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address connectivity through the existing waterways. Proposed protection criteria 3 and <br />4 place a higher value on wetlands that are within 1 a0 feet of protected waterways and <br />on wetlands with direct surface water connections to protected wetlands. These criteria <br />will lead to protection of many of the wetlands with these connections, helpin to rovide <br />g p <br />the linkages called for in Policy 3.$. Therefore the amendments are consistent with <br />Policy 3.$. <br />Summary Conclusions: West Eugene Wetlands Plan Consistency <br />The above findings indicate that the proposed amendments are consistent with the a livable olicies <br />pp p <br />in the remainder of the WEWP. The proposed amendments meet the criterion of consistenc with <br />Y <br />the remainder of the refinement plan. <br />Section 9.145 ~Z}~c} "Thy plan amendment is found to address one or more of the <br />fallowing: <br />1. An error in the publication of the plan;" <br />Findings: Not applicable. <br />Section 9.145 ~Z}~c} 2. "A change of circumstances in a substantial manner not anticipated <br />in the plan;" <br />Findings: Proposed policy 3.17 is introduced as a clarification of existing policy in the Plan. <br />Property owners, developers, and various agency staff have on numerous occasions <br />commented on the lack of clarity in the existing plan regarding how the protection and <br />development criteria are interpreted and a lied and whether all wetlands on ublic land <br />pp p <br />were intended to be protected. The lack of clarity in these policy areas was not <br />anticipated at the time of Plan adoption. Proposed Policy 3.17 addresses lack of clarity <br />expressed by the public following adoption of the Plan. Therefore it responds to a <br />situation not anticipated during Plan adoption and is consistent with this criterion. <br />Section 9.145 ~~}~c}3. "Incorporation into the plan of new inventory material which relates <br />to a statewide goal; or" <br />Findings: Proposed Policy 3.17 includes changes to the criterion which addresses rare plants <br />to respond to new information about rare plant distribution that was not available at <br />the time of Plan adoption. Information gathered since adoption of the Plan shows <br />that there are a number of small wetland sites, surrounded by development, with <br />small rare plant populations which would be very difficult to protect due to their <br />isolation from other habitat areas, small size, and surrounding uses. Due to their <br />isolated nature these sites cannot be integrated or connected to the larger wetland <br />system. When the Plan was adopted in 1992, it was thought that the rare plants <br />existed only on the large, pristine wet prairie wetland sites such as the 'billow Creek <br />Preserve. Proposed Policy 3.17 would require consideration of plant species listed <br />Policy Amendments 4rdrnance, F~rhibit C (Ref nement Plan Amendment Findings) Page .5 <br />