c/o Neil Björklund, Senior Planner
541-682-5507, neil.h.bjorklund@ci.eugene.or.us
Ann Siegenthaler, Associate Planner
541-682-5451, ann.siegenthaler@ci.eugene.or.us
Planning and Development Department
City of Eugene, Oregon
Re: Staff recommendation of March 10, 2003 regarding NRS inventory and significance criteria
Dear Planning Commissioners,
Thank you for the dedication to public interests which you demonstrated in re-opening the record on the city’s Natural Resources Inventory (NRS) and significance criteria. Since the NRS is a project the city has been working on for more than fifteen years, the opportunity for public comment on significant changes proposed months after your public hearing seems especially important.
In continuation of your commitment to the public interest, it is most important that you adopt the significance criteria shown in Attachment A of the staff memo, and the corresponding inventory Map A.
The primary alternative option, shown in Attachment B and Map B, is deeply flawed. Although it represents a sincere attempt at improving the inventory, it comes too late to have been adequately crafted, and it would in fact seriously damage both the scientific integrity and regulatory enforceability of the NRS.
I write to you on behalf of Friends of Eugene, a local 501(c)3 non-profit dedicated to preservation of liviability in Eugene, Southeast Neighbors, the city-recognized neighborhood association representing more than 6000 residences and some 13,000 residents in southeast Eugene, and the Citizens Nature Project, a volunteer coalition of several dozen average citizens and experts in the environmental sciences, who have collectively contributed grassroots documentation on about 120 areas of potentially significant natural resources to the record for the NRS process. Although these groups represent different constituencies, different interests, and different bases of knowledge with regard to natural resources, we have a common position with regard to the current staff recommendations on the NRS.
In their March 10, 2003 memo to the EPC, city staff made four specific recommendations. I’d like to address all four in summary, and then discuss the second item in detail:
Staff Recommendation One
That the Planning Commission move forward with Planning Commission action on significance criteria and inventory for riparian and upland wildlife habitat sites in order to complete adoption by the City Council in June 2003.
We agree with this sound recommendation. After 15 years of work, the inventory is as good as it is going to get. The process should move forward at last, both to meet local needs and state deadlines.
Staff Recommendation Two
Option 4.3: Recommend to City Council adoption of revised significance criteria as
shown in Attachment B, and corrected and revised inventory as shown on Maps B1
through B4.
Instead of Option 4.3, we recommend the option staff describe as Option 4.2 on page 6 of their memo, because it represents the only option which is reasonably accurate to both science and policy:
Recommend to City Council adoption of corrected significance criteria as shown in Attachment A, and corrected inventory as shown on Maps A1 through A4.
Staff Recommendation Three
Direct staff to provide information on potential protection measures to affected property owners prior to public hearing before the City Council.
This recommendation should be amended for balance, to read something like:
Direct staff to provide information on potential protection measures to affected property owners and other interested citizens prior to public hearing before the City Council.
Staff Recommendation Four
Direct staff to hold a public information session prior to the public hearing before the
Council on the revised Goal 5 Inventory for riparian and upland wildlife habitat sites to
provide information on the status of the inventory and on potential impacts to specific
parcels.
This recommendation should be amended for balance, to read something like:
Direct staff to hold a public information session prior to the public hearing before the
Council on the revised Goal 5 Inventory for riparian and upland wildlife habitat sites to
provide information on the status of the inventory and on potential impacts both to specific
parcels, and to overall natural resource preservation.
Criteria A versus Criteria B
The modest adjustments shown in significance criteria A and the corresponding Map A, which staff refers to as ‘corrections’, are generally reasonable, and from our perspective, on balance probably improve the NRS inventory.
In contrast, close inspection shows that the more substantial adjustments shown in significance criteria B and the corresponding Map B, which staff refers to as ‘revisions’, are not reasonable. From either a scientific or a policy perspective, Map B represents a giant and strangely arbitrary step away from a reasonable and accurate inventory.
Among the hundreds of pages of citizen and expert testimony on the characteristics and ecological important of more than a hundred areas, several specifically document the important of areas that would be dropped under the arbitrary impact of criteria B.
Other testimony details the full range of language difficulties and scientific shortcomings in criteria B. I will focus on what is perhaps the most problematic, least defensible aspect of the proposed revised criteria: the 500 foot limitations.
There is no basis in the record for these dimensional limitations. Technically, they represent a mis-use of the waterway and habitat survey data. As shown in Map B, they would arbitrarily result in literally hundreds of acres of prime natural resource lands being dropped from the inventory.
To try to illustrate the inappropriateness of criteria B, just for example, I have taken a few pictures of areas in site E37 which would be removed from the inventory if criteria B were to be allowed. Can you tell that these not natural resources, to drop them from the inventory? Please see below.
Sincerely,
Kevin Matthews
President, Friends of Eugene
541-345-7421 vox
541-345-7438 fax
matthews@artifice.com
Photo taken 2003.0328 showing part of Eugene NRS Draft Inventory Site E37 which would be removed from the inventory under criteria B (see text above for details). © KMM
Part of Eugene NRS Draft Inventory Site E37 which would be removed from the inventory under criteria B. © KMM
Part of Eugene NRS Draft Inventory Site E37 which would be removed from the inventory under criteria B. © KMM
Part of Eugene NRS Draft Inventory Site E37 which would be removed from the inventory under criteria B. © KMM
Part of Eugene NRS Draft Inventory Site E37 which would be removed from the inventory under criteria B. © KMM
Part of Eugene NRS Draft Inventory Site E37 which would be removed from the inventory under criteria B. © KMM
Part of Eugene NRS Draft Inventory Site E37 which would be removed from the inventory under criteria B. © KMM
Part of Eugene NRS Draft Inventory Site E37 which would be removed from the inventory under criteria B. © KMM
