It is critical that DSL hear from the community. Originally they tried to change the permit conditions without any public notice or comment. It was only after strong protests by Portland Audubon, Willamette Riverkeeper and Urban Greenspaces Institute that DSL grudgingly agreed to a 30-day comment period. The attempt to completely bypass the public process was outrageous, but the real problem is the proposal itself.
Please submit comments to Ms. Melinda Butterfield at email@example.com and specifically reference Ross Island Removal-Fill Application Number 9819-RF before the end of day on Thursday, September 22, 2022. Use key talking points outlined below.
Key Talking Points
- Ross Island Sand and Gravel Company should be given no more than six years to complete its restoration obligations. The restoration efforts have already taken decades and they are ten years behind schedule on completing the work. Giving them another 12 years to finish the restoration is outrageous. The State must require that all restoration requirements are completed within 6-years and should impose substantial penalties if deadlines are not met.
- The permits should require that shallow water and emergent wetland areas be off limits to motor boats. There are plenty of areas in and around the lagoon to use motorized boats. Fragile shallow water habitat and emergent wetlands are not appropriate for this type of activity.
- Class A Fill should be required for all in-water and upland restoration activities. Allowing Ross Island to use contaminated Class B and Class C fill in the “uplands” doesn’t make any sense. Almost the entire island, including the “uplands”, is in the special flood hazard area and subject to complete inundation during flood events.
- The State must require Ross Island Sand and Gravel Company to provide bonding for the entire projected cost of the project. It was recently revealed that Ross Island secretly sold the island to the company’s pension fund. As reported in the media, the legality of this sale is questionable and could result in significant legal challenges. As a condition of the amended permits, the State must ensure that in the event that Ross Island Sand and Gravel Company is unable or unwilling to meet its obligations, that neither the taxpayers or the pension fund is forced to step-in.
- The State should require as a condition of the permits that Ross Island allow local, state, and federal enforcement agencies to access the waters adjacent to the island. Waterways in Oregon are typically publicly owned but some of the water areas around Ross Island are an exception and are owned by the company. Even when clearly illegal activities are occurring, Ross Island Sand and Gravel has not always allowed enforcement to proceed. Enforcement agencies need to have the ability to protect in-water habitat areas.
Ross Island is one of our region’s most valuable natural areas—habitat for wild birds and endangered salmon and an incredible place in the middle of the city to experience and enjoy nature. However, it’s been seriously damaged by decades of mining that brought great wealth to the Ross Island Sand and Gravel Company. The Company is years behind on its obligations. State Agencies such as DSL and DEQ must ensure that any permit modifications result in expeditious, enforceable and durable completion of all restoration obligations.
Please write DSL and let them know what you think!