Posted by Kevin Matthews on December 17, 2002 at 12:00:57:
Eugene Planning Commission
Dear Eugene Planning Commissioners,
Thanks you for hearing citizen input on the Eugene Natural Resources Study Draft Inventory and Significance Criteria.
It is a matter of the highest importance for the Draft Inventory and Significance Criteria to be approved by the EPC and forwarded post-haste to the Eugene City Council.
According to this inventory, which has now undergone scientific and public process for some fourteen years, there are fewer than 4000 acres left of significant riparian and upland habitat left to consider within the Eugene UGB. Protecting these scant remaining areas has become an absolutely critical planning issue.
Substantially the same Draft Inventory and Significance Criteria before the Planning Commission to day have already been approved by the Eugene City Council, which further declined to water-down the significance criteria in response to City of Springfield and Lane County actions several months ago.
The Draft Inventory and Significance Criteria are not perfect. The significance criteria should be more clear about the important value of ecological continuity, and should give more credence to the value of resources lands which are intact in terms of trees, soils, and hydrology, and therefore highly restorable, but are discounted nonetheless under the current criteria due to invasion by lesser non-native plants.
The draft inventory has undergone a recent revision, from the September 2001 LCOG maps to the October 2002 Eugene maps, for which there is insufficient public documentation.
The city NRS web page "http://www.ci.eugene.or.us/NRS/eugene.htm" says, "In October 2002, Eugene updated its inventory of riparian and upland habitat sites to reflect changes in site boundaries due to development that had occurred since the original inventory."
We've read "Draft Inventory of Goal 5 Riparian and Upland Wildlife Habitat Sites Within the Eugene Urban Growth Boundary", 2002.1115, NR_Inventory_11_15.pdf, and don't see this addressed in there.
We have requested a list of the specific changes that were made to the September 2001 maps, resulting in the October 2002 maps, either be in the form of detailed descriptive text, or in the form of legislative format maps, demarking both the September 2001 and the October 2002 boundaries, with additions and deletions clearly denoted.
With the City maps of October 2002 in a somewhat different size and format from the September 2001 LCOG maps, and especially for a large, discontinuous site like E37, covering over 1200 acres, encompassing perhaps hundreds of tax lots, it is not practical to decipher specific changes to the inventory by unaided visual comparison.
As we understand the update process leading to the 2002.10 maps, deletions were made based on 1999 aerial photographs. However, the Citizens Nature Project submitted more than 100 site reports based on actual on-site field work done during the summer of 2000. We would have appreciated an opportunity to specifically review any possible discrepancies between our documented on-site field work and changes made by photo-interpretation.
However, despite these imperfections in the Draft Inventory and Significance Criteria, we do have overall confidence in the inventory as proposed. In fact, from a scientific perspective, it represents some of the highest quality, most solid product by local government staff and citizens recently seen.
These fewer than 4000 acres need to be reviewed for potential protection now, without further delays. Their modest extent has already been accounted for in the residential and industrial lands studies.
Fourteen years is more than long enough for Eugene to wait for finishing just the first step of the state-mandated standard Goal 5 planning process.
Co-coordinator, Citizens Nature Project
President, Friends of Eugene
President, Southeast Neighbors
Citizens Nature Project http://www.NatureProject.org/nature.html
To join the Citizens Nature Project general discussiom email list,
just send email to "email@example.com", and in the body
of the message say exactly: subscribe nature
To leave the list say exactly: unsubscribe nature
Kevin Matthews, firstname.lastname@example.org
541-345-7421 vox, 541-345-7438 fax, P.O. Box 1588, Eugene, OR 97440