Posted by Kevin Matthews on March 09, 2001 at 19:01:09:
Dear Nature Project People and Friends,
Great thanks and congratulations to all the Nature Project folks and other neighbors who turned out to comment at the Joint Planning Commissions Public Comment Session on Tuesday, March 7, on the Metropolitan Natural Resources Study. The commentors at the session consisted mainly of us, a few concerned landowners, and representatives of the gravel pit operators.
The comments made were eloquent and well-informed, raising sound questions about the timing and adequacy of public information provided for the forum.
The outcome is exactly what we wanted for this stage of the process. Our concerns were heard, and LCOG and city staff were asked by the Planning Commsssioners to provide us with the complete list of responses to our nature site submissions, and also to provide more detailed, higher-resolution maps.
The public comment period has been extended about six weeks, or to about 30 days after when we get the response list and the better maps. Also, another public comment session is being scheduled for around the end of this six week period.
Staff continues to work with us to fill these information needs. Eric Wold of the City of Eugene says the repsonse list will be on the CIty web site on Monday, and Kathi Wiederhold of LOCG say on Monday or Tuesday she'll know when the better maps will be available.
Our NEXT STEP is to carefully review those materials, once we've gotten them.
PS: Below, for your entertainment, is a copy of the written comments I submitted on behalf of the CNP Tuesday night. In the live presentation, I gave the commissioners a quick overview of the CNP and how we've worked together.
Citizens Nature Project 6 March 2001
Joint Planning Commissions of
Eugene, Springfield, & Lane County
Re: Metropolitan Natural Resources Study
Joint Public Comment Session
Tuesday, March 6, 2001
We can all be proud today to see our community making significant progress toward substantive compliance with state-wide natural resource planning goals. Local government staff have worked hard and well to develop the draft inventory and significance criteria presented today.
As you are probably aware, this draft inventory has been enhanced by the voluntary efforts of several dozen citizen surveyors, loosely coordinated by the Citizens Nature Project, who spent several days last summer and fall documenting potential nature resource sites across Eugene and Springfield.
Staff of LOCG and local governments, led by Kathi Wiederhold, have earned our sincere appreciation for their extra efforts to receive, catalog, and review the more than 130 citizen site reports we submitted last year. We also thank them for acknowledging these contributions of the Citizens Nature Project in the documents they have provided you today.
Unfortunately, public notice for today's comment period was scanty, and perhaps imbalanced, so many of the citizen intervenors are unable to comment here today. To remedy this, we ask that you 1) keep today's public comment session open for 30 days past today, and 2) take concrete and effective steps to ensure that comments submitted after today receive the same level of attention and exposure as comments made or submitted now.
Some other factors add to the issues of timing and distribution of notice, in making constructive comment more difficult. Hopefully these can also be addressed.
The draft significance criteria, available to us in explicit form for the first time in this packet, are not in themselves transparent and complete. They are also presented without explanation or discussion of the various policy choices embodied in their current form. Yet these criteria, new to the public, have already been applied substantively in editing the inventory of sites.
The Tier 1 Significance Criteria list of 11 items is quite good as far as it goes. But why do these criteria not include other values, such as contribution to habitat corridors and continuity, the presence of other Goal 5 attributes like recreational and educational value, or the potential for restoration of habitat quality? Values like these, while perhaps secondary, can be important in accurately assessing the significance of partially impacted sites, or sites appropriate for multiple community uses.
The Tier 2 Significance Criteria list of two items is more problematic. The Wildlife Habitat Assessment (WHA) process used appears to be documented only in an appendix to a ten year old attachment, which says in part:
This rating system was meant to assess the relative values
of water areas and upland areas. It was not intended to
provide a comprehensive analysis of each site. Information
derived from the narrative descriptions and rating sheets
should be used in tandem with an emphasis paced on the
(Lev, 1990, p34)
Some explanation of the policy choices implicit within the modified WHA methodology used, and of the choice of the magic number 17, would allow citizens and elected officials alike more complete access to the inventory basis.
With regard to the inventory itself, the compact maps included in the packet are very helpful for getting a general overview. However, maps of large "sites" such as E37, Southwest Hills, don't even begin to provide sufficient resolution to allow comment on specific site boundary choices made by staff, and all the site maps lack detail. For some 20 sites, all we can tell at present is that boundaries were "adjusted". Information on the content of those actual adjustments is apparently not yet available to the public.
To receive constructive comment, the significance criteria need to be complete and transparent, and the site maps and site descriptions need to be sufficiently detailed ‹ much more detailed than those in the present packet.
Looking forward, we should plan to continue the positive citizen engagement this process has achieved to date by adding another public comment session early in the conflicting uses and ESEE phase of the process. The potential importance of adding a session like this was recognized by the Citizen Involvement Committee that approved the current process. Now that the contingency of high public interest has come to pass, we hope you will welcome it constructively.
We applaud the progress being made on the vital local natural resources inventory project. This is especially positive after so many years of past. Given the challenge in completing this process, it is all the more important that it be completed as accurately as possible for our community.
Joint Coordinator, Citizens Nature Project
Citizens Nature Project http://www.NatureProject.org/nature.html
Neighbors Forum http://www.SoutheastNeighbors.org/sen_forum.html
FoE Forum http://www.FriendsofEugene.org/friendly.html
Kevin Matthews, email@example.com
541-345-7421 vox, 541-345-7438 fax, P.O. Box 1588, Eugene, OR 97440