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inventories, the local jurisdiction does not have the option of broadening the application of the criteria beyond what is explicitly given in the OARs. Staff does not dispute the presence of pileated woodpeckers in the South Hills, or within some of the upland wildlife habitat sites that were recommended to be included in the Goal 5 inventory in 2003. However, establishing the presence of the species is not sufficient to meet the OAR safe harbor criteria for wildlife habitat sites. New Information The Council motion indicates that there is new information related to pileated woodpeckers in the South Hills. Staff has reviewed the record used in the 2003 Council action and the additional information submitted as part of the discussion item on acquisition of the Nectar Way property and is unaware of any new information on this topic. Information on the presence ofpileated woodpeckers at several locations in the South Hills has been in the record for Goal 5 for a number of years and was considered in the Council's action in 2003. Status of Pileated Woodpecker Pileated woodpeckers were listed by the State of Oregon as a sensitive species in 1997. This designation was not made because they are rare or declining in numbers, but because they have been considered an indicator species for mature and old-growth forest, and because they are sensitive to clear-cutting and other forms of timber harvest that involve removal of large live and dead trees (which the woodpecker needs for nesting, roosting and foraging).~ Research has shown that in western Oregon, the species is not dependent on old growth forest, but will utilize stands 70 years of age or older for nesting and 40 years or older for foraging.: Studies have documented that nest cavities created by pileated woodpeckers are utilized by more than 20 species of secondary cavity nesters (i.e., species that nest in cavities created previously by another species). For this reason, the pileated woodpecker has been considered a "keystone habitat modifier," which is a species that plays a unique and important role in maintaining habitat for other species,s Of the 24 species of secondary cavity nesters documented as using pileated woodpecker nests, six are known to occur in forested areas of the South Hills (western screech-owl, northern pygmy-owl, northern saw-whet owl, Vaux's swift, northern flicker, and brown creeper). Recent Breeding Bird Survey data show that the species is increasing in numbers in western Oregon.4 Pileated woodpeckers are considered common to uncommon throughout western Oregon, west of the Cascade crest.5 In the Willamette Valley, suitable habitat for pileated woodpeckers probably did not commonly exist prior to Euro-American settlement and consequent fire suppression.6 Before the suppression of seasonal fires, oak savanna habitat dominated in the foothills of the Willamette Valley. As fire was suppressed, Douglas fir-dominated forest has overtaken the historic oak savanna and oak ~ Oregon Department of Fish and Wildlife, Wildlife Diversity Program. Species At Risk, Sensitive, Threatened and Endangered Vertebrates of Oregon, Second Edition. June 1996. : Mellen, T.K., E.C. Meslow, and R.W. Mannan. Summertime Home Range and Habitat Use of Pileated Woodpeckers in Western Oregon. Journal of Wildlife Management, 56(1) 96-103. 1990. ~ Aubrey, K.B, and C.M. Raley. The Pileated Woodpecker as a Keysone Habitat Modifier in the Pacific Northwest. USDA Forest Service Technical Report. PSW-GTW-181. 2002. 4 Sauer, J. R., J. E. Hines, and J. Fallon. 2005. The North American Breeding Bird Survey, Results and Analysis 1966 - 2004. Version 2005.2. USGS Patuxent Wildlife Research Center, Laurel, MD s ODFW. Ibid. 6 Personal communication, Peg Boulay, Sensitive Species Coordinator, ODFW, June 2005.