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<br />The designation of a substantial acreage of wetlands for Development reflects an effort to <br />minimize the economic hardship of wetland protection on the property owner. The <br />wetlands designated for Protection and Restoration would be eligible for acquisition <br />under the West Eugene Wetlands Acquisition program administered by the Bureau of <br />Land Management. Such acquisition would also help to minimize economic hardship. <br />We conclude that although neither of these actions eliminates economic hardship, they do <br />show a good faith effort to minimize them, and therefore we conclude the wetland <br />designations for the Speedway site are consistent with Goal 3.2. <br /> <br />Goal 3.3 <br /> <br />"Minimize adverse impacts to protected wetlands from adjacent <br />development. " <br /> <br />The wetland designations for the Speedway site include substantial areas designated for <br />Development. The West Eugene Wetlands Plan and its implementing ordinances do not <br />require setbacks upon areas of fill authorized within wetlands. This policy is intended to <br />reduce the financial burden of developing within wetlands designated for Development. <br />In order, then, to minimize impacts from development on this 'site, the area of protection <br />and restoration must be sufficiently wide so that most of the wetland area is not <br />immediately next to the development. In this respect, a wider Protection/Restoration <br />corridor provides more protection for the wetlands in that corridor than a narrower <br />corridor would. A wider corridor would also provide more buffering effect for the <br />WCNA by keeping development further from sensitive rare plant areas on the south side <br />of 18th Avenue. We conClude, therefore, that the existing wetland designations for this <br />site, which include a 900 foot corridor along the east side of the property, are consistent <br />with Goal 3.3. <br /> <br />Goal 3.5 <br /> <br />"Protect and expand current populations and habitats of rare plants and <br />animals that currently exist in west Eugene." <br /> <br />This site contains several plant species that are listed as "rare" in the West Eugene <br />Wetlands Plan. . The wetland designations for this site would protect nearly all of the <br />existing rare plants, and would allow for suitable habitat between these existing plants for <br />expansion of these populations. If only the areas immediately surrounding the existing <br />plants were protected or restored, little opportunity would exist for expansion of the <br />populations. We conclude that the wetland designations for this site would protect and <br />allow expansion of current rare plant populations. Therefore, these designations are <br />consistent with Goal 3.5. <br /> <br />Goal 3.6 . <br /> <br />"Achieve state and federal requirement of 'no net loss' of wetlands in both <br />quantity (area) and quality (functions and values)." <br /> <br />"No net loss" can be pursued through a combination of avoiding wetland impacts where <br />possible, and replacing those low quality wetlands where development values outweigh <br /> <br />Speedway Site Ordinance, Exhibit C (Refinement Plan Amendment Findings) <br /> <br />Page 21 <br />