Port of Portland Letter to Oppose
Mr. Paul Shirey
Port of Portland
Box 3529
Portland, Oregon 97208
Dear Mr. Shirey,
This letter is to inform the Port of Portland of the Audubon Society of Portland’s decision to oppose the proposed three-phase development of West Hayden Island. This was a unanimous decision of both our Conservation Committee and our Board of Directors. It is our contention that the 827 acres of habitat located on West Hayden Island are of such value that the entire area ought to be protected for its multiple values, including the largest extant cottonwood bottomland habitat within the Urban Growth Boundary. After examining Portland’s Goal 5 ESEE analysis we would recommend a finding to prohibit or limit all conflicting uses and a designation of the entire 827 acres as Open Space. We anticipate that the regional Goal 5 work currently underway at Metro will also place a very high value on the protection and, where appropriate, restoration of fish and wildlife habitat at West Hayden Island. As you know, the island is especially important habitat for the recently listed steelhead and salmon.
The Audubon Society of Portland’s Urban Naturalist Program became involved in discussions regarding West Hayden Island as far back as 1984 and participated in two separate planning processes (first with Portland General Electric, and later with the Port of Portland). We also participated in Portland’s Columbia Corridor Goal 5 planning process when West Hayden Island was identified as a citywide significant Goal 5 resource. Currently we are participating on the West Hayden Island Area Plan and Natural Resource Management Plan Advisory Committee.
The reasoning behind our decision to oppose the Port’s development on West Hayden Island is as follows:
1. The value of the fish and wildlife habitat located on West Hayden Island is well documented. The Metro Greenspaces Master Plan, developed in July of 1992, recognized that West Hayden Island along with Ridgefield and Steigerwald National Wildlife Refuges, Vancouver Lake lowlands, and Government, Gary and Flagg Islands “form an important component of the Pacific Flyway.” The City of Portland Goal 5 Inventory states, West Hayden Island “is an area of large structural diversity and provides both present and potential wildlife habitat of high quality within an urban center.” It noted specifically West Hayden Island’s size, diverse wetlands, meadows and cottonwood/ ash forest habitats, and the high potential for interspersion of wildlife between it and other adjacent wildlife areas. West Hayden Island scored second (99 out of a potential 100) in habitat inventory for the Columbia Corridor. After careful examination of the Port’s draft Planning Documents, it is our opinion that the establishment of marine facilities is incompatible with the protection and preservation of this valuable resource.
2. Despite years of input from both public and private agencies as well as private individuals and various Port assembled citizens advisory committees, the Port of Portland has made numerous changes to the various plans it has put forth over the years. Each change has been made with seemingly diminished concern for the issues raised by the community regarding the value of the habitat located on West Hayden Island. Nowhere is this better exemplified than in the ever-shrinking acreage of the area that the Port proposes to have designated as Open Space. As recently as March of 1997, the Port stated that it would set aside 269 acres as Open Space. Today, that number stands at only 217 acres. This represents a 20% reduction from 1997 estimates. The establishment of a parking lot, an access road and utility corridors will further reduce the size of this area.
3. The Port’s own upland mitigation plan stands as testament to the uniqueness of the 488 acres of intact cottonwood-ash riparian forest located on West Hayden Island. This forest tract is significant not only within the Metro area but also within the region. The Port’s draft Natural Resource Element states “few local natural areas contain such a large contiguous area of this riparian forest community.” It goes on to state estimate that West Hayden Island represents 4% of this habitat located between river mile 12 and river mile 145 on the Columbia River. The Port estimates that 240 acres of riparian bottomland forest will be lost in the implementation of its proposed project. This figure does not include an additional 80 acres of forest that will be permanently enclosed within the development area and which at some future date may also be eliminated altogether. The Port’s current search for mitigation sites has identified no single site that would equal the entire 240 acres that are being lost. Government Island could potentially represent 160 acres but this site is problematic because of its distance from West Hayden Island. In the immediate vicinity of West Hayden Island no potential mitigation site larger than 66 acres was identified. The fact is that there is no way to effectively replace one large tract of forest with several smaller tracts. Significant species diversity will inevitably be lost in the process unless one single tract can be identified for mitigation purposes.
4. The development as it is currently proposed would not only eliminate the habitat value of the 610 acres proposed to be rezoned as Industrial Sanctuary, but would also significantly reduce the habitat value of the remaining 217 acres that would be zoned as Open Space. Construction will cause an ongoing disruption to the entire area over the course of the next 30 years and light and sound generated by these facilities will cause disruption in perpetuity. In the current proposal, the area designated as Open Space will be bisected by a traffic bridge and further fragmented by the imposition of utility corridors. We are particularly dismayed to see that rail lines continue to be proposed as a permitted use in the Open Space area despite the Port’s recent assurances that no rail lines will be located in this area.
5. The 30-year economic projections on which the three-phase West Hayden Island development project is based are speculative at best. There is no guarantee that phases two and three will ever occur. However, the way in which phase one is configured along with the rezoning that the Port is currently requesting, will ensure that the habitat value of the entire 610-acre development site will be degraded. We believe that a far more prudent approach would be to look at each phase of this development as a separate project. By doing so the Port might be able to locate either already developed or less environmentally valuable alternative sites.
6. The Port of Portland considered only economic and transportation issues in its alternative site analysis. Given the exceptionally high habitat value of West Hayden Island, we believe that the Port of Portland should examine opportunities to cooperate with other Port Authorities, look to existing facilities that might be able to be upgraded, and revisit other potential sites along the Columbia River that might be able to fill its short and long term needs. We believe that the Port’s failure to incorporate broader environmental concerns has resulted in a document with a flawed alternatives analysis.
7. The success of and need for the Port’s development on West Hayden Island is contingent upon several separate projects for which the Port has yet to have acquired either permits or funding. These include the construction of a traffic bridge between Marine Drive and West Hayden Island, the construction of a second railroad bridge to West Hayden Island, and the deepening of the Columbia River Channel. Each of these projects would have significant environmental effects. We believe that the Port has a responsibility to fully explain how failure to successfully achieve each of these projects would impact the proposed development on West Hayden Island.
Please feel free to contact us if you would like to discuss any of these issues further.
Sincerely
Bob Sallinger
Audubon Society of Portland Wildlife Care Center Director
West Hayden Island Area Plan and NRMP Advisory Committee
Mike Houck
Audubon Society of Portland Urban Naturalist
West Hayden Island Planning Advisory Committee (1996, 1997)
cc. Holly Michael (ODFW)
John Marshall, Jennifer Thompson (USFWS)
Ben Meyer, Michelle Day, (NMFS)
Lori Warner, (DSL)
Judy Linton, (USCOE)
Emily Roth (DEQ, Portland Harbor Program)
Ralph Thomas Rogers, Yvonne Vallette (EPA)
Portland City Council
Metro Council
