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woodland habitat. These oak-dominated habitats do not support pileated woodpeckers, since they are neither densely forested nor do they contain adequate density of dead and dying trees to provide nesting, roosting and foraging sites required by these woodpeckers. Based on staff communications with knowledgeable bird-watchers in Eugene, it appears that the pileated woodpecker has been sighted in both developed and undeveloped areas throughout the South Hills. A search of the scientific literature did not reveal any studies of the bird's nesting, foraging and roosting behavior or habitat needs in an urban area. Status of the 2002 Goal 5 Inventory in the South Hills The Goal 5 inventory for the South Hills, as it was developed in 1989, consisted of three very large habitat areas: the West Eugene Uplands (Site E37; 2,642 acres), the Southwest Hills (Site E38; 3,043 acres) and the Laurelwood Uplands (Site E38; 1,575 acres). Over the 16 years since the original inventory was conducted, these sites have been greatly modified and reduced in extent due to development. Although the boundaries of these sites were updated a number of times to remove developed areas, no update of the habitat evaluations were conducted. Each of these large habitat areas was evaluated as a single unit to determine its relative value as wildlife habitat. It is clear that the undeveloped areas in the South Hills are not uniform in their habitat quality or ecological function. There are areas with varying levels of habitat quality and that serve a variety habitat functions. Due to the way these sites were evaluated for Goal 5, the existing Goal 5 inventory data do not include this kind of information. The absence of this kind of data will inhibit making distinctions of value among the various types of habitat within these huge areas, such as would be required under the Goal 5 ESEE (Economic Social Environmental Energy) analysis. Addressing Other Resources In addressing only pileated woodpecker habitat, the Council motion does not make it clear whether the Council intends that staff will address the regionally scarce and ecologically important habitat types in the South Hills, such as oak woodland, oak savanna, native upland prairie, old growth Douglas fir/western hemock forest, mature/old growth grand fir, or Ponderosa pine stands. It is also not clear whether it is the Council's intention that rare plant populations be inventoried or addressed. Two rare plant species, tall bugbane (Cimicifuga elata) and wayside aster (Aster via/is) are known to occur in the South Hills. Four additional species are possible in the South Hills: Kincaid's lupine (Lupinus sulphureus ssp. kincaidii), rigid white-topped aster (Aster curtus), Willamette Valley daisy ((Erigeron decumbens var. decumbens), and shaggy horkelia (Horkelia congesta ssp. congesta). Including these resources in a review of the inventory in the South Hills would provide a more holistic and scientifically defensible basis for making decisions in the Goal 5 process. The Council's June 8, 2005 motion would also not add to the Goal 5 inventory the following upland sites that were removed from the inventory in 2003: Site E34 West Eugene Oak Savanna, Site E40 Riverfront Park (upland portion), Site E43 Alton Baker Park Uplands, Site E55 Skinner Butte, Site E80 Masonic Cemetery, Site E83 Elliott Hill/Tugman Park Oak Woodland, Site E84 Bond Lane Park, Site E85 North Delta, and Site E89 West Lawn Memorial Park (heron rookery). Please contact me at 682-5507 or via e-mail (neil.h.bjorklund~ci.eugene.or.us) if you have questions or need additional information.