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habitat identification. The pileated woodpecker is listed as a sensitive species by the State of Oregon, and is not listed as threatened or endangered at the federal level. Therefore, staff met with biologists from the Oregon Department of Fish and Wildlife (ODFW) and determined from that meeting that ODFW had not issued a map ofpileated woodpecker habitat within the local area. The public record was also reviewed, and no map delineating areas of pileated woodpecker habitat had been submitted into the public record, nor had such a map been referenced in testimony in the record. On that basis, staff concluded that criterion (4)(b) was not met. Only one official map that addresses pileated woodpeckers is known among current and past staff involved in the Goal 5 process. That map is contained in an April 12, 1978 Metro Plan Update working paper entitled "Vegetation/Wildlife/Wildlife Habitats." Map D-2 in that working paper was created by using vegetation mapping: specific wildlife species were "assigned to their characteristic habitat types as represented by the vegetative cover types." No source is given for the data, and no references are given for any study of habitat needs of the wildlife species referenced on the map. The map notes two discrete locations for pileated woodpecker within the urban growth boundary: (1) a point location west of Fox Hollow Road near Foxtail, and (2) a point location west of South Willamette Street, just south of Trailside. Due to the lack of delineated boundaries of a habitat area suitable for pileated woodpecker, this map does not meet the OAR criterion for the safe harbor inventory process, which requires a map of a habitat "area." The map showing two point locations would not facilitate inclusion ofpileated woodpecker habitat in the Goal 5 inventory without additional field study and inventory work to delineate the boundaries of suitable habitat. The two pileated woodpecker locations on Map D-2 were not included in the list of 35 significant vegetation and wildlife areas identified in the working paper. The maps of Goal 5 upland wildlife habitat sites that were developed as part of the preliminary Goal 5 inventory, and the inventory sites recommended by the Planning Commission in 2003, were not based on the specific, scientifically documented habitat needs of the pileated woodpecker. These habitat areas were based on general habitat characteristics, including food, cover, and water that provide habitat to a wide range of species. So, while it is clear that some of these mapped habitat areas do include habitat areas used by the pileated woodpecker, they also likely include areas not used by the woodpecker, and do not include some areas that are likely used by the woodpecker. Therefore, staff does not consider these maps to represent, in any scientifically defensible way, maps ofpileated woodpecker habitat. The legal record for the adoption of the Eugene Goal 5 inventory that opened with the notice of a public hearing before the Eugene Planning Commission in November 2002 contains two pieces of testimony that mention the pileated woodpecker on two sites (headwaters of Amazon Creek south of Martin, and site E37 west of Amazon). In 2000, at least five pieces of written testimony were submitted through the Metro Goal 5 process that indicated sightings ofpileated woodpecker on at least 3 specific sites (forested area north of Dillard Road, forest above Owl Road and forested area near 23rd and City View). One additional site (Amazon headwaters area above Martin Street) was noted as providing habitat for pileated woodpecker, but did not include any documentation of sightings or the basis for the conclusion that the site provides habitat for this species. None of these comments included a professionally prepared map delineating the area of the woodpecker's habitat on those sites, and none of these included documentation for the individuals submitting this testimony of professional credentials relating to identification of pileated woodpecker habitat. None of these references provide any supporting details, such as date of sighting, in what activity the bird sighted was engaged, or on how many occasions the species was sighted. It is important to note, that the safe harbor process does not allow the local government to revise these criteria. Revisions to the safe harbor inventory criteria would have to be adopted by the local government as standard Goal 5 inventory significance criteria. Therefore, under the safe harbor provisions for Goal 5