and the Department of
Land Conservation and Development. A text amendment would maintain the SM zone and SMIA
combining zone, but it would require two separate hearings (hearings officer followed by Board of
Commissioners).
5. Proposing a new landfill overlay zone for the site that would allow land disposal sites on lands
designated with the overlay zone. This option requires a map and text amendment to County
code and adoption of the landfill overlay to the site. During discussions with the County Planning
Department, the County noted that the overlay should have occurred before the landfill siting
process and overlays are used to limit uses or provide more restrictive development standards,
not to add allowed uses and less restrictive standards.
-
The Roth East property is zoned EFUHR with the overlays of Forest Use 1(F1), LM, Sage Grouse
Habitat Area - Low Density, SMIA, and WA. The SMIA overlay only covers a small area in the
northernmost portion of the lot.
Surrounding zoning includes EFUHR, SM, and F1. The existing use is rural undeveloped land that is
used for grazing.
Land disposal sites are listed as a conditional use on non -high value farmland zoned Exclusive Farm
Use (EFU; DCC 18.16.031). The site is designated as containing farmland of statewide importance
only, which corresponds to soil types identified as non -high value farmland, therefore land disposal is
a conditional use on this site.
A conditional use review would be required to approve a landfill operation at this site in compliance
with DCC Chapter 18.128 Conditional Use, and specifically with DCC 18.128.015 General
Standards, which require the applicant to demonstrate that there is adequate transportation access
to the site, the natural and physical features of the site are considered suitable, and demonstrating
that the use will be compatible with existing and projected surrounding uses.
The standards for disposal sites as conditional uses found at DCC 18,128.120 Disposal Site would
also apply. These standards were used as part of the screening criteria to identify and evaluate
potential new landfill sites.
Additionally, because the site is within an EFU zone, DCC 18.16.040 requires that conditional uses
must meet the requirements of what is known as a Farm Impacts Test, described in ORS 215.296(1)
and included in the DCC at 18.16.O4O.A. which states that the proposed use will not force a
significant change or significantly increase the cost in accepted farm or forest practices on
surrounding lands devoted to farm or forest practices, and that the actual site on which the use is to
be located is the least suitable for the production of farm crops or livestock. The Farm Impacts Test
could lead to the Land Use Board of Appeals. See Appendix E for more information.
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/i Moon Pit Site I
The following are potential required permits. See Appendix E for more information.
Depending on the zoning strategy chosen for the site, one or more County land use approval permits
would be required including a Conditional Use Permit and Site Plan Review.
The Moon Pit site's existing access road crosses land owned and managed by the BLM and granting
the County access rights could constitute a new right-of-way easement which would be subject to the
National Environmental Policy Act because BLM would be issuing a permit or making a decision. An
environmental assessment would be prepared if it is deemed unlikely that a proposed action would
have a significant effect on the environment, or an environmental impact statement would be
prepared if the proposed action would have a significant effect on the environment.
Oregon Revised Statutes 459 requires that a solid waste facility apply to the DEQ for a Solid Waste
Disposal Permit prior to starting operation.
A DOGAMI Transfer of Surface Mining Permit may be required. However, if this permit process is not
applicable to the site, then an Operating Permit may be required. Unless the County is mining
aggregate for off -site export and use, mining operations related to landfill development and
operations are not considered surface mining operations under DOGAMI and are covered under
DEQ's permitting process (see ORS 517.750(16)(b)(F).
Oregon DEQ requires monitoring point sources and diffuse area -wide sources for potential air
contaminants. An Oregon Title V Air Quality Operating Permit will also be required. Under this permit
program, the facility has to report on compliance with conditions of its permit at least every six
months.
Natural Resource permits or compliance approvals that would be required include an Eagle
Incidental Take Permit; Oregon Department of Fish and Wildlife (ODFW) Wildlife Habitat Mitigation
Policy (OAR 635-415-0000); Greater Sage -Grouse Area Combining Zone (DCC 18.89.060); and
Wildlife Area Combining Zone (DCC 18.88.030).
4.1.3.2 Roth East Site
The following are potential required permits. See Appendix E for more information.
One or more County land use approvals or permits would be required for the EFU zoned site
including a Conditional Use Permit, Site Plan Review, and Landscape Management Review (either
Visible or Non -Visible).
An Oregon DEQ Solid Waste Disposal Permit would be required for this site.
Similar to the Moon Pit site, the Roth East site would be required to monitor point sources and
diffuse area -wide sources for potential air contaminants. It would also be required to apply for and
follow the regulations under Oregon's Title V Air Quality Operating Permit.
Natural Resource permits or compliance approvals that would be required include ODFW's Wildlife
Habitat Mitigation Policy (OAR 635-415-0000); Wildlife Area Combining Zone (DCC 18.88.030);
Greater Sage -Grouse Area Combining Zone (DCC 18.89.060); Sage -Grouse (OAR 635-140-0000).
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4.2 Transportation System
A brief description of the daily transportation activities anticipated at both sites, as well the location
and the associated findings with each is presented below. Appendix E Appendix F provides a
summary of the overall transportation -related considerations and findings for both sites.
® ®1 Daily Landfill Activities at Bothit
The Solid Waste Department anticipates that the daily activities would be comprised of the following:
■ The landfill would not be open to public use so all traffic generated by the site would be
associated with employees, the transfer of materials via truck, and service providers.
■ Seven employees would be on -site per day for operations and maintenance.
■ Approximately 35 haul trucks would transfer materials to the site per day, 7 days per week.
Based on these estimates, either site would generate a total of 84 vehicle trips on a typical day
(i.e., seven employee trips in and seven trips out and 35 truck trips in and 35 truck trips out). All the
existing transfer stations are located to the northwest of both sites being considered so the majority
of traffic would use US 20 to travel to/from the northwest of each.
EMA
The Moon Pit site is located between Bend and Millican and currently functions as an active surface
mine. The mine is accessed via an existing roadway that intersects US 20 opposite the Horse Ridge
Frontage Road to the south. The use of this existing roadway would minimize the upfront capital
expenditures needed if this site were selected.
The existing access road to the mine also provides access to the Badlands Wilderness area and
trailhead, which could create a perception about the interaction between large trucks and trail users.
Given that large trucks use the road today, it is suggested that if this site is selected, the County add
signage along the route to alert landfill drivers to the location of the Badlands Trailhead parking lot.
Field observations revealed that pavement repair and some roadway widening may be needed at
various locations along the existing access. Given that the access road abuts BLM lands, any
widening of the roadway to accommodate the landfill trucks would be subject to BLM review which
could be timely and costly, depending on the extent of repairs/widening needed.
As such, if this site is selected, a detailed engineering evaluation of the structural sufficiency of the
existing roadway and the need to re -pave and/or widen in places would need to occur and can
inform overall costs of this site. However, this site offers transportation and cost -related benefits that
are more optimal than those offered at the Roth East location.
4.2.3 Rothas it
The Roth East site is located southwest of the Newt Morris Road/US 20 intersection. There is an
existing dirt road to the property that connects to Pine Mountain Road. As such, access to a landfill
at this site would occur via the existing Pine Mountain Road/US 20 intersection or via construction of
a new access between Pine Mountain Road and Newt Morris Road that would connect to US 20. If
the existing dirt roadway connecting to Pine Mountain Road is used for access, this road would need
to be reconstructed to provide for both employee and truck traffic. In addition to anticipated trips
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described above for both sites, up to 5 water truck trips may be needed per day to supplement
exempt well water supplies at the Roth East site during the summer months.
Given that this site has no existing improved access road to US 20, the primary cost and siting
considerations relate to the construction of an access roadway of sufficient width and structural
integrity between the site and US 20. The need for a new roadway would require more upfront capital
expenditures compared to the Moon Pit site. A detailed engineering study would be needed to
assess the potential routes between the site and US 20. A preliminary review of possible alignments
identified at least four potential routes but more detailed evaluation is needed. This evaluation will
need to consider the length of the route between the site and US 20, how and where the route
intersects with US 20 (particularly related to the availability of sight distance along US 20), the
potential for impacts to and/or avoiding the adjacent BLM properties, and the availability of
right-of-way.
Finally, if the Roth East site were selected and the existing Pine Mountain Road/US 20 intersection
were the preferred access to the landfill, it is recommended that the County consider improving the
intersection to a traditional intersection design (T intersection) and adding wayfinding signage at
both the US 20 intersection and along the site access route.
From a transportation perspective, it appears that the Moon Pit site might be the optimal site given
the presence of the existing access road and its use by large trucks serving the existing surface
mine. However, if either site is selected, it is recommended that a detailed engineering study of
roadway construction (and/or reconstruction) feasibility be conducted to better understand potential
capital expenditures as well as impacts to adjacent BLM lands.
4.3 Water Infrastructure Assessment
Examination of Knott Landfill's 2020 water usage data revealed that average daily water demand
drops below 5,000 gallons per day (gpd) in the winter months and peaks around 50,000 gpd in the
summer months. The total annual water use for landfill operations in 2020 was approximately
6.8 million gallons. See Appendix G for more information.
Based on these historical water usage patterns, it is recommended that water rights are obtained
with an annual duty of 21.5 acre-feet, based on an estimated annual use of 7.0 million gallons per
year. Maximum daily demand for future operations is estimated to be 100,000 gallons per day (gpd),
assuming a peak month average daily flow of 50,000 gpd multiplied by a peak day factor of 2. A well
production rate of 208 gallons per minute (gpm) is recommended to supply this maximum daily
demand of 100,000 gpd during an 8-hour time frame. Additionally, a water storage capacity of
200,000 gallons is recommended to sustain maximum day demand and fire suppression water
storage needs in the event well or power supply issues.
Both sites are located within the Deschutes Groundwater Study Area, where mitigation is required for
new water right permits. In late 2023, the Oregon Water Resources Department declared an
indefinite basin -wide pause on processing new water right applications in this area, citing injury to
the hydrologic health of the basin. As a result of these two factors, the timeframe for securing and
mitigating for new water rights permits may extend beyond 2029 when the new landfill will need to
be operational. If Oregon Water Resources Department considers these two sites to be part of the
General Zone of Impact, General Zone temporary mitigation rights may be a viable short-term option
with an understood cost of around $3,300 per year. General Zone permanent mitigation credits
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could also be a possible long-term option from private water rights brokers at around $200,000 to
$250,000.
There are two wells on -site at Moon Pit, referred to as Well A and Well B. Well A was installed in 1986
and is currently inactive. Well B has been operational since 1994, is capable of producing
1,000 gpm, and is primarily utilized for on -site dust suppression. Water right permit G-12860 is
appurtenant to the Moon Pit site property for industrial use (dust control and gravel washing). The
maximum use rate for this permit is 1.09 cubic feet per second, which is equivalent to 490 gpm and
significantly greater than the anticipated future landfill operation water requirements. Although
transfer the water rights is not offered with the property acquisition, the seller is willing to lease a
partial water right to the County for landfill operational needs at a reasonable cost until the County
can secure its own water rights.
The Moon Pit site is located inside the Deschutes Groundwater Study area and the General Zone of
Impact Area. If a new water right permit is needed, General Zone temporary mitigation rights may be
a viable short-term option until permanent mitigation requirements can be satisfied. The estimated
costs for water infrastructure upgrades are $215,000 for water rights, $100,000 for well
improvements, $400,000 for a water storage tank, and $50,000 for site water piping, totaling an
estimated $765,000. See Appendix G for more information.
4.3.2 Roth
The Roth East site, located within the Deschutes Groundwater Study area and the General Zone of
Impact Area, has one existing well, the Powell Well (DESC 194), which is primarily used by a nearby
residence and for stock watering. The occurrence of groundwater at the Roth East proposed facility
site area is unknown, and available data suggest depth to first water is around 500 feet. The Powell
well can produce 50 gpm with no drawdown, suggesting it can produce water at a higher rate.
However, the reported well production occurred in 1990 following well installation, and the current
well yield capacity is unknown. The well would need to be upgraded or replaced to function as a
supply well for a future solid waste facility.
The existing Powell Well (also referred to as the "Deep Well") on the Roth East site does not have
water rights and is thus limited to the exempt well production rate of 5,000 gallons per day. Until
water rights can be secured, it is assumed that water trucks from Knott Landfill would be needed to
meet elevated water demands in March -October. It may be possible to purchase and transfer water
rights from an existing water rights holder in the vicinity.
There are no identified water rights appurtenant to the Roth property. The closest identified water
right to the Roth East site is a water right issued to the Bend Trap Club (water right permit G-16505).
If a new water right permit is needed, General Zone temporary mitigation rights may be a viable
short-term option until permanent mitigation requirements can be satisfied. The estimated costs for
water infrastructure upgrades are $215,000 for water rights, $500,000 for well improvements,
$400,000 for a water storage tank, $50,000 for site water piping, and a new water truck fill station,
totaling an estimated $1,190,000. See Appendix G for more information.
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4.4 Electrical Power Supply
The Moon Pit landfill site, served by Central Electric Cooperative (CEC), necessitates significant
upgrades to the existing electrical infrastructure to meet both initial and future power demands. The
site requires a new electrical service that is adequately sized to power initial landfill loads and future
landfill gas power generation.
The specific anticipated landfill electrical loads at Moon Pit include a Scale House/Electric Gate,
Office/Admin Building, Maintenance Building, Water Supply Well Pump, eight Leachate Pump
Stations, and a Gas Vacuum Blower. The need for 8 Leachate Pump Stations distinguishes Moon Pit
from Roth East in terms of power demand.
To accommodate these needs, CEC would need to upgrade and extend about 9.5 miles of existing
overhead utility lines from the closest three-phase power connection point to the Moon Pit location.
This includes upgrading 2.6 miles of an existing single-phase pole line and extending new three-
phase power lines (overhead or underground) for an additional 7 miles along US 20 with potential
easements through BLM property. The estimated utility cost for these upgrades is approximately
$2,000,000. See Appendix H for more information.
a
Roth East also falls under the jurisdiction of CEC for its electrical needs. Similar to Moon Pit, Roth
East will need a new electrical service tailored to support both the initial landfill operational
requirements and future landfill gas power generation.
Anticipated landfill electrical loads for Roth East are similar to those at Moon Pit but with only four
Leachate Pump Stations indicating a lower power demand compared to Moon Pit.
The infrastructure upgrade for Roth East involves approximately 2.3 miles of overhead utility line
enhancements from the nearest three-phase connection point. This comprises upgrading about
1.2 miles of an existing single-phase pole line and extending new three-phase lines (overhead or
underground) an additional 1.1 miles toward the landfill location possibly requiring easements
through private property. The estimated utility upgrade cost is $700,000; this is significantly lower
than that of Moon Pit. See Appendix H for more information.
4.5 Flood Risks
The flood risk assessment for the Moon Pit site reveals that while the site itself is not directly within
mapped flood hazard areas, the northern part of the site is near the 100-year floodplain for the Dry
River, an ephemeral stream. This proximity increases the risk of flood impacts, especially from
intense thunderstorms and periods of rapid snowmelt, which can lead to flash flooding. The site is
influenced by a relatively large upstream drainage basin of approximately 3 square miles, which
further elevates the risk of flash flooding.
Several existing drainage channels on the site convey runoff from the upstream drainage basin
northwest toward Dry River. The assessment emphasizes the potential impacts of climate change,
which may increase flood frequencies and extents. To mitigate these risks, the assessment
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recommends further study and the implementation of mitigation strategies, such as conservatively
sized perimeter ditches, to manage and reduce flood risks effectively. See Appendix I for more
information.
The flood risk assessment for the Roth East site indicates that the site is not directly within mapped
flood hazard areas. However, there is an upstream drainage basin of approximately 1 square mile
that presents a moderate risk of flash flooding. This risk is particularly pronounced during intense
thunderstorms and periods of rapid snowmelt, which can result in significant runoff.
Several channels on the site collect runoff from the northeast slope of Pine Mountain and drain
north through the site, discharging to Dry River, an ephemeral stream, near US 20. The assessment
highlights that the mapped floodplain for Dry River crosses US 20 in several locations, posing a
secondary flood risk to site access. To address this risk, coordination with state transportation and
hazard mitigation agencies is recommended to identify detours and alternate routes in case of
disruptions to US 20 due to flooding. See Appendix I for more information.
i !=
The Moon Pit site is located within the High Lava Plains physiographic province with pre -Holocene
northwest trending normal faults bounding Moon Pit, expressed by the site's fault bounded basin
(Appendix J). This setting provides the opportunity to readily screen the operations from public view.
In the southeastern two-thirds of Moon Pit, the surface geology consists of mid -Miocene -aged basalts
that erupted from vents within the Brothers Fault Zone and High Lava Plains to create the Bear
Creek Buttes. In the northwestern third of the site, the surface geology comprises alluvium that is
believed to have been deposited by the Dry River drainage. Gravel -rich alluvium and the underlying
basalt bedrock are quarried in this portion of the site. The northwest portion of the Site contains up
to 42 feet of layered sand and gravel alluvial sediment overlying approximately 20 to 30 feet of
basalt. This unit of basalt is underlain by approximately 6 feet of inter -flow sediment.
Test pits excavated in 1993, boreholes advanced in 1996, and test pits advanced in 2023 (Delve)
identified the following general strata in the alluvial (northwest; approximately 135-acre) portion of
Moon Pit:
■ Sand with silt topsoil - Lightweight pumiceous topsoil, foamier and more organic than
underlying sediment, thickness up to about 5 feet.
s Gravel with sand and cobbles - Horizontally bedded, thickness about 8 to 10 feet.
■ Sand with fine gravel - The predominant soil type in this portion of the site; thickness up to
42 feet.
■ Quaternary basalt - Believed to be a continuation of the Oregon Badlands basalt that has
been capped with alluvial sediment deposited within fault -bounded basins at the northwest
edge of Bear Creek Buttes.
The Roth East site is also located within the High Lava Plains physiographic province with only
pre -Holocene faults present nearby that affected the deposition of volcanic features surrounding
Roth East (Appendix J). Unlike Moon Pit, there are no visible expressions of these older faults. Roth
East lies southeast of the Millican Valley, a dry high desert perched basin bordered to the south by
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the Pine Mountain and to the north by Bear Creek Buttes. The Roth East development area would
require more effort to screen operations as compared to Moon Pit as it lies atop alluvial deposits
forming the northern flank of Pine Mountain. The deposits include talus, slope wash, fanglomerates
and windblown material.
A geophysical study carried out by Siemens and Associates in 2023 estimated at least 300 feet of
unconsolidated alluvial deposits overlying bedrock beneath the proposed development area. During
the 2023 geotechnical investigation, borings drilled in the upper 150 feet of subsurface strata
encountered subrounded basalt and tuff gravel mixed with varying proportions of silt and sand in
6- to 12-inch layers typical of alluvial deposits. Groundwater or saturated strata was not encountered
in the borings. Bedrock was also not encountered. Roth East's surface soil includes a notable
quantity of pebbles and cobbles, which gradually diminishes in size and quantity downslope toward
the lacustrine Millican Valley floor to the northwest. See Appendix J for more information.
The Moon Pit site is located near the eastern edge of the Upper Deschutes Basin. The regional
groundwater flow direction from Moon Pit within the basin is to the north-northwest. Two water wells
are located on -site, DESC 5750 (Well A), which was developed in 1986 and is currently not in use,
and DESC 9126 (Well B), which was developed in 1994 and is currently used. Well B is located at an
elevation of approximately 3,600 feet and reports a depth to water of 852 feet, indicating a
groundwater elevation of approximately 2,750 feet. The yield for Well B is estimated at 1,000 gpm
based on purging rates from the owner during the well sampling procedure.
Given the depth to groundwater is greater than 800 feet and the geology consists of a heterogeneous
and disconnected suite of volcanic units the potential for vertical migration of fluids from Moon Pit to
reach groundwater is low.
Water samples collected from Well B and analyzed for the typical suite of landfill parameters indicate
very good quality with no constituents reported above the EPA Maximum Contaminant Levels (MCL)
and only one parameter (iron) at a concentration above the OAR 340-40 numerical groundwater
quality reference levels. Slight exceedances of trace metals can be expected from water supply well
grab samples not specifically designed for compliance groundwater monitoring.
Roth East is located along the far east margin of the Upper Deschutes Basin. The regional
groundwater flow direction from the Millican Valley is likely to the north-northwest, roughly following
topography and the path of Dry River, which once catastrophically drained Lake Millican. There are
no wells in close proximity to the proposed development area. However, based on modelling using
existing water wells the regional groundwater elevation at the proposed development area is
anticipated to be approximately 3,800 feet above mean level.
A well located near the southwestern corner of Roth East (DESC 194; a.k.a., the Powell Well or Deep
Well) and situated approximately 1.1 miles from the proposed development area at an elevation of
roughly 4,800 feet (600 feet above the Millican Valley floor), reports a depth to water of 970 feet
(groundwater elevation of approximately 3830 feet) and a yield of 50 gpm. Given this well was
designed for residential uses the yield for a larger diameter well designed for industrial uses would
likely provide a higher yield. The geophysical investigation conducted by Siemens and Associates
indicates that first bedrock is located at a depth of greater than 300 feet below the surface of the
proposed development area, corresponding to an approximate elevation range of 4,150 to
4,300 feet.
Water wells within the presumed footprint of prehistoric Lake Millican (below an elevation of
approximately 4,300 feet) have reportedly encountered a saturated zone near the bottom of the
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approximately 450-foot-thick sedimentary sequence, with low yields. It is unknown whether this
shallower saturated zone is present beneath Roth East's development area. Assuming there is no
saturated zone above the bedrock in the development area, the groundwater would be expected to
be at least 500 feet below the development area. The potential for vertical migration of fluids from
Roth East through the thick sedimentary sequence and the unknown thickness of volcanic bedrock
to groundwater is low.
Groundwater samples were collected from the Powell Well (DESC 194) following purging and the
stabilization of the field indicator parameters and analytical results of typical landfill parameters
indicate very good water quality with no constituents reported above the EPA MCL or the OAR 340-40
numerical groundwater quality reference levels. See Appendix J for more information.
4.7 Preliminary Geotechnical Feasibility
Delve Underground conducted a preliminary geotechnical feasibility assessment related to the siting
of a new landfill on a 346-acre portion of the Moon Pit property. A copy of the preliminary
geotechnical feasibility report is included in Appendix K.
The preliminary geotechnical feasibility assessment included a combination of a desktop study and
limited geotechnical explorations consisting of test pits to provide a preliminary summary of the
subsurface conditions. The subsurface exploration program included 12 test pits excavated to
depths ranging from 2.6 to 7.0 feet below ground surface (bgs). All but two test pits were terminated
as a result of practical refusal of equipment on shallow bedrock. Bedrock observations were limited
to exposures created by quarrying activities, which indicated a variability within the underlying rock
mass. No laboratory tests have been performed to assess the adequacy of bedrock for future use as
a construction aggregate.
The preliminary assessment of the site did not identify geotechnical critical flaws for future
development as a municipal solid waste landfill. However, because of the shallow nature of bedrock
encountered, earthwork and site excavation will require extensive drilling and blasting methods to
excavate future waste cells to their proposed depths. Additional key summaries include:
® Faults that bound the graben (geologic term for earth crust between two faults and on which
the Moon Pit quarry is situated) are not included within the U.S. Geological Survey Quaternary
Fault and Fold Database. Alluvial units and the Newberry Volcano lava flow do not exhibit
offsets along the northwest projections of the faults; therefore, the faults are interpreted to
be inactive.
® Shallow bedrock is persistent throughout the site and covered with a thin (less than 10 feet
thick) veneer of undifferentiated alluvium and loess. Thicker amounts of alluvium may be
present where it has not been mined out in the northwestern portion of the site.
■ Practical refusal with conventional equipment occurred during the excavation of all test pits
which resulted in termination less than 10 feet bgs. Shallow bedrock conditions will likely
require drilling and blasting techniques to excavate the desired depth of the waste cells.
® Bedrock exposed in quarry exposures in the southeastern portion of the site consisted of a
complex sequence of basaltic lava flows and cinder -filled interbeds. Both lava flow and
interbeds generally varied between 2 and 10 feet thick.
® Review of seismic surveys and cross sections compiled by Siemens & Associates within the
David Evans and Associates, Inc. report entitled "Deschutes County Landfill Site Evaluation"
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(prepared for Deschutes County Department of Solid Waste, dated August 7, 1996) indicated
an irregular bedrock contact with varying depths of sediment accumulation within the
northwest portion of the site. Some drill and blast mining (for basalt rock products) was
conducted in this area but was discontinued because of poor rock quality.
■ Depth to groundwater is anticipated to be well below the bottom of the proposed landfill cells
(see Section 4.6.2).
® Based on the shallow bedrock conditions and the waste cells excavated into the underlying
bedrock, Delve does not anticipate issues with bearing capacity or settlement associated
with future site development.
■ On -site materials will require laboratory testing to assess whether materials meet the
specification of intended use per Oregon Standard Specifications for Construction.
■ Site Class B is preliminarily recommended for future seismic design based on the materials
encountered in the subsurface exploration program.
® Review of the site development plans by G. Friesen Associates, Inc., dated September 26,
2023, indicate 3H:1V (horizontal to vertical) slopes along the perimeter of the waste cells.
These slopes are suitable at this time based on the current understanding of the subsurface
conditions and that waste cells will be excavated into the underlying bedrock.
As noted above, the results of this study are based on a limited subsurface investigation and should
be considered preliminary in nature. Additional site characterization will be required to complete the
geotechnical characterization of this site if it is selected for final design, as well as to determine the
quality of rock for potential on -site use.
The estimated thickness of subsurface materials encountered at the time of exploration and the
anticipated use of materials is presented in Table 1. Across the site, the average thickness of
overburden materials (alluvium, loess, and colluvium) is estimated to be 5 feet, plus or minus 3 feet.
No laboratory tests have been performed to assess the durability of bedrock for future use as a
construction aggregate. Note that the current coverage of test pits is inadequate for fully assessing
the subsurface conditions for a 346-acre development, and lateral variations of materials likely exist.
Table 1. Soil Usage Summary for Moon Pit
Estimated
Geologic Unit
ASTM Classification
Thickness (feet)
Anticipated Use'
Alluvium/Loess2
Silty SAND (SM)
1 to 5.5
Daily cover
Well -graded GRAVEL with sand and cobbles (GW)
Well -graded SAND with silt (SW-SM)
Colluvium3
Well -graded GRAVEL (GW)
>6
Daily cover
Bedrock
Well -graded GRAVEL with silt and SAND (GW-GM)
1 to 4
Daily cover for gravel -sized or
(extremely
Well -graded GRAVEL with sand (GW)
finer; crush/screen oversize
weathered)4
rock clasts for drain rock,
Silty SAND with gravel and cobbles (SW)
structural fill, and road base
Bedrocks
N/A
Unknown
Crush for drain rock,
(unweathered)
structural fill, and road base
Notes:
1 Anticipated uses are assumed. No laboratory testing has been performed and bedrock quality is currently unknown. Laboratory testing
is required for approval of on -site use.
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2 Alluvium and loess accumulation throughout the undisturbed areas of the site and overlies bedrock, and old alluvial gravels previously
mined in the northwest portion of the site.
3 Colluvium limited to areas adjacent to fault scarp and only encountered in TP-3 and TP-4.
4 Bedrock encountered within test pits represents the upper weathering profile and contains varying amounts of sand and fines.
Bedrock quality is currently unknown and requires evaluation and laboratory testing to determine durability and quality.
5 Bedrock quality determination is beyond the scope of this exploration although visual observations of cuts and other exposures
suggest high variability ranging from poor to moderate.
Delve Underground conducted a preliminary geotechnical feasibility assessment related to the siting
of a new landfill on a 382-acre portion of the Roth East property. A copy of the preliminary
geotechnical feasibility report is included in Appendix K.
The preliminary geotechnical feasibility assessment included a combination of a desktop study and
limited geotechnical explorations consisting of four geotechnical borings, and two parallel
geophysical surveys utilizing electrical resistivity and seismic resistivity. Borings were advanced to
depths ranging from between 46.5 to 150 feet bgs and were terminated in predominantly gravelly
alluvial fan deposits. Bedrock was not encountered within the borings and is estimated to be at a
depth of approximately 400 feet based on the results of the geophysical surveys.
Disturbed soil samples were collected in conjunction with standard penetration tests (SPT) using a
standard split -spoon sampler and a modified California split -barrel sampler. However, because of the
relatively small sampler opening sizes (i.e., 1.375 to 2.4 inches), they do not provide an adequate
sample size to accurately describe a predominantly gravel soil type.
The preliminary assessment of the site did not identify geotechnical critical flaws for future
development as a municipal solid waste landfill. Additional key summaries include the following:
■ The unnamed faults near Millican Valley (U.S. Geological Survey fault ID 841) have an age
constraint of less than 750 thousand years (ka); considerably older than the 12,000 years
Holocene age defined by RCRA Subtitle D.
® The Pine Mountain catchment basin now drains to the northwest of Pine Mountain, and the
paleochannel that previously supplied sediment for the alluvial fan beneath the site is now
separated from the upslope catchment basin, and thus inactive. The elimination of this
sediment supply likely resulted from faulting of the linear ridge with a poor age constraint but
is likely older than mid Quaternary (>750,000 years), and considerably older than the
Holocene.
® The geomorphic relationship between the alluvial fan and surrounding topography suggests
that the fan is mid Quaternary or older in age, and that the upslope sediment supply for the
fan was disconnected around the same time, or before the faulting and uplift of the knob by
the unnamed faults near Millican Valley.
® Faulting of the knob is likely older than the Holocene (12,000 years) and not a hazard for the
future development of the site. However, a lack of Holocene deposition of sediments within
the site makes the age constraint relative to preliminary observations elsewhere within
Millican Valley.
® Preliminary review of the limited extent of lidar (light detection and ranging) within the
western extent of Millican Valley near Horse Ridge does not indicate any offsets of Newberry
Volcano lava flows, alluvial fans, or sediments associated with Lake Millican. All units within
this area are late Pleistocene in age, thus indicating faulting along the unnamed faults of
Millican Valley is older than 12,000 years, and not active by the RCRA Subtitle D definition of
Holocene (10,000 years to 12,000 years). However, the lack of deformation and offset within
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these units may indicate (1) a lack of deformation within the last 100,000 years, (2)
geomorphic overprinting as a result of a prolonged recurrence interval, and (3) discontinuous
fault structures across the basin.
■ Preliminary geotechnical drilling encountered coarse -grained soils to a maximum depth of
150 feet bgs that largely consist of gravels of varying sizes, consistent with materials
generally encountered within an alluvial fan. The materials appear to be predominantly
gravels, but SPT samples limit the ability to quantify the amount of gravel because of
sampling intervals and the limited size of what can enter the sampling tube.
■ Geophysical surveys indicate that up to 400 feet of what are interpreted as coarse -grained
soils are within the limits of the survey profiles. The boundary of the site has changed from
the time of original planning of the subsurface program, and it has since been moved farther
to the southwest; this area currently lacks coverage from the geophysical survey. Shallowing
of bedrock should be anticipated toward the south of the site near the linear ridge.
® Based on the materials encountered, conventional earth -moving equipment for mass grading
and excavation of soil is anticipated; however, large boulders on the order of 4-foot diameter
may be encountered.
® Based on the materials encountered, issues with bearing capacity or settlement associated
with future site development are not expected.
® On -site materials are likely suitable for use in site development pending future lab testing to
identify the durability of the material.
■ Site Class C is recommended for future seismic design based on the materials encountered
in the subsurface exploration program.
■ Site development plans by G. Friesen Associates, Inc., dated September 26, 2023, indicate
3H:1V (horizontal to vertical) slopes along the perimeter of the waste cells. These slopes are
suitable at this time based on the current understanding of the subsurface conditions, but
additional input may be required as plans for site development progress.
■ Site development plans by G. Friesen Associates, Inc., dated September 26, 2023, indicate
excavation extending to close proximity of the linear ridge. This area lacks subsurface
information because of the limitation of the exploration program, and shallow bedrock may
be encountered. To reduce cost overrun, a comprehensive geotechnical exploration program
should be completed as a future phase of work if this site is selected for future development.
As noted above, the results of this study are based on a very limited subsurface investigation and
should be considered preliminary in nature. Additional site characterization will be required to
complete the geotechnical characterization of this site if it is selected for final design, as well as to
determine the quality of gravels within the alluvial fan deposit for potential on -site use.
The estimated thickness of subsurface materials encountered at the time of the explorations and the
anticipated use of materials is presented on Table 2. Across the site, the average thickness of
overburden materials (alluvial fan deposits) is estimated to be greater than 150 feet. No laboratory
tests have been performed to assess the durability of gravels within the overburden materials for
future use as a construction aggregate. Note that the current coverage of borings and geophysical
surveys is inadequate for fully assessing the subsurface conditions for a 382-acre development, and
lateral variations of materials likely exists.
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Table 2, Soil Usage Summary for Roth East
Geologic Unit
ASTM Classification
Estimated
Thickness
Anticipated Use 1
Alluvial Fan
Silty SAND (SM)
>150 feet
Daily cover; crush/screen
Deposits 2
Well -graded SAND with silt (SW-SM)
for drain rock, structural
fill, and road base
Silty GRAVEL (GM)
Well -graded GRAVEL with silt and sand (GW-GM)
Well -graded GRAVEL with sand (GW)
Bedrock
N/A
Unknown
Unknown
Notes:
1 Anticipated uses are assumed. No laboratory testing has been performed to determine the durability of on -site gravel. Durability tests
will be required before final approval of on -site use.
2 Gravel percentage poorly constrained due to the limited opening diameter within the SPT and ModCal sampling tube.
3 Bedrock was not encountered in the geotechnical drilling exploration and estimated at around 400 feet below grade by geophysical
exploration.
4.8 Environmental Site Assessment Phase I
Parametrix conducted a Phase I Environmental Site Assessment (ESA) of the Moon Pit Alternative
including a review of available documentation pertaining to the subject property, a site
reconnaissance, and a review of relevant public agency documents. The Phase I ESA was conducted
in general accordance with ASTM Standard E1527-21, which defines the generally accepted industry
practices and procedures currently applicable at the time and place of this study. The purpose of the
Phase I ESA was to identify recognized environmental conditions (RECs) on or near the subject
property.
A review of historical aerial photographs, topographic maps, and the Hooker Creek construction
materials website indicate that the subject property was undeveloped until the late 1980s/early
1990s, when aggregate mining operations began. A former asphalt plant was reportedly located on
the subject property. Historical aerials can be referenced in the Phase I ESA, Appendix L.
As part of the Phase I ESA, regulatory database -listed sites by federal and Oregon agencies were
reviewed. Additionally, a compilation of historical uses of the subject property and site vicinity was
reviewed to determine whether past operations pose a risk to the subject property. The subject
property is listed on the Environmental Cleanup Site Information (ECSI) database. A comment dated
April 24, 1997, notes that there is no release reported and that the site was added to the ECSI list
for tracking purposes. The listing indicates that historical site use at the subject property is unknown,
but it may have been used by the military during World War II (historical document review did not
indicate any military usage on the subject property). No contamination at the site has been
documented. Listing of the site on the ECSI database for tracking purposes does not represent a
REC to the subject property. A full list of the databases reviewed can be found in Appendix L.
Parametrix conducted a site examination on October 5, 2023. The site examination consisted of
observing the area, providing observations of the general environmental conditions, and visually
assessing the area for evidence of hazardous substances and petroleum products. Two diesel
aboveground storage tanks (ASTs) are in use at the property: an approximately 250-gallon AST near
the gate and a 10,000- to 20,000-gallon AST that provides fuel to the generator for the groundwater
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supply well on -site. Minor staining was noted near the 250-gallon AST. De minimis staining was also
noted near the site entrance, in operation areas, at the equipment boneyard, and in the vicinity of
the former asphalt plant. None of the staining appeared to be extensive or associated with active
releases. A number of labeled and unlabeled drums (some still containing liquids) were also noted
throughout the site, primarily in the boneyard and near the generator building. Photographs taken
during the site reconnaissance can be found in the Phase I ESA, Appendix L.
�_-.:_ '" ' , � • ^ � to � � � ; ��
The former presence of the asphalt plant operations, as well as observed petroleum staining in
several areas of the property, represents a REC to the subject property.
Based upon the conclusions of this investigation of the subject property, a limited Phase II ESA is
recommended on the subject property to delineate shallow soil contamination, if any, and to
establish baseline conditions. The Phase II ESA should include surface and shallow depth soil
sampling in the former asphalt plant area, as well as other operational areas, near ASTs, and in
areas of observed petroleum staining.
Parametrix conducted a Phase I ESA of the Roth East Alternative including a review of available
documentation pertaining to the subject property, a site reconnaissance, and a review of relevant
public agency documents. The Phase I ESA was conducted in general accordance with ASTM
Standard E1527-21, which defines the generally accepted industry practices and procedures
currently applicable at the time and place of this study. The purpose of the Phase I ESA was to
identify RECs on or near the subject property.
A review of historical aerial photographs and topographic maps indicate that the subject property has
been undeveloped, aside from a single residence (constructed after 1994), since at least 1951.
Historical aerials can be referenced in the Phase I ESA, Appendix L.
As part of the Phase I ESA, regulatory database -listed sites by federal and Oregon agencies were
reviewed. Additionally, a compilation of historical uses of the subject property and site vicinity was
reviewed to determine whether past operations pose a risk to the subject property. The subject
property and adjacent properties are not listed on any regulatory database that would indicate a past
or current release or storage of hazardous materials. A full list of the databases reviewed can be
found in Appendix L.
Parametrix conducted a site examination on October 4, 2023. The site examination consisted of
observing the area, providing observations of the general environmental conditions, and visually
assessing the area for evidence of hazardous substances and petroleum products. There is one
residence on the subject property along with a couple of outbuildings and ranch infrastructure
(corrals, cattle watering trough, etc.). A domestic water well is located on the subject property, and a
large water storage tank was noted on the ridge above the well. Two small (approximately
250-gallon), locked fuel ASTs were noted in the vicinity of the other ranch infrastructure. The ASTs
appeared to contain residual fuel. No staining or distressed vegetation was noted in the vicinity.
Photographs taken during the site reconnaissance can be found in the Phase I ESA, Appendix L.
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4.8.2.1 Recognized Environmental Conditions
No RECs were identified for the Roth East site during Phase I ESA.
Based upon the conclusions of this investigation of the subject property, no further environmental
investigation is warranted at this time.
4.9 Air Quality, Weather, and Greenhouse Gas Emissions
Parametrix prepared a technical memorandum that summarizes local air quality data, weather data,
and a greenhouse gas (GHG) analysis for the Moon Pit and Roth East sites. Please see Appendix M. It
also discusses facilities in close proximity to the site that may contribute to local air quality issues.
The weather data from the past five years were acquired from two weather stations east of Bend,
Oregon. The data included minimum and maximum temperatures, daily precipitation, PM2.5 and
ozone (air quality) data, and wind speed and direction data.
The wind rose diagram from Redmond Roberts Field indicates dominant wind directions out of the
northwest and southeast, with the most frequently occurring wind speeds between 8 and 13 miles
per hour (mph). The Moon Pit site is located between two weather stations, and the Roth East site is
located farther east of the Horse Ridge station. General sustained wind speeds and gusts at the
Horse Ridge station are higher than at the Calgary Loop station indicating that wind conditions at
Roth East are likely more intense than at the Moon Pit site, though these station data do not
necessarily represent site conditions. During development and operation of the landfill, an on -site
weather station will be located at the site to inform the County's adaptation of landfill operations
based on current weather conditions.
Local air quality data was reviewed from the past five years, which were downloaded from the
Oregon Department of Environmental Quality (DEQ) website. The closest publicly owned air quality
monitoring station is located at Prineville Davidson Park. The maximum PM2.5 level measured at
this station was recorded on September 12, 2020. The spikes in monitored PM2.5 are likely
associated with large wildfires in Oregon, Washington, and California during those time periods. The
maximum ozone level was recorded on September 12, 2020. The vicinity of both sites is
predominantly vacant, undeveloped land. There are no industrial or power -generating plants within a
3-mile radius of either site that would contribute to areawide air quality conditions.
Mapped wildfire risk data indicate that both the Moon Pit and the Roth East sites have a high burn
probability. According to the U.S. Forest Service, burn probability is based on the likelihood of over
250 acres burning at a given location (determined by wildfire simulation modeling). A high probability
indicates between 1 in 500 and 1 in 50 chance of a wildfire over 250 acres in a single year. For both
sites, fire protection measures would be in -place and the selected site is expected to function as a
fire break - relatively devoid of fuel sources - that would interrupt the continuation of wildfires
moving towards the site.
GHG emissions were calculated for scenarios involving the haul transportation of municipal solid
waste from transfer stations to Moon Pit and Roth East. The baseline fleet transition that was
evaluated (diesel to renewable natural gas [RNG] to electric) resulted in a contribution of Moon Pit of
-50,000 MT CO2e whereas Roth East would generate-75,000 MT CO2e of GHG emissions over the
2029 to 2129 timeframe. The transition to renewable diesel is already underway, and RNG is also a
reasonable, present-day option. These fuel transitions would reduce GHG emissions further but also
offer opportunities for cost reduction and revenue streams.
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The 5-year record of temperature data collected at the BEND station reported a minimum
temperature of -7 degrees Fahrenheit (F) on February 23, 2022, and a maximum temperature of
107 degrees F on June 30, 2021. Temperature data at this station are spotty for the latter part of
2022 and 2023. Additional station data can be referenced in the Air Quality Technical Report,
Appendix M.
MWIRRNNNl �
The 5-year record of precipitation data collected at the BEND station reported sixteen precipitation
events exceeding 0.5 inches in a day, occurring in fall, winter, and spring. Fewer significant
precipitation events occurred during summer. Average daily precipitation data collected at the BEND
station reported eleven daily averages above 0.2 inches and significantly lower averages during
summer months. Additional station data can be referenced in the Air Quality Technical Report,
Appendix M.
Lightning susceptibility in the vicinity of the Moon Pit site is relatively low (a risk index score of 20.7
based on FEMA National Risk Index methodology 1.
Dominant wind directions at the Redmond Roberts Field station (22 miles northwest of the site) are
out of the southeast. Most often occurring wind speeds are between 8 and 13 miles per hour. The
Calgary Loop (EW816O) weather station reports sustained winds up to 18 miles per hour and gusts
up to 31 miles per hour. The US 20 Horse Ridge station reports sustained winds up to 26 miles per
hour and gusts up to 43 miles per hour. Winds speeds at the Moon Pit site are expected to be
between these ranges.
Available relevant air quality data from the past 5 years were downloaded from the DEQ website.2
The closest publicly owned air quality monitoring station is located at Prineville Davidson Park,
approximately 25.4 miles northeast of the site. Air quality data from this station monitors particulate
matter, or PM2.5, and ozone. PM2.5 is atmospheric particulate matter with a diameter less than 2.5
micrometers. Ozone can cause oxidation of electronics and sensitive instruments.
The maximum PM2.5 level (518.1 micrograms per cubic meter [pg/m3]) measured at the Prineville
Davidson Park station was recorded on September 12, 2020. These data were supplemented with
PM2.5 data from the Bend NE 8th and Emerson station, which is 16 miles northwest of the site. The
maximum PM2.5 level (547.1 pg/m) measured at the Bend NE 8th and Emerson station was
recorded on August 16, 2021. The spikes in monitored PM2.5 are likely associated with large wildfires
in Oregon, Washington, and California during those time periods. Local and regional wildfires are
generally the largest contributor to spikes in airborne particulates in eastern Oregon.
1 https://hazards.fema.gov/nri/li htnin
2 https:/Zoragi deq state or us/Rem/stationreport
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The maximum ozone level (39 parts per billion) was recorded on September 12, 2020.
4.9.1.5 Local Air Quality Activities and Impacts
The vicinity of the site is predominantly vacant, undeveloped land. There are no industrial or power -
generating plants within a 3-mile radius that would contribute to areawide air quality conditions.
4.9.1.6 Wildfire Risk
The Moon Pit site is mapped by the US Forest Service as having a high burn probability. Although the
frequency of lightning strikes is higher near Moon Pit, the extent of historical fires suggests that fires
near the Moon site are typically smaller and less -likely to propagate. The soils and landforms of the
Moon Pit site have low vegetation production potential which limits the accumulation of fuels. Thus,
fire events historically have been typically limited to a few trees. Stand replacement, and mixed -
severity fire events were infrequent (more than 150 years).
The 5-year record of temperature data collected at the BEND station reported a minimum
temperature of -7 degrees Fahrenheit (F) on February 23, 2022, and a maximum temperature of
107 degrees F on June 30, 2021. Temperature data at this station are spotty for the latter part of
2022 and 2023. Additional station data can be referenced in the Air Quality Technical Report,
Appendix M.
The 5-year record of precipitation data collected at the BEND station reported sixteen precipitation
events exceeding 0.5 inches in a day, occurring in fall, winter, and spring. Fewer significant
precipitation events occurred during summer. Average daily precipitation data collected at the BEND
station reported eleven daily averages above 0.2 inches and significantly lower averages during
summer months. Additional station data can be referenced in the Air Quality Technical Report,
Appendix M.
Lightning susceptibility in the vicinity of the Roth East site is relatively low (a risk index score of 20.7
based on FEMA National Risk Index methodology 3.
Dominant wind directions at the Redmond Roberts Field station (22 miles northwest of the site) are
out of the southeast. Most often occurring wind speeds are between 8 and 13 miles per hour. The
US 20 Horse Ridge station reports sustained winds up to 26 miles per hour and gusts up to 43 miles
per hour. Wind speeds at the Roth East site are expected to generally resemble what has been
observed at this weather station.
Concerns have been raised by the public regarding high winds, whirlwinds carrying dust and debris,
and thermal draft that are utilized by paragliders. These concerns relate to landfill operations, as
3 https://hazards.fema.Fov/nri/lightning
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strong winds can exacerbate various environmental and operational challenges. Wind has the
potential to spread litter and debris beyond the landfill boundaries. Additionally, airborne particles
carrying odors from decomposing waste may be dispersed, causing nuisance to nearby communities.
Operationally, high winds can disrupt daily landfill activities, affecting waste deposition and
compaction processes. To mitigate wind -related risks, landfill operators often implement engineering
controls such as windbreaks, cover systems, and dust suppression measures. Regular monitoring
and contingency plans are crucial to promptly address adverse weather conditions and ensure the
effective and environmentally responsible management of landfill sites.
Available relevant air quality data from the past 5 years were downloaded from the DEQ website.4
The closest publicly owned air quality monitoring station is located at Prineville Davidson Park,
approximately 31 miles northeast of the site. Air quality data from this station monitors particulate
matter, or PM2.5, and ozone. PM2.5 is atmospheric particulate matter with a diameter less than
2.5 micrometers. Ozone can cause oxidation of electronics and sensitive instruments.
The maximum PM2.5 level (518.1 pg/m3) measured at the Prineville Davidson Park station was
recorded on September 12, 2020. These data were supplemented with PM2.5 data from the Bend NE
8th and Emerson station, which is 25 miles northwest of the site. The maximum PM2.5 level
(547.1 pg/m3) measured at the Bend NE 8th and Emerson station was recorded on August 16,
2021. The spikes in monitored PM2.5 are likely associated with large wildfires in Oregon, Washington,
and California during those time periods. Local and regional wildfires are generally the largest
contributor to spikes in airborne particulates in eastern Oregon.
The maximum ozone level (39 parts per billion) was recorded on September 12, 2020.
4.9.2.5 Local Air Quality Activities and Impacts
The vicinity of the site is predominantly vacant, with a handful of rural residential properties located
throughout the area. There are no industrial or power -generating plants within a 3-mile radius that
would contribute to areawide air quality conditions.
4.9.2.6 Wildfire Risk
The Roth East site is mapped by the US Forest Service as having a high burn probability. This site has
more productive soils supporting sage steppe and more invasive species, especially cheatgrass, that
have a higher potential of carrying wildfire. Where there is an abundance of invasive nonnative
species such as cheatgrass, areas that used to burn once every 20 to 100 years can now burn every
7.5 to 15 years in sage steppe habitat.
4 https://oragi.de .state.or.us/Report/station re port
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4.10 Natural Resources
The site is located in the Smith Canyon -Dry River (HUC 170703050710) watershed, with general
slope to the northwest. The site consists of an active aggregate material mine interspersed with
juniper woodland and shrubland. The site is incidentally grazed by cattle entering through gaps in
fencing. The site is bordered by BLM land and is nearby to Oregon Badlands Wilderness. The
topography of the site is slightly sloped to the northwest with hillsides directly outside the site to its
north, east, and south. The site elevation ranges from 3,600 to 3,860 feet.
4.10.1.2 Vegetation
Present within the site is 167.1 acres of juniper woodland and 10.9 acres of shrub steppe. The
remainder of the site consist of disturbed mined out areas, roads, and buildings (206.82 acres). The
vegetation in the juniper woodland was dominated by western juniper (Juniperus occidentalis), big
sagebrush (Artemisia tridentata), rubber rabbitbrush (Ericameria nauseosa), cheatgrass (Bromus
tectorum), bluebunch wheat grass (Pseudoroegneria spicata), and Idaho fescue (Festuca
idahoensis). Shrub steppe habitat was dominated by big sagebrush, rubber rabbitbrush, cheatgrass,
bluebunch wheat grass, and Idaho fescue. Other native species found include antelope bitterbrush
(Purshia tridentate), cushion wild buckwheat (Eriogonum ovalifolium), common yarrow (Achillea
millefolium), needle and thread (Hesperostipa comata), and Sandberg bluegrass (Poa secunda).
Common weedy species found within disturbed areas include cheatgrass, night -flowering catchfly
(Silene noctiflora), Russian thistle (Salsola tragus), Mexican fireweed (Bassia scoparia), and tumble
mustard (Sisymbrium altissimum). Mexican fireweed is listed as a noxious weed by the Oregon
Department of Agriculture.
r i
.2.1 Wetland and Waters
An artificial pond built within uplands adjacent to a mine cell in the site's northwest was found to
have wetland characteristics (Appendix N). The pond was originally used for gravel and sand washing
but is now used for dust control and for fire suppression. Three streambeds are mapped as
intermittent seasonally flooded riverine features by National Wetland Inventory to occur within the
eastern half of the site. These features are located in gullies with upland vegetation. The gullies
lacked stream bed and bank features and did not contain hydric soils or hydrophytic vegetation
(Appendix N). These gullies are likely ephemeral systems that only have flow during spring melt in
high snowpack years. The artificial pond and the ephemeral gullies would not be considered
jurisdictional. No other wetland or water features were observed on -site. Site development would not
require permitting under Sections 404 and 401 of the Clean Water Act and Oregon's Removal -Fill
Law (OAR 196-795-990).
Federally listed threatened and endangered species or designated critical habitat are not likely to be
present using habitat found within the site (Appendix N); therefore, site development would not
initially require permitting under Section 10 or Section 7 of the Endangered Species Act. If greater
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sage grouse ([sage -grouse] Centrocercus urophasianus) or pygmy rabbit (Brachylagus idahoensis)
are listed as threatened or endangered during planning and construction of the SWMF or during
major operational changes once constructed, the County would need to consult with USFWS for
compliance under Section 10 or Section 7 of the ESA (Appendix M).
The site is within 2 miles of a golden eagle nest and its development will result in a permanent
alteration of habitat and an Eagle Incidental Take Permit may be required for project development.
The permit would be used for consultation and to determine a take statement and associated
required mitigation. Potential mitigation can be conducted via an in -lieu fee which is calculated as
take over time. Alternatively, Deschutes County could allocate money to a local utility company to
retrofit utility poles to protect raptors and other birds from electrocution through a Memorandum of
Agreement. See Appendix N for further information Bald and Gold Eagle Protection Act and
requirements for permitting site development.
Various migratory birds that are protected under the Migratory Bird Treaty Act of 1918 may forage on
or nest on the site. To avoid and minimize effects to migratory birds, initial site development
(vegetation clearing and grubbing) should be conducted during the non -nesting season. If vegetation
disturbance occurs during the nesting season, the site should be surveyed for nesting birds by a
qualified biologist. See Appendix N for further information on Migratory Bird Treaty Act species that
may be present on -site and for construction best management practice to minimize impacts.
The site is entirely within mule deer (Odocoileus hemionus) and elk (Cervus canadensis) winter range
designated by ODFW and is partially in a Wildlife Area Combining Zone for North Paulina Winter
Range designated by Deschutes County. The site is also entirely within essential and limited
pronghorn (Antilocapra americans) habitat as designated by ODFW. Tracks and scat of mule deer
and elk were observed throughout the site. The habitat on -site is of low to moderate quality for these
big game species (Appendix N). Site development would result in a permanent loss of 167.1 acres of
juniper woodland and 10.9 acres of shrub steppe which would require mitigation (see below in
Section 4.10.3)
The Site is not sage -grouse habitat (Appendix N). However, site development would result in indirect
impacts that would impact low density sage -grouse habitat. Indirect impacts can include sound
disturbance and from increased densities of ravens (Corvus corax). Landfills can result in elevated
densities of ravens due to additional food sources and roosting locations. Ravens predate on sage -
grouse and higher abundance of the species within sage -grouse habitat has been linked with lower
sage -grouse reproductive success.
In coordination with ODFW, the estimated impact of site development on sage -grouse is a loss of
7.8 functional acres which would require mitigation (see below in Section 4.10.3).
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n
Mule Deer and elk winter range and essential and limited pronghorn habitat are considered
Category 2 habitat by ODFW's Wildlife Habitat Mitigation Policy (OAR 635-415-0000). Category 2
habitat is deemed to be essential for a species, populations, or species assemblage (OAR 635-415-
0025). Avoidance of impacts through alternatives to the proposed action are recommended. If
impacts are unavoidable, mitigation of impacts would be required through in -kind, in -proximity,
habitat mitigation to achieve "no net loss" and a "net benefit" of habitat quantity or quality (OAR
635-415-0025(B)).
A mitigation plan would need to be developed to characterize compensatory mitigation to impacts to
167.1 acres of juniper woodland and 10.9 acres of shrub steppe. Because impacts to mule deer and
elk winter range essential and limited pronghorn habitat spatial overlap, mitigation for each can be
stacked into one mitigation project. Mitigation may involve making on -site habitat improvements or
acquiring a parcel of land with those habitats to prevent its development (avoided loss) or improve
its habitat (enhancement). Enhancement can include a combination of actions that may include
livestock grazing restrictions, weed treatment, native revegetatio n/ resto ration, fire readiness, and
fence removal/fence upgrade. Further information on mitigation options for mule deer, elk and
pronghorn habitat can be found in Appendix N.
4.10.3.2 Sage -Grouse
Site development would be considered a large-scale development (>40 acres) which would impact
significant sage -grouse habitat and thus is considered a conflicting use (OAR 660-023-0115(7)).
Conflicting uses require compliance with the mitigation hierarchy and ODFW's Sage -grouse Mitigation
Program and Policy. The development of the site must show that the overall public benefits outweigh
the damage to the significant sage -grouse habitat (DCC 18.89.110). The development of the SWMF at
the site must demonstrate that impacts to sage -grouse habitat are unavoidable and the project was
developed to minimize impacts. The extent of direct and indirect impacts on significant sage -grouse
habitats must be mitigated for and provide a net conservation benefit to sage -grouse (OAR 635-140-
0010(e)).
Site development would result in the loss of 7.8 functional acres of sage -grouse habitat. To achieve a
net conservation benefit, ODFW requires compensatory mitigation to restore 115% of impacted
functional acres. Thus, a mitigation plan would need to be developed to characterize the restoration of
9 functional acres of sage -grouse habitat. Mitigation actions include acquisition of bank credits,
payment in -lieu, and permittee responsible on or off -site mitigation. At present, there is no mitigation
bank available with approved credits. ODFW is currently reviewing documents for a mitigation bank
that could be a future option for mitigation for site development. The estimated in -lieu fee cost
provided by ODFW is $500,000. The in -lieu fee cost should be considered as the maximum cost for
sage -grouse mitigation. Perm ittee-responsible on -site mitigation is not possible given the extent of the
SWMF on the site. Off -site mitigation could involve acquiring a parcel of land and performing mitigation
actions or working with private or public landowners on a conservation plan. Common mitigation
measures that could result in restoration of sage -grouse habitat include juniper removal, cattle grazing
management, reseeding of native forbs and grasses, fence removal, and invasive removal. Further
information on mitigation options for sage -grouse habitat can be found in Appendix N.
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it !1111111pil 1 11111111111►
The development of the SWMF at the site would require minimization and avoidance through site
design, employing best management practices during construction and operations to avoid impacts
to Migratory Bird Treaty Act -protected species, and to mitigate for impacts to golden eagle habitat,
mule deer and elk winter range, essential and limited pronghorn habitat, and significant sage -grouse
habitat. The initial cost of mitigation is estimated to be $700,000 with $800,000 in operations and
maintenance. These values are approximations of costs for site development and should only be
used for site selection comparisons for the SWMF. Further development of a mitigation plan and
coordination with ODFW, the County, and others would be required to determine the cost of natural
resource mitigation for the development of the SWMF at Moon Pit. Further information on cost
estimates can be found in Appendix N.
!: 1
The site is located in the Mahogany Butte -Dry River (HUC 170703050706) watershed, with general
slope to the northwest. The site consists of sage brush steppe environment with native and non-
native grasses and bunchgrasses and is currently used for grazing. The site is bordered by private
lands that are also used for grazing. The topography of the site is slightly sloped to the north. The site
elevation ranges from 4,480 to 4,600 feet.
4.10.5.2 Vegetation
The site is entirely composed of shrub steppe habitat. Vegetation within the site is dominated by big
sagebrush, rubber rabbitbrush, crested wheat grass (Agropyron cristatum), and Idaho fescue. Other
native species found include western juniper, bluebunch wheat grass, cushion wild buckwheat,
antelope bitterbrush, lupine (Lupinus species), and prairie June grass (Koeleria macrantha). Invasive
and non-native species present in low densities included cheatgrass, spotted knapweed (Centaurea
stoebe), tumble mustard, medusahead rye (Taeniatherum canput-medusae), and clasping pepper
weed (Lepidium perfoliatum). Medusa rye and spotted knapweed are listed as noxious weeds by the
Oregon Department of Agriculture.
0 . ". Roth East Site Protected Species, Habitat, and
Wetland and Waters
Within the site, nine streambeds are mapped as intermittent seasonally flooded riverine streambeds
by National Wetland Inventory. These features are located in gullies with upland vegetation. The
gullies lacked stream bed and bank features and did not contain hydric soils or hydrophytic
vegetation (Appendix N). These gullies are likely relict topographical features from previous climatic
conditions and are currently ephemeral systems that may only have flowing water during spring of
high snow pack years. No other wetland or water features were observed on -site. Site development
would not require permitting under Sections 404 and 401 of the Clean Water Act and Oregon's
Removal -Fill Law (Oregon Administrative Record [OAR] 196.795-990) as features present on -site are
not jurisdictional.
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4.10.6.2 Federal and State Listed Species
Federally listed threatened and endangered species or designated critical habitat are not likely to be
present using habitat found within the site (Appendix N); therefore, Site development would not
initially require permitting under Section 10 or Section 7 of the Endangered Species Act. If sage -
grouse or pygmy rabbit are listed as threatened or endangered during planning and construction of
the SWMF or during major operational changes once constructed, the County would need to consult
with USFWS for compliance under Section 10 or Section 7 of the ESA (Appendix M).
4.10.6.3 Bald and Gold Eagle Protection Act
The site is not within 2 miles of a golden eagle or bald eagle nest and thus site development is
unlikely to impact these species. Site development would not require permitting under the Bald and
Gold Eagle Protection Act.
4.1.0.6.4 Migratory Bird Treaty Act
Various migratory birds that are protected under the Migratory Bird Treaty Act of 1918 may forage on
or nest on the site. To avoid and minimize effects to migratory birds, initial site development
(vegetation clearing and grubbing) should be conducted during the non -nesting season. If vegetation
disturbance occurs during the nesting season, the site should be surveyed for nesting birds by a
qualified biologist. See Appendix N for further information on Migratory Bird Treaty Act species that
may be present on -site and for construction best management practice to minimize impacts.
4.10.6.5 Big Game Range
The site is entirely within mule deer (Odocoileus hemionus) and elk (Cervus canadensis) winter range
designated by Oregon Department of Fish and Wildlife (ODFW) and is partially in a Wildlife Area
Combining Zone for Deer Winter Range designated by Deschutes County. The site is also entirely
within essential and limited pronghorn (Antilocapra americans) habitat as designated by ODFW and
is within a Wildlife Area Combining Zone for Antelope Range as designated by Deschutes County.
No tracks or scat of these big game species were observed on -site. The habitat on -site is of
moderate to high quality for these big game species. Site development would result in a permanent
loss of 309.3 acres intact shrub steppe habitat which would require mitigation (see below in
Section 4.10.7)
4.1.0.6.6 Sage -Grouse
The site is entirely within low -density greater sage -grouse habitat and is adjacent to core area
sage -grouse habitat as designated by ODFW. The site is used lightly by sage -grouse during the
summer and winter and is located within a corridor that connects leks located to the site's east and
west (Appendix N).
The habitat on -site is of moderate quality for sage -grouse. Site development would result in direct
and indirect impacts to sage -grouse habitat. Direct habitat includes habitat removal whereas indirect
impacts can include noise disturbance during construction and operations and predation from
increased densities of ravens (Corvus corax). Landfills can result in elevated densities of ravens due
to additional food sources and roosting locations. Ravens predate on sage -grouse and higher
abundance of the species within sage -grouse habitat has been linked with lower sage -grouse
reproductive success.
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In coordination with ODFW, the estimated impact of site development on sage -grouse is a loss of
173.3 functional acres which would require mitigation (see below in Section 4.10.7).
Mule Deer and elk winter range and essential and limited pronghorn habitat are considered Category
2 habitat by ODFW's Wildlife Habitat Mitigation Policy (OAR 635-415-0000). Category 2 habitat is
deemed to be essential for a species, populations, or species assemblage (OAR 635-415-0025).
Avoidance of impacts through alternatives to the proposed action are recommended. If impacts are
unavoidable, mitigation of impacts would be required through in -kind, in -proximity, habitat mitigation
to achieve "no net loss" and a "net benefit" of habitat quantity or quality (OAR 635-415-0025(B)).
A mitigation plan would need to be developed to characterize compensatory mitigation to impacts to
309.3 acres of shrub steppe. Because impacts to mule deer and elk winter range essential and
limited pronghorn habitat spatial overlap, mitigation for each can be stacked into one mitigation
project. Mitigation may involve making on -site habitat improvements or acquiring a parcel of land
with those habitats to prevent its development (avoided loss) or improve its habitat (enhancement).
Enhancement can include a combination of actions that may include livestock grazing restrictions,
weed treatment, native revegetation/restoration, fire readiness, and fence removal/fence upgrade.
Further information on mitigation options for mule deer, elk and pronghorn habitat can be found in
Appendix N.
4.10.7.2 Sage -Grouse
Site development would be considered a large-scale development (>40 acres) which would impact
significant sage -grouse habitat and thus is considered a conflicting use (OAR 660-023-0115(7)).
Conflicting uses require compliance with the mitigation hierarchy and ODFW's Sage -grouse
Mitigation Program and Policy. The development of the site must show that the overall public
benefits outweigh the damage to the significant sage -grouse habitat (DCC 18.89.110). The
development of the SWMF at the site must demonstrate that impacts to sage -grouse habitat are
unavoidable and the project was developed to minimize impacts. The extent of direct and indirect
impacts on significant sage -grouse habitats must be mitigated for and provide a net conservation
benefit to sage -grouse (635-140-0010(e)).
Site development would result in the loss of 173.7 functional acres of sage -grouse habitat. To
achieve a net conservation benefit, ODFW requires compensatory mitigation to restore 115% of
impacted functional acres. Thus, a mitigation plan would need to be developed to characterize the
restoration of 199.3 functional acres of sage -grouse habitat. Mitigation actions include acquisition of
bank credits, payment in -lieu, and permittee responsible on or off -site mitigation. At present, there is
no mitigation bank available with approved credits. ODFW is currently reviewing documents for a
mitigation bank that could be a future option for mitigation for site development. The estimated
in -lieu fee cost provided by ODFW is $7.6 million. The in -lieu fee cost should be considered as the
maximum cost for sage -grouse mitigation. On -site mitigation would involve improving habitat
conditions within the parcel of land on or adjacent to the impact site, whereas off -site mitigation
could involve acquiring a parcel of land and performing mitigation actions or working with private or
public landowners on a conservation plan. Common mitigation measures that could result in
restoration of sage -grouse habitat include juniper removal, cattle grazing management, reseeding of
native forbs and grasses, fence removal, and invasive removal. Further information on mitigation
options for sage -grouse habitat can be found in Appendix N.
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The development of the SWMF at the site would require minimization and avoidance through site
design, employing best management practices during construction and operations to avoid impacts
to Migratory Bird Treaty Act -protected species, and to mitigate for impacts to mule deer and elk
winter range, essential and limited pronghorn habitat, and significant sage -grouse habitat. The initial
cost of mitigation is estimated to be $1,500,000 with $2,500,000 in operations and maintenance.
The maximum cost of mitigation is estimated to be $8,800,000 with $7,600,000 for in -lieu payment
to ODFW for sage -grouse habitat impacts. These values are approximations of costs for site
development and should only be used for site selection comparisons for the SWMF. Further
development of a mitigation plan and coordination with ODFW would be required to determine the
cost of natural resource mitigation for the development of the SWMF at Roth East. Further
information on cost estimates can be found in Appendix N.
4.11 Archaeology and Cultural Heritage
FFR
A reconnaissance survey for archaeological and historical resources was completed by Willamette
Cultural Resources Associates, Ltd. (WillametteCRA) at the Moon Pit and Roth East locations in
September 2023. The intent of the reconnaissance survey was to assess the potential for cultural
resources at each location and provide further actions that may be necessary to address cultural
resources requirements. The reconnaissance was not a compliance -level survey (by state or federal
standards) as the project areas were not surveyed systematically to cover all of the potential impact
areas, and identified resources were not formally recorded with the Oregon State Historic
Preservation Office (SHPO). The following is a summary of WillametteCRA's reports, which are
included in their entirety in Appendix 0.
w
WillametteCRA performed a records and literature review of sites and survey data on file with the
Oregon SHPO, General Land Office maps and survey notes, historic topographic maps and aerial
photographs, and historical references in the WillametteCRA in-house library.
Three previous archaeological surveys have occurred within portions of the Moon Pit location. These
prior surveys resulted in the identification of two archaeological resources within Moon Pit, and three
archaeological resources immediately adjacent to Moon Pit. These resources are primarily single
precontact lithic artifacts and small lithic scatters. The exception to this is a large multicomponent
site near to Moon Pit. This site (35DS2384) is comprised of multiple precontact rock art panels,
several concentrations of lithic debitage, multiple formed tools, and remnant features of a historic
period farmstead/ranch bracketing a slot canyon located north of Moon Pit. The site has been
recommended as eligible for listing in the National Register of Historic Places (NRHP).
Historic maps and aerial imagery depict no developments within Moon Pit with the exception of
informal roads/trails. Historically, no buildings or structures were present.
Moon Pit is located on a parcel that encompasses both a relatively level lowland and gentle slopes
leading up to Horse Ridge in the south, as well as a level upland area in the northwest. Relic
drainages bisect the property in the southeast and east. Intensive mining and quarrying activity has
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modified the topography and hydrology of the project parcel over the last 20 to 30 years. Given the
proximity of a large, NRHP-eligible archaeological site (35DS2384), the presence of drainages, and
the distribution pattern of previously identified sites in the broader vicinity, portions of the parcel
undisturbed by mining activity have a moderate to high probability of containing precontact
archaeological resources. Based on previous archaeological investigations, sparse lithic scatters
and/or lithic isolates that may represent ephemeral habitation areas related to 35DS2384 are likely
present.
Extant buildings and structures within the parcel do not date to the historic period and there are no
historic built environment resources within or in the immediate vicinity of Moon Pit. WillametteCRA
suspects there is a low probability for historic -period archaeological resources.
4.11.2.2 Roth East.
There has only been one previous archaeological study within Roth East; however, it did not involve
field survey. As a result, the Roth East location has never been surveyed and there are no previously
recorded archaeological resources.
A review of historic maps and aerial imagery of Roth East shows historic development limited to
informal roads and trails and limited agricultural activity. There is one structure present in the north
central portion of Roth East visible as early as the 196Os. Modern aerial imagery suggests the ruins
of the structure may still be present.
Roth East is located on a parcel that encompasses both a relatively level lowland, and gentle slopes
leading up to Pine Mountain in the south and a level upland area in the northeast part of the project
that overlooks the valley. Relic drainages bisect the property. Given the lack of previous survey,
presence of drainages, and the distribution pattern of previously identified sites in the broader
vicinity, the area has a high probability of containing precontact archaeological resources. Based on
previous archaeological investigations, sparse lithic scatters and/or lithic isolates that may represent
ephemeral habitation areas are likely present.
There are no historic built environment resources in Roth East. Historic map research shows little to
no historic -period development within or near the project area. WillametteCRA suspects there is a
low probability of historic -period archaeological resources in Roth East. The exception to this would
be the potential ruins of the 196Os structure, which would be recorded as an archaeological
resource.
4.11.3 Cultural Resources ReconnaissanceSurvey
The reconnaissance -level field survey consisted of meandering transects spaced approximately
20 meters apart within each quadrant. Archaeological resources were noted and mapped with a GPS
(global positioning system) but were not formally recorded or delineated.
WillametteCRA staff conducted a visual inspection of approximately 100 of the 560 total acres. The
previously recorded resources were not relocated during the reconnaissance. Five new
archaeological resources (three sites and two isolates) were identified. The sites were all small lithic
scatters comprised of flakes, flaked tools, and formed tools, including a possible Plateau
side -notched point. Obsidian was among the raw materials represented. The isolates were both
single historic hole -in -top cans.
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4.11.3.2 Roth East.
WillametteCRA staff conducted a visual inspection of approximately 128 of the 645 total acres.
Twelve archaeological resources (six sites and six isolates) were identified during the
reconnaissance. The majority of resources (n=10) were precontact lithic isolates (one artifact) or
sparse lithic scatters. The precontact sites vary in size and content, with the largest and most diverse
site consisting of 14 artifacts. This artifact assemblage included a projectile point, flakes, and flaked
tools. The projectile point resembled a Plateau side -notched point which dates to ca. 1500 years
before present.
In general, the precontact archaeological resources at Roth East consisted of flakes and formed
tools made from obsidian and fine-grained volcanic material. The historic resources consisted of a
scatter of cans and lumber, and a spoked wheel.
4.11.4 Culturales r es Impacts
A comparison of the relative density of cultural resources between Moon Pit and Roth East indicates
that Roth East has more abundant cultural resources. Both locations are considered to have a
moderate to high probability for precontact archaeological resources and a low probability for
historic -period archaeological resources. No historic built environment resources are anticipated.
Present land use is a relevant factor contributing to the difference in cultural resource densities
between Moon Pit and Roth East. At Moon Pit, half of the proposed landfill footprint is disturbed by
gravel and rock mining, which greatly reduces the potential for cultural resources, particularly intact
archaeological resources. Since Roth East is largely undisturbed, the potential for discovery of intact
cultural resources is greater.
4.11.5 Cultural Resources Mitigation
Based on the available data, Roth East carries the greatest degree of schedule and cost risk. A
formal survey of both Roth East and Moon Pit would better define the potential schedule and cost
implications. Below is the general process for addressing cultural resources which impacts the
schedule and cost.
A systematic pedestrian survey of the entire area proposed for development is recommended. If an
archaeological site or isolate is identified, and the project has the potential to impact it, then the
resource needs to be delineated and formally evaluated under Oregon state law (assuming there is
no federal nexus to the project). With some exceptions, evaluating whether an archaeological
resource is significant requires an Oregon SHPO archaeological permit. To obtain a SHPO permit, a
Secretary of Interior -qualified archaeologist on the Oregon SHPO's approved list must apply. The
application requires a research design, which takes time to prepare. Once submitted, the application
goes through a 30-day review period (realistically closer to 35 days) with SHPO during which time
interested Tribes may comment. SHPO or tribal comments or questions about the application may
delay the process. Once the permit is obtained, field investigations may commence. The duration of
the field investigations depends on the complexity of the resource. Once field investigations and
post -field analysis are completed, the permit holder presents the findings (report and resource
forms) to SHPO for concurrence. SHPO has 30 days to review the findings.
If the resource is determined significant, then impacts to the resource will need to be avoided or
mitigated (e.g., archaeological data recovery, public interpretation, etc.); mitigation is specific to the
individual resource and impact. If the resource is determined not significant, then the resource is not
protected by Oregon law and requires no avoidance or mitigation, and the project may proceed as
planned. If SHPO disagrees with a finding or requests more information to support a finding, the
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SHPO review clock starts over at 30 days. Under state law, Oregon SHPO has the final say as to
whether a resource is significant.
4.12 Community Assessment
The Deschutes County Department of Solid Waste is working with a SWAC to evaluate siting options
for the new solid waste management facility. The SWAC has been meeting regularly since April 2022
to review and discuss information during the multi -step siting evaluation. In June 2023, the SWAC
recommended further study of the Moon Pit and Roth East finalist sites.
4.12.2 CommunityCharacteristics
The County is looking to enter into negotiations with a willing seller and is engaged in direct outreach
with the Moon Pit and Roth East property owners. Both sites are in the same census tract in
Deschutes County (41017000100). The census tract population is approximately 1,962 people and
is not identified as disadvantaged.
■ For the Moon Pit site, there are no known residences within 1 mile of the site and one
residence within 2 miles of the site. There are a variety of active recreational uses in the
vicinity of the site, including the Badlands Rock Trailhead and parking area and general
outdoor use by mountain bikers (outside the Badlands Wildlands Wilderness) and others.
■ For the Roth East site, there are two known residences within 1 mile of the site and eight
within 2 miles of the site location. There are a variety of active recreational uses in the
vicinity of the site, including an off -road vehicle trail system, a Pine Mountain launch area for
paragliders and hang gliders, a shooting range, and general outdoor use by mountain bikers,
hikers, birdwatchers, and others.
Throughout the siting evaluation, the County has been working to share information with interested
parties and the community and collect public input in writing and during public meetings held with
the SWAC. As part of ongoing outreach, the County has contacted area residents, public agencies,
Tribes, recreation and environmental interests, and others. No response has been received from
contacted Tribes (as of May 22, 2024). In addition to individual community members, agencies and
organizations that submitted comments included the Bureau of Land Management, US Fish and
Wildlife Service, East Cascades Audubon Chapter, Oregon Natural Desert Association, Central Oregon
Landwatch, League of Conservation Voters, University of Oregon Department of Physics/Pine
Mountain Observatory, and the United States Hang Gliding and Paragliding Association. These
written comments from agencies and organizations are included in Appendix R.
Based on the comments received, the Moon Pit and Roth East site locations in a comparatively less
developed part of the county have been viewed as a positive by some community members, while
others highlight considerations about operational hauling costs and winter roadway conditions.
Site -specific concerns expressed by local community members generally relate to potential
environmental issues, health risks or other local impacts. For the Moon Pit site, this includes
consideration of the proximity to the Badlands Wilderness, concerns about nearby cultural resources,
and potential disruption of area recreation uses. For the Roth East site, this includes consideration of
potential local impacts to Millican Valley landowners, light pollution and related impacts to the Pine
Mountain Observatory, and potential disruption of area recreation uses such as paragliding.
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Specifically, the potential for high winds at Roth East to spread debris and dust and concerns about
contamination of local groundwater have been noted.
For both sites, there are concerns about potential impacts to habitat and area wildlife resulting
from site development and operation. Of the two sites, development of Roth East is generally
viewed as having more potential visual and residential impacts while development of Moon Pit is
perceived as having minimal new impacts because of its current use as a gravel mine. Because
the Moon Pit site is already disturbed and will continue to support surface mining (regardless of
landfill siting), concerns were raised that development of a new landfill at the Roth East site
would cause a greater disruption to the surrounding area than at the Moon Pit site.
An abbreviated tabular summary of public comments for the two sites is presented below in Table
3. These comments are part of the public record for the siting evaluation work and have been
made available to the project team, SWAC, and Board of County Commissioners.
Table 3. Public Comments Received by County (December 2022-October 2023)
Moon Pit Site Roth East Site
Total Public Comments 224 300
Top Categories Wildlife
(over 100 mentions) 218 sage grouse, 218 eagles and
raptors, 216 deer
Environment
218 noise
Recreation
206 general
Zoning
206 wildlife
Wildlife
274 sage grouse, 227 general,
245 deer, 208 elk, 205 cougar
Environment
267 noise
Zoning
243 wildlife
Recreation
225 general, 131 paragliding
Notes: Some comments identified in this summary referenced the area near the site (e.g., Badlands Wilderness or Millican Valley) not the
specific site. The full record is available through the County's project webpage at deschutescounty.gov/managethefuture.
Once a final site is selected, the site permitting process is expected to include additional outreach
and public process such as notifications and opportunities for comment. This consultation with
federal, state, and local agencies, along with Tribal governments, can help identify strategies to
mitigate potential impacts during site development and operations. Along with informative outreach
for the broader community, providing ongoing opportunities for two-way communication with
adjacent property owners, local community groups, and interested parties is recommended to invite
feedback and help identify concerns and potential solutions. For example, continued briefings and
small group discussions with stakeholder organizations and interested parties, backyard and small
group engagement with neighbors to discuss property -specific considerations, and periodic meetings
with the SWAC are suggested methods of sharing information and inviting input.
The County is committed to a transparent process and is working with a SWAC to evaluate siting
options. SWAC members are appointed and represent incorporated cities, franchise haulers, the
Environmental Center, and the community at -large. The SWAC has been meeting regularly since April
2022 to review and discuss information during the multi -step siting evaluation. The meetings allow
for in -person and online attendance and include public comment periods.
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As part of the siting evaluation process, County staff have received and responded to hundreds of
public comments. These comments are part of the public record for the siting evaluation work and
have been made available to the project team, SWAC, and Board of County Commissioners.
In addition to the SWAC meetings, the County has been sharing information and inviting community
input using a range of outreach tools including updates to the Board of County Commissioners, direct
outreach and mailings to property owners and site neighbors, direct outreach to Tribes, briefings to
community groups and public agencies, news media interviews and press releases, e-news updates,
group mailings to interested parties, and a community open house. The County has also created a
project webpage and a StoryMap dedicated to the siting evaluation process with information about
the project timeline, maps, frequently asked questions, and various resource links. See Appendix P
for more information in the Community Assessment.
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The Parametrix team prepared planning level opinions of probable cost (costs) for both sites. These
opinions have ranges of -30% to +50%, which is an appropriate level of accuracy for comparison of
sites. See Appendix C for Site Owner Solicitation Responses with terms and prices for acquisition.
See Appendix Q for SWMF waste projections and cost estimates for development and operations at
each site.
5.1 Capacity and Projected Life
Moon Pit has an estimated airspace capacity of 64 million cubic yards over 346 acres. The available
airspace on this footprint provides a project lifespan of 100 years.
Roth East has a footprint of 387 acres with an estimated 80 million cubic yards of airspace. The
projected life of the landfill is 125 years based on the preliminary design. The MSW disposal area
footprint on the site has the possibility of expansion horizontally and vertically and could provide over
250+ years of solid waste disposal capacity for Deschutes County residents if needed.
5.2 Population to be Served
As with the existing Knott Landfill, the new Deschutes County landfill would serve the population of
Deschutes County. Portland State University Population Research Center issued the Coordinated
Population Forecast for Deschutes County (2022-2072) in 2022 with estimates of current and
future population. The population estimate for Deschutes County in 2022 is 207,921. The forecast
predicts that the population in Deschutes County will continue to grow over the next 50 years, but
with a declining average annual growth rate (AAGR) that falls from 2.2% in 2022 down to 1.1% 2047.
For the remainder of the forecast period (2047-2072) it is projected that the AAGR will hold steady
at 1.1%. For municipal solid waste projections, it was assumed that this terminal 1.1% AAGR would
continue into the future for the remainder of the 100-year landfill planning period. See Appendix Q
for population projection tables.
5.3 Accepted and Prohibited Wastes
The SWMF will accept MSW from Deschutes County transfer stations. The site will continue following
the current waste screening and acceptance policies that are currently in place at Knott Landfill.
Hazardous waste will not be accepted for disposal at the new landfill site.
5.4 Rate of Waste Disposal
It is estimated that the annual total waste generated in Deschutes County in 2020 was
296,500 tons. Of this total, it is estimated that 98,000 tons of material was recycled which
computes to a recovery rate of 33%. In 2020, the quantity of waste that was landfilled at Knott
Landfill was 198,000 tons. Deschutes County has implemented a recovery rate goal of 45% waste
diversion by 2025. For municipal solid waste projections, it was assumed that the recovery rate
would increase at a rate of 1% per year, up to 45% in 2038, and then remain at 45%. The annual
waste disposed is still estimated to grow even with the increased recovery rate due to population
growth in the county.
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The current annual per capita waste generation in Deschutes County is approximately
3,050 lbs./capita. It is assumed that this per capita waste generation rate will remain steady through
planning period. Waste generation, recovery rates, and waste projections were based on the
Deschutes County Solid Waste Management Plan (2019), 2018-2021 Material Recovery and Waste
Generation Rates Reports, and 2022 Knott Landfill Tonnage Analysis provided by Deschutes County
Solid Waste. See Appendix Q for waste projection tables.
5.5 Mineral Resources
Moon Pit has potential for mineral and surface mining operations on site due to the existing surface
mine. The mining can continue in areas where the landfill is planning future fill and expansion. This
can assist in subsidizing the initial and ongoing operations cost associated with the landfill. Surface
mining can be utilized to subsidize landfill operation costs through re -purposing of mined areas. This
dual utilization optimizes the economic potential of the land, helping offset the expenses associated
with landfill development and operation. By repurposing mined areas for waste disposal, operators
can effectively rehabilitate the land for a new purpose, contributing to sustainable land use
practices. Balancing economic benefits with environmental stewardship is essential to ensure a
sustainable and responsible approach to resource extraction and waste management.
Roth East has enough material on -site for all the current and future landfill needs. This includes
drainage, daily cover, and final cap cover.
5.6 Initial Development Costs
The Parametrix team prepared planning -level opinions of probable cost (costs) for both sites. These
opinions have ranges of -30% to +50%, which is an appropriate level of accuracy for comparison of
sites. See Appendix C for Site Owner Solicitation Responses with terms and prices for acquisition.
See Appendix Q for SWMF Cost Estimates for development and operations at each site.
Initial development costs are estimated at $50 to $64 million, which includes $15.4-15.9 million for
land acquisition. Landfill cell development costs are estimated at $705,000 to $1,075,000 per acre.
Annual operating costs are estimated at $7.6 million per year, which includes $2.5 million/year for
waste hauling. The estimated average cost per ton is $43 to $48 in 2023 dollars, to dispose of 37.6
million tons over a 100-year lifespan. The cost estimate ranges presented here depend on the extent
and cost of cell excavation that could occur as a part of on -site aggregate mining operations.
5.6.2 RothEast Site
Initial development costs are estimated at $36 to $44 million, which includes $5.5-7.0 million for land
acquisition and $1.5-7.6 million for natural resource mitigation. Landfill cell development costs are
estimated at $393,000 per acre. Annual operating costs are estimated at $8.4 million/year, which
includes $3.3 million/year for waste hauling. The estimated average cost per ton is $44 in 2023
dollars, to dispose of 46.3 million tons over a 113-year lifespan. If the disposal capacity is increased
beyond 200 years, the cost per ton could be significantly reduced.
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5.7 Refuse Cell Construction
Moon Pit cell construction costs are estimated at $1.1 million per acre, primarily due to the presence
of rock at the site. Excavation for refuse cells will require rock drilling, blasting and crushing to produce
daily, intermediate, and final cover material, as well as materials for cell development and roads. Table
4 shows the estimated cost for the development of future landfill cells. The construction costs that are
shown are based on the most recent prices paid by Deschutes County at the Knott Landfill.
If the required Rock Drilling, Blasting, and Crushing (2-inch Minus) can be completed by contractors at
a reduced unit cost of $4 per cubic yard in consideration for the aggregate resource, the estimated
cost of cell development reduces to $705,240 per acre. If this rock removal work is not subsidized by
the aggregate resource value and a unit cost of $12 per cubic yard is assumed, the estimated cost of
cell development is $1,074,600 per acre, as shown below in Table 4. Due to fluctuating aggregate and
construction market conditions, the cost of cell development is expected to fall within the range of
$700,000 to $1.1 Million per acre at Moon Pit. The range of costs presented for Moon Pit in this
section and in Appendix Q are predominantly driven by these assumed unit costs for Rock Drilling,
Blasting, and Crushing.
Table 4. Estimate of per acre Cost for Landfill Cell Development at Moon Pit
Estimated
Item Unit Quantity Cost Cost (2023$)
Excavation
CY
38,000
$ 4.00
$ 152,000
Rock Drilling, Blasting, and Crushing (2-inch Minus)
CY
34,200
$ 12.00
$ 410,400
Embankment
CY
6,000
$ 2.00
$ 12,000
6-inch Soil Cushion Layer
CY
900
$ 10.00
$ 9,000
Geosynthetic Clay Liner
SF
48,000
$ 1.00
$ 48,000
Geomembrane
SF
48,000
$ 0.90
$ 43,200
Cushioning Geotextile
SF
12,000
$ 0.85
$ 10,200
Geonet Composite
SF
48,000
$ 0.95
$ 45,600
12-inch Drainage Layer
CY
1,600
$ 10.00
$ 16,000
Separating Geotextile
SF
36,000
$ 0.85
$ 30,600
8-inch Leachate Collection Pipe
LF
300
$ 30,00
$ 9,000
Landfill Gas Collection System
Lump Sum
1
$ 10,000.00
$ 10,000
Subtotal
$ 796,000
Engineering and Administration (15%)
$ 119,400
Contingencies (20%)
$ 159,200
Estimated per acre Cell Development Cost
$ 1,074,600
Assumptions:
1. Approximately 90% of the excavation volume will require rock drilling, blasting and crushing.
2. Rock drilling, blasting, and crushing cost assumes no contractor mining, just processing for County uses
CY = cubic yards; SF = square feet
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The MSW disposal area at Roth East is located in an area that can be excavated by the County as
part of their Daily, Intermediate and Final Cover Borrow operations. Because of this, the estimated
cost for the development of future landfill cells at the Roth East site is considerably less than Moon
Pit. Table 5 shows the estimated cost for the development of future landfill cells at Roth East. The
estimated cell construction cost is $394,000 per acre which is about one-third of the cost for cell
development at Moon Pit.
Table 5. Estimate of per acre Cost for Landfill Cell Development at Roth East
Item
Unit
Quantity
Unit Cost
Estimated
Cost (2023 $)
Rough Excavation'
CY
-
$ 4.00
$ 0
Finish Excavation2
CY
15,000
$ 4.00
$ 60,000
Embankment
CY
5,000
$ 2.00
$ 10,000
6-inch Soil Cushion Layer
CY
900
$ 10.00
$ 9,000
Geosynthetic Clay Liner
SF
48,000
$ 1.00
$ 48,000
Geomembrane
SF
48,000
$ 0.90
$ 43,200
Cushioning Geotextile
SF
12,000
$ 0.85
$ 10,200
Geonet Composite
SF
48,000
$ 0.95
$ 45,600
12-inch Drainage Layer
CY
1,600
$ 10.00
$ 16,000
Separating Geotextile
SF
36,000
$ 0.85
$ 30,600
8-inch Leachate Collection Pipe
LF
300
$ 30.00
$ 9,000
Landfill Gas Collection System
Lump Sum
1
$ 10,000.00
$ 10,000
Subtotal
$ 291,600
Engineering and Administration (15%)
$ 43,740
Contingencies (20%)
$ 58,320
Estimated per acre Cell Development Cost
$ 393,660
Assumption:
1. Two thirds of cell excavation would occur as a part of daily cover borrow operations by Deschutes County Solid
Waste staff.
2. One-third of total excavation if fine grading to cell subgrade design elevations.
CY = cubic yards; SF = square feet
5.8 Description of Operation
The landfill will not be open to the public and will therefore have minimal landfill staff when
compared to a landfill that has a high volume of commercial haulers and the public. The daily
operation of the landfill involves a systematic process to manage waste disposal efficiently. Scale
house operators will weigh, screen, and direct inbound waste materials to their proper locations. It is
anticipated that disposal, waste compaction, daily cover and other fill operations will be similar to
what is currently happening at Knott Landfill.
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Table 6 shows the estimated total annual operating costs for hauling waste to Moon Pit and Roth
East from the County's transfer stations and disposing of it in the landfill.
Table 6. Comparison of Estimated Annual Operating Costs
Moon Pit
Roth East
Administrative Labor Subtotal
$
1,288,000
$
1,288,000
Equipment Owning and Operating
Subtotal
$
1,614,000
$
1,614,000
Environmental Monitoring Subtotal
$
868,000
$
902,000
Haul Cost Subtotal
$
2,536,000
$
3,280,000
Miscellaneous Subtotal
$
1,269,000
$
1,332,000
Total Annual Operating Costs
$
7,576,000
$
8,417,000
Daily cover and intermediate cover operations are critical aspects of landfill management. Daily
cover involves the application of a protective layer of soil or alternative materials over the exposed
waste at the end of each operational day. This cover helps control odors, prevents the attraction of
pests, and reduces windblown debris. It also contributes to overall site aesthetics. Intermediate
cover, on the other hand, is applied periodically during active landfill operations to control erosion,
manage surface water runoff, and create a barrier between waste and the environment. Both daily
and intermediate covers play key roles in minimizing environmental impacts and maintaining
regulatory compliance within the landfill operation. The cover cost for Moon Pit and Roth East has a
negligible difference, both sites will operate under the same cover assumptions with similar cost. The
additional costs of obtaining cover materials at Moon Pit are captured in the cell development capital
costs noted above.
5.10 Landfill Closure
It is anticipated that Moon Pit and Roth East will have similar closure costs. The total estimated cost
for each site includes final contouring and grading, landfill gas collection systems, geotextile cushion,
geosynthetic clay liner (GCL), geomembrane, geonet composite layer, 24-inch topsoil/soil protective
layer, seed, fertilizer and mulch, cover system irrigation, and monitoring and maintenance. The final
cost for closure at both site locations is estimated to be $378,000 per acre. Again, the additional
costs of obtaining cover materials at Moon Pit are captured in the cell development capital costs
noted above.
5.11 DEQ Permitting
Both landfill sites will require a Solid Waste Disposal Site Permit from DEQ. The DEQ permit for
landfill operations is to ensure that the landfill operates in compliance with environmental laws and
regulations. This permit outlines specific conditions and requirements that the landfill must adhere
to, including waste acceptance criteria, operational practices, monitoring procedures, and closure
plans. DEQ permits are designed to mitigate potential environmental hazards associated with
landfills, such as soil and water contamination, air pollution, and wildlife disruption. The permit
process involves a comprehensive review of the landfill's design, construction, and operational plans,
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with a focus on minimizing the impact on surrounding ecosystems and communities. Moon Pit and
Roth East both have an estimated initial permitting cost of $1.5 million.
5.12 Summary of Cost Analysis
Each site has a unique set of design challenges that contribute to their overall cost over the life of
the landfill. Initial development, land acquisition, operations, and final cover all play a part in the
total cost to design, operate, and close a landfill. The SWMF will accept MSW from Deschutes County
transfer stations, any increased cost to the public is reflected in the tipping fees in table 6.
For the Moon Pit site, upfront costs are expected to be higher, but annual operational costs are
expected to be lower. Initial development costs are estimated at $50 to $64 million, which includes
$15.9 million for land acquisition. Landfill cell development costs are estimated at $705,000 to
$1,075,000 per acre. Annual operating costs are estimated at $7.6 million per year, which includes
$2.5 million per year for hauling waste. The estimated average cost per ton is $43 to $48, to dispose
of roughly 38 million tons over a 100-year lifespan.
The cost estimate ranges presented for Moon Pit depend on the extent and cost of cell excavation
that could occur as a part of aggregate mining operations on -site. If permitting and aggregate market
conditions are favorable, there is greater upside potential for the Moon Pit site with the opportunity
for aggregate mining to subsidize landfill excavation costs. Initial capital costs are significantly higher
at Moon Pit, which would necessitate higher tip fees for the first 30 years.
For the Roth East site, upfront costs are expected to be lower, but annual operational costs are
expected to be higher due to the extended haul distance. Initial development costs are estimated at
$36-44 million, which includes $5.5-7.0 million for land acquisition. Landfill cell development costs
are estimated at $393,000 per acre. Annual operating costs are estimated at $8.4 million per year,
which includes $3.3 million per year for waste hauling. The estimated average cost per ton is $44, to
dispose of roughly 46 million tons over a 113-year lifespan. While the Roth East site is offered at a
lower acquisition price and will have lower cell excavation costs, the additional operational costs for
further waste hauling are projected to drive total cumulative costs beyond that of Moon Pit around
year 83 of operations (circa 2112).
For both sites, it is assumed that upfront acquisition and development costs would be financed with
a 30-year bond at a 4.75% interest rate. The total cost of debt service, landfill operations, and cell
expansion have been analyzed for the first 30-years to estimate the cost per ton and related tipping
fees required to cover these costs during this time period (2030-2059). For Moon Pit, the estimated
30-yr cost per ton is $59-$68 and the tipping fee is $106-$115 per ton. For Roth East, the estimated
30-yr cost per ton is $53-$55 and the tipping fee is $100-102 per ton.
To further understand these costs in terms of impacts to County residents, increases to household
garbage collection bills and self -haul disposal costs were estimated. Household garbage collection
bills are estimated to increase from the assumed current rate of $25 per month to around $29 per
month with Moon Pit and $28 per month with Roth East. Self -haul household waste and construction
debris disposal costs are estimated to increase from the current rate of $14 (for up to 4001b load
covered & secured) to $21-$23 with Moon Pit and around $20 with Moon Pit. Table 7 below
compares the estimated costs and disposal fees associated with each site.
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Table 7. Landfill Site Cost Comparison
Item Moon Pit Roth East
Operating Period
2029-2129
2029-2142
Estimated Lifespan (years)
100
113
Land Acquisition Costs
$15,870,000
$5,500,000 to $6,898,000
Initial Development Costs
$35,266,900 to $49,036,900
$30,580,740 to $37,215,609
Total Initial Costs (Land + Development)
$51,136,900 to $64,906,900
$36,080,740 to $44,113,609
Landfill Cell Development Costs
$193,125,000 to $347,094,000
$142,905,000
Closure Costs
$131,404,000
$146,548,000
Operating Costs
$1,259,744,358
$1,720,346,129
Post -Closure Operations Costs
$9,068,316
$9,068,316
Total Lifespan Costs
$1,643,978,574 to $1,812,217,574
$2,054,948,185 to $2,062,981,054
Total Waste Disposal Projection (tons)
37,686,654
46,319,902
Avg. Cost per Ton over Lifespan
$43 to $48
$44
Upfront Capital Costs Financed'
$79,551,043 to $101,969,346
$68,419,316 to $83,651,914
30-yr Operational Costs (2030-2059)
$96,021,924 to $123,081,891
$328,800,270
30-yr Total Costs (2030-2059)
$344,700,390 to $386,439,390
$397,219,586 to $412,452,184
30-yr Waste Disposal Projection (tons)
7,462,195
7,462,195
30-yr Cost per Ton
$59 to $68
$53 to $55
30-yr Tipping Fee
$106 to $115
$100 to $102
Est. Monthly Residential Collection Bi112
$28.05 to $28.83
$27.56 to $27.73
Monthly Res. Collection Bill $ Increase2
$3.05 to $3.83
$2.56 to $2.73
Monthly Res. Collection Bill % Increase2
12% to 15%
10% to 11%
Est. Self -Haul Disposal Costa
$21.18 to $23.02
$20.01 to $20.42
Self -Haul Disposal Cost $ Increase 3
$7.18 to $9.02
$6.01 to $6.42
Self -Haul Disposal Cost % Increase 3
51% to 64%
43% to 46%
1. Acquisition and development costs financed with 30-yr bond at a 4.75% annual interest rate.
2. Increase of $0.85 for every $10 increase above current $70/ton tipping fee. Residential collection bill assumed at $25/month.
3. Based on current cost of $14 for up to 0-400 Ibs of household/construction waste disposal with load covered & secured.
May 2024 1 553-2509-011 5-7
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for double -sided printing
Deschutes County Solid Waste Management Facility (SWMF)
Final Site Evaluation
Deschutes County Solid Waste Department
The selection of a new site for the Deschutes County SWMF is a complex decision that requires
careful consideration of various factors. The two candidate sites, Moon Pit and Roth East, each
present unique advantages and challenges.
Moon Pit offers the advantage of existing infrastructure, including an access road, gate, scales, and
well, which could reduce site development costs. The site's current use as a gravel mine provides
some "free" airspace and reduces initial excavation needs. However, the site's layout is more
complex and less efficient than Roth East, resulting in a lower capacity -to -acreage ratio and the need
for more leachate pump stations. The presence of shallow bedrock increases excavation costs,
although this could be offset by potential aggregate mining operations. Risks may emerge from the
land use approval process and a potentially extended National Environmental Policy Act process for
the access road. The Moon Pit site has upside potential and downside risk related to aggregate
mining for cell excavation, depending on marketability of on -site rock. Initial capital costs are
significantly higher at Moon Pit, which would necessitate higher tip fees for the first 20 years.
However, the existing and useful transportation network that provides direct access from US 20 is a
significant advantage. The Moon Pit site is generally viewed as having fewer visual and residential
impacts, and because the site is currently used as a gravel mine, there is a perception that use as a
landfill would pose minimal new impacts.
Roth East, on the other hand, has a more efficient square shape, resulting in a better capacity -to -
acreage ratio and fewer leachate sumps/pumps. The mix of sand, gravel, and cobbles within the
excavation depth on -site is very favorable for efficient landfill development and operation. However,
there is no existing infrastructure on -site and no existing improved access road between the site and
US 20 support landfill operations. Potential risks may arise from the Farm Impacts Test which could
lead to a Land Use Board of Appeals appeal which can be a lengthy process. While the Roth East site
is offered at a lower acquisition price and would have lower cell excavation costs, the additional
operational costs for further waste hauling are projected to drive total cumulative costs beyond that
of Moon Pit around year 83 of operations (circa 2112). Of the two sites, development of Roth East is
generally viewed as having more visual and residential impacts, Appendix P.
Given these considerations, both sites appear to be viable options for the new County SWMF. The
Moon Pit site is appealing due to its existing infrastructure, lower haul costs, and lower degree of
impacts to residences and wildlife. The Roth East site is appealing with its efficient layout, favorable
excavation conditions, and potential for a longer lifespan. This decision is a significant step toward
ensuring the long-term sustainability of waste management in Deschutes County. The selection of
either site will ultimately depend on the specific priorities and needs of the County.
This process for selection of the preferred SWMF site involved thorough review, discussion, and
consideration of study findings, leading to a formal recommendation to the Board of County
Commissioners. The process for reviewing information and selecting the preferred Deschutes County
SWMF site involves several key milestones in 2024:
■ February 20 SWAC Meeting: Review executive summary, site comparison table, and study
findings with the SWAC, providing the SWAC opportunity to submit written comments.
■ March 8: Distribute draft report for SWAC members, commissioners, and other relevant
parties for detailed review and consideration, prior to March SWAC meeting.
® March 19 SWAC Meeting: Review and discuss draft report with the SWAC.
May 2024 1553-2509-011 6.1
Deschutes County Solid Waste t lanagemart Facility (SWMF)
Final Site Evaluation
Deschutes County Solid Waste Departmk�:it
■ April 5: Submit final report to Deschutes County Solid Waste for distribution to SWAC
members, commissioners, and other relevant parties for detailed review and consideration.
■ April 16 SWAC Meeting: SWAC members provide a formal recommendation to the Board of
County Commissioners regarding their preferred site for the new County SWMF.
■ June 12: First Board of County Commissioners Public Hearing.
■ July (date TBD): Second Board of County Commissioners Public Hearing and Board selection
of preferred County SWMF site.
On April 16, 2024, the Solid Waste Advisory Committee unanimously recommended the Moon Pit
site for Board of County Commissioners consideration as the location for the new Solid Waste
Management Facility. Key reasons for this recommendation included:
■ The site is currently being used as an aggregate surface mine and is already disturbed
■ Based on the current use, there is less likelihood of new impacts to area wildlife or recreation
■ The site is comparatively closer to existing facilities which will help manage haul costs and
greenhouse gas emissions
The Committee also recommended that the Board of County Commissioners:
■ Work with stakeholders to develop and implement a robust and comprehensive mitigation
strategy that reflects community values to minimize impacts to area wildlife and recreation
■ Prioritize waste prevention and recovery and move as quickly as possible to implement those
strategies to reduce the overall costs and greenhouse gas emissions of the new landfill
6-2 May 2024 1 553-2509-011
underground
July 3, 2024
Board of County Commissioners
Deschutes County
1300 NW Wall Street
Bend, OR 97703
Subject: Moon Pit Land Acquisition and Resource Development
Re: On -Site Material Characteristics
Dear Deschutes County Commissioners:
503.227.1800
2843 NW Lolo Drive
Bend, OR
97703
Delve Underground completed a Preliminary Geotechnical Feasibility Report (Appendix K) as part of the
Phase 2 Final Solid Waste Management Facility (SWMF) Site Evaluations and presented the results in a
report dated February 2024.'This technical letter was developed to provide the Deschutes County
Commissioners with additional specifics regarding the subsurface materials at the Moon Pit and their
commercial viability. To this end, we discuss the general types of materials (soil and rock) that are
present, how they could be used commercially, and as on -site purposes associated with the landfill.
Additional specifics are also provided regarding the commercial value as well as potential future use of
various products that could be quarried on site.
Previous Report Summary
The following provides a summary of conditions at the existing site based on our findings and review of
reports prepared by Mark V. Herbert & Associates (MHA) dated April 8, 1993, and Siemens and
Associates (SA) dated August 6, 1996.2, 3 Both reports are included as Appendix E in our report and were
part of a previous phase of evaluating landfill locations in the 1990s.
The MHA assessment was limited to the excavation of test pits (32 total) but no soil borings,
limiting the ability to characterize the underlying bedrock. Based on the results of this
investigation, potential marketable products were determined to be topsoil, drain rock, pea
gravel, coarse concrete aggregate, concrete sand, asphalt aggregate, and select structural
backfill.
• MHA estimated 630,00 CY of topsoil, 725,000 CY of sand and gravel, 807,000 CY of silty gravel
with sand, and 240,000 CY crushable rock. Note that the northwest area considered was
1 Delve Underground. 2024. Phase 2 Final SWMF Site Evaluation — Moon Pit: Preliminary Geotechnical Feasibility
Report. Prepared for Deschutes County, Delve Underground project no. 6491.0, report dated February 2024.
z Mark V. Herbert & Associates (MHA). 1993. Moon Ranch Gravel Pit Evaluation, Deschutes County, Oregon.
Prepared for Matt Day, report dated April 8, 1993.
3 Siemens & Associates. 1996. Deschutes County Final Landfill Site Evaluation — Site "L", Horse Ridge, Oregon —
Results of Onsite Soil and Rock Investigation. Prepared for David Evans and Associates Inc., project no. 996021,
report dated August 6, 1996.
delveunderground.com
Moon Pit Land Acquisition and Resource Development
On -site Material Characteristics
July 2, 2024
Page 2 of 4
approximately 281 acres at the time of the 1993 investigation, and the entirety of the property
is now being considered, which totals approximately 440 acres.
• The Moon Pit was originally operated as a sand and gravel quarry. As these materials were
depleted, operations transitioned to a rock quarry where bedrock is first blasted and then
processed by crushing to produce salable materials. Some of the sand and gravel material is still
present on site, particularly to the northwest.
• In 1996, SA advanced 22 auger borings to characterize the site as a potential landfill. These
borings were not advanced significantly into the bedrock. The results were used to further
define the extent of the sands and gravels and evaluate the site's viability as a landfill.
• Review of seismic surveys and cross sections compiled by SA indicated an irregular bedrock
contact with varying depths of sediment accumulation within the northwest portion of the site
at the time of exploration.
• Presently, shallow bedrock is persistent throughout the site and covered with a thin (less than
10-foot thick) veneer of undifferentiated alluvium and loess (wind deposited silt and fine sand).
Thicker amounts of alluvium may be present where it has not been mined out in the
northwestern portion of the site.
• Bedrock exposed in the quarry exposures in the site's southern portion consisted of a complex
sequence of basaltic lava flows and cinder -filled interbeds. Both lava flow and interbeds
generally varied between 2 and 10 feet thick.
• Bedrock exposed in the northwestern portion of the site by mining was highly weathered and
not of commercial grade. Following the discovery of low -quality material beneath the sand and
gravel, operations shifted to the southern portion of the site. The extent of these materials is
unknown. This material is likely still usable for daily cover at the landfill.
• On -site materials will require laboratory testing to assess whether materials meet the
specification of intended use per Oregon Standard Specifications for Construction (OSSC).
Table 1 summarizes materials present on site and anticipated uses of these materials included within
our 2024 report.
Moon Pit Land Acquisition and Resource Development
On -site Material Characteristics
July 2, 2024
Page 3 of 4
Table 1. Summary of Onsite Materials and Potential Uses
Silty SAND (SM)
Alluvium Loessz Well -graded GRAVEL with sand and
/ cobbles (GW) 1— 5.5 Daily cover
Well -graded SAND with silt (SW-SM)
Colluvium3 Well -graded GRAVEL (GW) >6 Daily cover
Bedrock
(extremely
weathered )4
Well -graded GRAVEL with silt and
SAND (GW-GM)
1-4
Daily cover for gravel -sized
or finer; crush/screen
oversize rock clasts for drain
rock, structural fill, and road
Well -graded GRAVEL with sand (GW)
Silty SAND with gravel and cobbles
(SW)
base
Bedrocks
(unweathered)
N/A
Unknown
Crush for drain rock,
structural fill, and road base
1 Anticipated uses are assumed. No laboratory testing has been performed and bedrock quality is currently unknown.
Laboratory testing is required for approval of on -site use.
z Alluvium and loess accumulation throughout the undisturbed areas of the site and overlies bedrock, and old alluvial gravels
previously mined in the northwest portion of the site. These old alluvial gravels may be locally thicker in this area.
3 C011uvium limited to areas adjacent to fault scarp and only encountered in TP-3 and TP-4.
4 Bedrock encountered within test pits represents the upper weathering profile and contains varying amounts of sand and
fines. Bedrock quality is currently unknown and requires evaluation and laboratory testing to determine durability and
quality.
s Bedrock quality determination is beyond the scope of this exploration although visual observations of cuts and other
exposures suggest high variability ranging from poor to moderate.
Discussion
The following are additional considerations with respect to the viability of existing on -site materials for
commercial and on -site use:
Commerciallv viable materials have been mined at this site for decades. Current mining
operations are in the southeast portion of the property. However, no lab results or quantities
have been provided to date to indicate the quality of materials mined. Materials produced are
likely used for road base, chip and seal, structural fill, and asphalt concrete aggregate. These
materials could also be potentially used for on -site development and operational purposes.
• The area associated with Phase 1 of the landfill development (northwest portion) has the
highest uncertainty with respect to material quality and quantity. Bedrock mining was
attempted in one location but discontinued due to low -quality rock. Additional site
characterization will provide additional clarity on ground conditions While some material may
Moon Pit Land Acquisition and Resource Development
On -site Material Characteristics
July 2, 2024
Page 4 of 4
not be commercially viable, it is anticipated it could be used for on -site purposes, primarily daily
cover.
An additional consideration for Deschutes County is the operation of this quarry as a "resource"
to contractors bidding on County projects. The quarry could be made available to prospective
contractors to mine and process crushed rock for these types of projects. This may increase the
competition between contractors as those without proximal quarries would be able to process
materials themselves versus purchase products from potential competitors. The Oregon
Department of Transportation maintains numerous quarries across the state for this purpose.
The current location of the Moon Pit limits its commercial value due to longer haul costs.
Projects where these products will be particularly competitive include roadway work on US 20
between Bend and Burns as well as county and city projects in southeast Bend. Future
expansion in the area is anticipated to be focused to the east of Bend, including the SE Area Plan
Development and Stevens Tract Property Development. This may increase the marketability of
materials produced at Moon Pit. Other potential projects that will need large quantities of
import include canal piping projects and the City of Bend Go Bond transportation projects such
as the Reed Market railroad overpass fill.
• While specifics regarding the market value of the quarry are limited due to the lack of specifics
regarding rock quality, the appraised value will be based on documentation of materials
produced and quality control data provided by the seller.
Additional Site Characterization
Additional site characterization would be required to understand the subsurface conditions, lateral
extent of deposits, and recover materials for laboratory testing. A future exploration program should be
performed after negotiations of land acquisition have begun. We recommend exploration of the Phase 1
area be prioritized due to the higher level of uncertainty of material quantities and properties in this
location.
Sincerely,
L 6/OA
Shaun Cordes, RG, CEG
Associate Engineering Geologist
cc: File
Encl.
JaAI--<,J
4-e_"
James Schick, RG, CEG
Principal Engineering Geologist
Parametrik
let's create tomorrow, together
DATE:
July 3, 2024
TO:
Deschutes County Board of Commissioners
FROM:
Deschutes County Solid Waste Department
SUBJECT:
Pa ra metrix
PROJECT NUMBER: Availability of Water at the Moon Pit Site
PROJECT NAME: Deschutes County SWMF Final Site Evaluations
Memorandum
This memo provides a focused overview of the water sources and water rights at the Moon Pit site, in
response to questions raised at the first public hearing on June 12, 2024. Additional and more
detailed information is available in Appendix G - Water Assessment, as part of the Deschutes SWMF
Final Site Evaluation Report.
The Moon Pit site has two water supply wells, Well A (DESC 5750) and Well B (DESC 9126). Well A is
currently not in use and is designated for domestic use per the well log, which is limited to 5,000
gallons per day. Well B is an industrial well used primarily for onsite dust suppression and capable of
producing 1,000 gpm, according to Hooker Creek.
Jill �illill� • . 1i : •
There is no water right associated with Well A. As such, its use would be limited to the exempt use
maximum of 5,000 gallons per day (gpd).
Water right permit G-12860 associated with Well B has a maximum use rate significantly greater
than the anticipated future landfill operation water requirements. It is estimated that the landfill
would require water rights authorizing a peak diversion rate of 50 gpm (0.11 cfs) to meet peak water
demands in the summer. This is roughly 10% of the total peak diversion rate of 1.09 cfs under
Hooker Creek water right G-12860. The maximum use rate of 1.09 cfs under Permit G-12860 is
further broken down into 0.27 cfs (174,505 gpd) for dust control and 0.82 cfs (529,978 gpd) for
gravel washing.
The dust control usage rate alone (0.27 cfs or 174,240 gpd) exceeds the anticipated needs.
However, this water right permit was not offered with the property in the solicitation response letter.
Following site selection, further discussion with Hooker Creek is recommended to coordinate transfer
of a portion of water right permit G-12860 to the County for the landfill water needs. If a partial water
right transfer from Hooker Creek cannot be secured, the County will need to explore other options
such as applying for a new groundwater permit and/or acquisition of certificated water rights with
the necessary rate and annual duty that can be transferred to the Moon Pit site for landfill
operations.
An interim water lease agreement has been discussed with Hooker Creek, in which a water cost of
$10 per 1,000 gallons (1 cent per gallon) was suggested. Hooker Creek stated that water could be
sold to the County per this interim water lease agreement until the County is able to secure its own
water rights that authorize withdrawal from the onsite wells. The annual operations budget (see
150 NW Pacific Park Lane, Suite 110 ® Bend, OR 97701 1 541.508.7710 1 Parametrix.com
Parametrik
July 3, 2024
Page 2
Appendix Q) includes a $52,000 estimated annual cost for Hooker Creek water charges at this unit
cost of $0.01 per gallon.
The fire flow need for the proposed structures is understood to be 60,000 (1,000 gpm for a 60-
minute duration. A fire hydrant is anticipated near the proposed buildings. A water storage volume of
200,000 gallons has been planned for and accounted for in the cost estimate. Fires that occur
within the landfill footprint are typically addressed by operations staff with soil cover and water
trucks if necessary, each holding approximately 4,000 gallons with a pump rate of 550 gpm. Fires
are typically more intense with yard debris and construction & demolition (C&D) debris operations -
neither of which are planned at the Moon Pit site.
Attachments:
• Well Map
® Well Photos
el
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let's create tomorrow, together
DATE: July 03, 2024
TO: Deschutes County Commissioners
FROM: Deschutes County Solid Waste Department
PREPARED BY: Parametrix
SUBJECT: Moon Pit Wildlife Mitigation Approach
PROJECT NAME: Moon Pit Site Evaluation
Technical Memorandum
This memorandum provides the approach for mitigation and associated cost for impacts to golden
eagle (Aquila chrysaetos), mule deer (Odocoileus hemionus), elk (Cervus canadensis), pronghorn
(Antilocapra americana), and greater sage -grouse (Centrocercus urophasianus, sage -grouse), as a
result of the development of the Solid Waste Management Facility (SWMF) at the Moon Pit Site.
Mitigation approaches are broken down to what is required for permitting as defined by statute and
what is additionally recommended to ensure a robust mitigation approach.
Golden Eagle
Requirements for mitigation for impacts to golden eagle habitat, as protected by the Bald and
Golden Eagle Protection Act, were based upon Title 50 Code of Federal Regulations 22.80. The Site
is within two miles of a golden eagle nest and its development will result in a permanent alteration of
habitat. The USFWS recommended the submission of an Eagle Incidental Take Permit. The permit
would be used for consultation and will be used to determine a take statement and associated
required mitigation. Further coordination with USFWS would be required to determine the degree of
mitigation required and its cost. Thus, costs for mitigation to impacts to golden eagle habitat as a
result of the development of the SWMF were not included in cost estimates provided below. The
overall cost for this mitigation is anticipated to be minor relative to the mitigation costs for big game
and sage -grouse habitat.
Big Game
Statutory mitigation requirements for impacts to big game habitat (elk, mule deer, and pronghorn)
was based upon Oregon Administrative Record (OAR) 635-415-0025 for impacts to Category 2
Habitat. Moon Pit consists of 167.1 acres of juniper woodland and 10.9 acres of shrub steppe that
are winter range habitat for elk and mule deer and is also essential and limited pronghorn habitat.
These habitats are considered Category 2 Habitats and impacts to these areas must be either
avoided or mitigated for. Mitigation of impacts, if unavoidable, must be in -kind, in -proximity, and
result in a net benefit of habitat quantity or quality. Parametrix reviewed properties available that
contained acreages of similar suitable Category 2 habitats in excess of what is present at the Site
and could be enhanced by practices including livestock grazing restrictions, weed treatment, native
revegetation/restoration, fire readiness, and fence removal/fence upgrades. Parametrix used the
acquisition cost of these properties and estimated the ongoing maintenance and operations of
enhancement practices to be used for cost estimates (see Table 1 below).
150 NW Pacific Park Lane, Suite 110 • Bend, OR 97701 1 541.508.7710 1 Parametrix.com
Parametrik
Sage -grouse
Technical Memorandum
Statutory mitigation requirements for impacts to sage -grouse was based upon OAR 635-140-0025
for impacts to sage -grouse habitat. Moon Pit is not within sage -grouse habitat, but the SWMF may
have indirect impacts on adjacent low -density sage -grouse habitat. Indirect impacts can include
sound disturbance from Site operations and an increased threat of predation from increased
densities of ravens (Corvus corax). Landfills can result in elevated densities of ravens due primarily
to additional food sources and in some cases roosting locations (Peebles and Conover 2017).
Ravens predate on sage -grouse and a higher abundance of the species within sage -grouse habitat
has been linked with lower sage -grouse reproductive success (Bui et al. 2010, Dinkins et al. 2010,
Coates et al. 2020). The degree of raven impact on sage -grouse has been linked with raven density
on the landscape (Coates et al. 2020). Although ravens have been recorded to disperse as far on
average as 40 kilometers (km) from a landfill (Peebles and Conover 2017), the density of ravens is
more constrained. Studies have shown that landfills and development increase raven density within
3 to 15 kms (Boarman et al. 1995, Bui et al. 2010, Coates et al. 2020, and Dinkins et al. 2021).
Parametrix applied the mitigation hierarchy of avoidance, minimization, and compensatory mitigation
(OAR 635-140-025) to determine the requirements for permitting the development of the SWMF at
Moon Pit and its cost for mitigating impacts to sage -grouse habitat.
The site selection process for the new SWMF initially identified over 100 potential sites of which 31
sites were selected for further study in Broad Site Screening, which included an assessment of
avoidance of sage -grouse habitat impacts to the extent practicable in regard to environmental and
financial feasibility. Fifteen of the sites that were considered in Broad Site Screening are within sage -
grouse habitat (including Roth East) and were not chosen in part to avoid direct impacts to low -
density and core sage -grouse habitat. Other sites distant from sage -grouse habitat were not pursued
due to factors such as proximity to airports, proximity to groundwater resources, risk of liquefaction,
geologic faults, preexisting grazing leases, lack of access to transportation corridors, functional site
acreage, willingness of owner to sell property, and site ownership among other factors. During the
final selection, Moon Pit was selected over Roth East in large part due to differences in sage grouse
habitat. Roth East is entirely within low density habitat, is adjacent to core habitat, and is along a
migration corridor for sage -grouse.
The development of the SWMF at Moon Pit will minimize the indirect impact of raven attraction by
limiting the availability of roosting structures present within the area, removing unoccupied nests
within the site, and by the placement of dirt over landfill materials to deter landfill scavenging by
ravens.
Parametrix determined the cost of compensatory mitigation by determining the degree of indirect
impact by coordination with Oregon Department of Wildlife (ODFW) which ran a preliminary Habitat
Quantification Tool (HQT) on the development of the SWMF at Moon Pit. The HQT is a science -based
method for the quantification of impacts to habitat function for sage -grouse as a result of
development or mitigation actions. The HQT is based on a well -established academically supported
framework and was prepared by the Willamette Partnership and the SageCon Quantification
Technical Team (State of Oregon 2019). For indirect impacts, the HQT does consider food and nest
subsidies for ravens within landfills and provides a 3.3 km buffer of impact in order to determine
functional habitat lost.
The preliminary HQT for Moon Pit determined that 7.8 functional acres of sage -grouse habitat would
be lost as a result of SWMF development. ODFW requires mitigation to achieve a net conservation
benefit (OAR 635-140-0025[3]) which is quantified as 15% above functional acre impact. In total,
the project would result in the required mitigation of 9 functional acres of sage -grouse habitat.
Acquisition, maintenance, and operations costs were estimated based upon obtaining 9 functional
Deschutes County Solid Waste Department 5532509011
Moon Pit Mitigation Memo 2 July 03, 2024
Parametrix
Technical Memorandum
acres of uplift. Common mitigation measures that could result in uplift of sage -grouse habitat include
juniper removal, cattle grazing management, reseeding of native forbs and grasses, fence removal,
and invasive species removal.
Statutory Mitigation Cost
The table below provides the estimated cost of acquiring properties, enhancing them, and
maintaining them for the duration of the project to support sage -grouse and big game habitat
mitigation.
Table 1. Estimated Cost for Statutory Wildlife Mitigation for Moon Pit
Initial Cost Operations and Maintenance
$700,000 $800,000
Various stakeholder groups have called for robust mitigation measures to go above and beyond
minimum requirements set forth by ODFW, in particular toward sage -grouse habitat. The HQT for
landfills uses a 3.3 km buffer to account for increased predation by ravens as a result of increased
densities of the species around the landfill. Although 3.3 km is within the range reported in scientific
literature (3 to 15 kms; Boarman et al. 1995, Bui et al. 2010, Coates et al. 2020, and Dinkins et al.
2021), it is on the lower end of measured distances of effect and thus the HQT may not fully account
for the realized impact the SWMF may have on nearby sage -grouse habitat.
With the uncertainty in the exact impact the SWMF may have on sage -grouse habitat through the
duration of the project, a long-term adaptive mitigation approach informed and assisted by local
stakeholders and experts should be used to ensure robust mitigation. Deschutes County Solid Waste
Department (DCSWD) proposes to establish a Host Environmental Community Agreement wherein a
portion of fees per ton of waste deposited at the SWMF is directed toward conservation and
recreational projects as directed by a committee. Host Community Agreements are common
agreements between communities and landfills to account for negative impacts such as noise, odor,
and depressed property values as a result of the development of the landfill (Jenkins et al. 2004).
This concept can be readily translated to fund conservation and recreational projects at the direction
of a committee composed of stakeholders and county officials. Establishment of the committee
would be through a facilitative process that brings in stakeholders and county officials who negotiate
on the structure of the committee. The aim of the committee would be to use funds generated by the
Host Environmental Community Agreement to fund conservation and recreational projects ranging
from property acquisition, conservation agreements, land management activities, trail and trailhead
maintenance, and other projects.
The mitigation approach described in this memorandum outlines requirements necessary for
permitting the project at the state and federal level according to statute. This approach also goes
above and beyond statutory mitigation requirements by providing a funding source to ensure that
species, habitats, and recreation that may be impacted by the development of the SWMF are
robustly mitigated for. The establishment of the Host Environmental Community Agreement and
associated committee will bring together stakeholders and leverages their expertise and knowledge
Deschutes County Solid Waste Department 5532509011
Moon Pit Mitigation Memo 3 July 03, 2024
Parametrik
Technical Memorandum
in order to conduct conservation and recreation activities to ensure long-term robust mitigation for
impacts of the SWMF.
Boarman, W.I., Camp, R.J., Hagan, M. and Deal, W., 1995. Raven abundance at anthropogenic
resources in the western Mojave Desert, California. Report to Edwards Air Force Base, California.
Bui, T.V.D., Marzluff, J.M. and Bedrosian, B., 2010. Common raven activity in relation to land use in
western Wyoming: implications for greater sage -grouse reproductive success. The Condor, 112(1),
pp.65-78.
Coates, P.S., O'Neil, S.T., Brussee, B.E., Ricca, M.A., Jackson, P.J., Dinkins, J.B., Howe, K.B., Moser,
A.M., Foster, L.J. and Delehanty, D.J., 2020. Broad -scale impacts of an invasive native predator on a
sensitive native prey species within the shifting avian community of the North American Great Basin.
Biological Conservation, 243, p.108409.
Dinkins, J.B., Perry, L.R., Beck, J.L. and Taylor, J.D., 2021. Increased abundance of the common
raven within the ranges of greater and Gunnison sage -grouse: influence of anthropogenic subsidies
and fire. Human -Wildlife Interactions, 15(3), p.6.
Jenkins, R.R., Maguire, K.B. and Morgan, C.L., 2004. Host community compensation and municipal
solid waste landfills. Land Economics, 80(4), pp.513-528.
Peebles, L.W. and Conover, M.R., 2017. Winter ecology and spring dispersal of common ravens in
Wyoming. Western North American Naturalist, 77(3), pp.293-308.
State of Oregon, 2019. Oregon Sage -Grouse Habitat Quantification Tool Scientific Rationale
Document. Version 2.2. Portland, OR.
Deschutes County Solid Waste Department 5532509011
Moon Pit Mitigation Memo 4 July 03, 2024
vT E S C0G
BOAR® OF
COMMISSIONERS
MEETING DATE: July 10, 2024
SUBJECT: Consideration of recommendations from the Solid Waste Advisory Committee
regarding the siting, development and mitigation of a new landfill
RECOMMENDED MOTION:
The recommendations of the Solid Waste Advisory Committee to the Board of County
Commissioners are to:
1. Select the Hooker Creek "Moon Pit" property for siting Deschutes County's future
landfill and authorize staff to move forward with negotiating a purchase agreement
and securing associated permits;
2. Direct that staff work with stakeholders to develop and implement a robust and
comprehensive mitigation strategy that reflects community values to minimize
impacts to area wildlife and recreation; and
3. Direct staff to prioritize waste prevention and recovery and move as quickly as
possible to implement those strategies to reduce the overall costs and greenhouse
gas emissions of the new landfill.
These recommendations are reflected in Order No. 2024-021, submitted for the BOCC's
consideration.
BACKGROUND AND POLICY IMPLICATIONS:
In 2019, the Board of County Commissioners (BOCC) approved the Deschutes County Solid
Waste Management Plan (SWMP) that outlined several key issues related to managing solid
waste in the County for the next 20 years and beyond. A primary recommendation of the
SWMP was the siting, permitting, and building of a new in -County landfill to replace Knott
Landfill when it reaches its capacity.
In April 2022, the BOCC appointed the SWAC that consisted of representatives of each of
the four municipal jurisdictions and both franchise haulers, as well as five citizens -at -large
and a representative of the environmental community. The role of the SWAC was to review
and recommend the criteria and process to be used to evaluate prospective sites and to
apply the criteria in the assessment and selection of a finalist location. The SWAC, working
with Department of Solid Waste staff and Parametrix (the consulting firm awarded the
contract to assist in the site assessment process), developed the Site Selection Criteria (SSC)
to guide the siting of a new solid waste management facility. After holding a work session
with staff to discuss and amend the document, the BOCC approved the SSC in June of 2022.
The site selection process reviewed over 200 areas of interest in the County, then reviewed
31 of those through the broad screening evaluation process. This was followed by the focus
screening evaluation of 12 potential sites. During this phase, the SSC was amended by the
BOCC at SWAC's recommendation to include the Federal Aviation Administration's advisory
memorandum which expanded the airport exclusionary zone from 10,000 feet from the
Bend and Redmond airports runways to a five -mile exclusionary zone from the airport
property boundary to minimize the potential for airplane bird strikes.
The SWAC recommended two sites in the eastern portion of the County for final site
evaluation. Following that evaluation, the SWAC came to a unanimous recommendation of
the Moon Pit site for BOCC consideration.
A public hearing was held before the BOCC on June 12, 2024, after which the Board allowed
the submittal of additional written comments until Wednesday, June 26t". All written public
comments and other relevant materials pertaining to the public hearing may be viewed at
www.deschutes.org/solidwaste/page/solid-waste-management-facility-location-proposal.
In follow-up to the public hearing and questions that were raised during the Board's
discussion, Parametrix has assembled three memoranda to provide additional information
and/or clarification regarding water rights, environmental mitigation, and aggregate value
as those issues pertain to the Moon Pit site. The full Solid Waste Management Facility Final
Site Evaluation Report and Appendices and all relevant SWAC meeting details can be
accessed at deschutes.org/managethefuture.
BUDGET IMPACTS:
The Solid Waste Department has included $2,700,000 in the FY24/25 budget for the next
stage of the procurement and permitting process. The overall project development is
anticipated to cost between $50-60 million to procure, permit, develop and commence
operation in 2030.
ATTENDANCE:
Tim Brownell, Director of Solid Waste
Dwight Miller, Project Manager, Parametrix