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HomeMy WebLinkAboutItem C: Goal 5 Invent/S.HillsEUGENE CITY COUNCIL AGENDA ITEM SUMMARY Work Session: Process for Review and Update of Goal 5 Inventory in the South Hills Meeting Date: June 27, 2005 Agenda Item Number: C Department: Planning and Development Staff Contact: Susan Muir www. cl. eugene, or. us Contact Telephone Number: 682-6077 ISSUE STATEMENT The purpose of this work session is to follow up on the motion passed by the council on June 8, 2005, regarding the Statewide Planning Goal 5 Inventory in the South Hills. BACKGROUND On July 28, 2003, the council adopted Ordinance #20296, which adopted Eugene's Goal 5 Inventory of Riparian and Upland Wildlife Habitat Sites. Adoption of that ordinance allowed the City to move forward and propose protection measures for the resources included on the inventory. Those measures are currently before the Eugene Planning Commission for consideration and are scheduled to be before the City Council in the fall. On June 8, 2005, the council passed a motion directing the City Manager to review and update the Goal 5 inventory in the South Hills, to respond to information about the presence of the pileated woodpecker in that area. For additional technical information about Goal 5 "safe harbor" provisions, the inventory adoption process in 2003, the pileated woodpecker and the status of the inventory information for the South Hills, please see the attached memo from staff dated June 20, 2005. The Goal 5 Periodic Review Work Task currently has a state mandated deadline for completion of June 30, 2005. This deadline was an extension from an earlier deadline and there are no other avenues for additional extensions. Prior to June 8, 2005, the City notified the Department of Land Conservation and Development that the project would not be completed by June 30, 2005, but that it would be completed as soon as possible and has presented the tentative timeline that kept the City close to the mandated schedule. City staff believes there was an informal good faith understanding with the State that staff was continuing to move the project forward, was working hard towards keeping the timeline, and was keeping the State plugged into the process and timeline to avoid problems. The State has authority to schedule the City of Eugene in front of the Land Conservation and Development Commission (LCDC) after June 30, 2005, and ask for a progress report and could consider other actions. Staff has not asked the State to respond to the June 8, 2005, motion in writing, but has asked them to be available for the June 27, 2005, work session. The Eugene Planning Commission is expected to complete its work on Goal 5 by early July 2005, and a work session and public hearing before the council are scheduled in September 2005. This means that, after approximately ten years of work on this Periodic Review task, the current Goal 5 process can be completed within 4 to 5 months. L:\CMO\2005 Council Agendas\M050627\S050627C.doc The addition of substantial areas of land to the current Goal 5 process could have significant impacts on the City's ability to comply with its current Periodic Review requirements for Statewide Planning Goal 5 and may have unintended consequences, including a delay in adoption of regulations that could result in additional loss of riparian habitat. Staff work to update and incorporate these additional areas into the inventory would likely take at least a year, and additional public notice and involvement would add additional time to the schedule. Because the bulk of the staff work in addressing waterways on the existing Goal 5 inventory is complete and under consideration by the Planning Commission, the Goal 5 process for the existing inventory of waterways can be completed relatively quickly. New areas of habitat would be subject to the same work tasks that staff has spent the last year working on for the waterway sites. These tasks include, at a minimum: 1) field verification of site conditions; 2) corrections to site boundaries based upon updated mapping of stream corridors; 3) corrections to site boundaries based upon new color 2004 aerial photos; 4) preparation of required analyses of economic, social, environmental and energy consequences of protecting or not protecting the site; 5) preparation of draft protection recommendations; 6) preparation of code amendments to implement recommended level of protection for each site; and 7) preparation of a legislative zone change to apply protection measures to sites recommended for protection. This work took 2 FTE approximately one year to complete for the waterway sites on the existing Goal 5 inventory currently in front of the Planning Commission for consideration. Staff suggests the council consider that the potential objective and desired outcome of the June 8, 2005, action could be addressed in other ways that may have distinct advantages. There may be a more practical and defensible way of considering protections for new areas. Related to timing; if the current process is completed as currently planned, and additional upland wildlife habitat areas are addressed subsequently, both of these can be completed by fall 2007, approximately the same schedule forecast for combining the two into the current process. Even though separating the two processes would delay the start of work on additional upland areas, the existing analyses (assuming the new work task applies just to the South Hills) would not have to be re-written, which would save considerable staff time. In addition, staff does not believe there would be any consequences in terms of proposed areas for protection, if they were considered at different times. This savings would balance against the delay in starting work on the added upland areas, which would make the two completion dates approximately the same. Separating the two processes allows protection measures to be applied to waterways and wetlands almost two years earlier than would be possible if both are combined into the current process, while facilitating completion of the work on the added upland areas within the same time frame. RELATED CITY POLICIES Council Resolution No. 4615, adopted in April 2000, provided direction to staff to respond to the ESA- listing of salmon in the Willamette River, and also called for action to complete the Goal 5 process. Completion of the Goal 5 process for riparian sites on the existing Goal 5 inventory will protect important habitat for the federally-listed threatened upper Willamette Spring Chinook Salmon. Eugene Growth Management Policy 17 states: "Protect and improve air and water quality and protect natural areas of good habitat value through a variety of means such as better enforcement of existing regulations, new or revised regulations, or other practices." The Goal 5 process is the main procedural tool for protecting natural resources through regulation. L:\CMO\2005 Council Agendas\M050627\S050627C.doc COUNCIL OPTIONS The primary options available to the council related to the June 8, 2005, City Council motion are summarized below: Option 1 - Implement the June 8, 2005, City Council motion as approved. Description: As indicated in the attached memo from staff, a review of City Council action in 2003, the record for that action, and associated findings, staff concludes that the council' s action was correct with regard to application of OAR safe harbor criteria related to sensitive species. While at least two state-designated sensitive species (pileated woodpecker and northern pygmy owl) are known to occur in the South Hills, there are no extant maps of their specific habitat prepared by state or federal agencies or by qualified professionals. Maps of generalized wildlife habitat, within which a sensitive species is known or noted to occur, were judged by staff as insufficient to meet the OAR requirement of a professionally prepared map of habitat for that species. The generalized maps of wildlife habitat sites created for the Goal 5 inventory were not based on specific habitat needs that have been scientifically documented for pileated woodpecker. Based on these conclusions, staff believes no further work is needed to address the June 8 Council motion. Even if a case could be made that the existing general habitat maps could be interpreted as showing pileated woodpecker habitat, this approach would not be not very defensible from a scientific standpoint. Staff believes that, given the tenuous nature of such a conclusion, and the potential for reasonable people to disagree on many aspects of the Oregon Administrative Rules, there are better approaches to address either pileated woodpecker habitat in the South Hills or upland wildlife habitat areas in the South Hills in general (see Option 3). Also, see attached memo for additional detail on existing data on pileated woodpeckers in the South Hills. If the council disagrees with the conclusions above, and believes that staff did err in 2003, this option would direct staff to review pileated woodpecker data and revise the inventory as part of the current Goal 5 process. This option would require notification of affected property owners and a public hearing before the Planning Commission prior to coming back to the council if additional areas are added to the inventory. This would mean that the current Goal 5 work would be stopped in order to include the additional habitat area. Not only would that leave important Goal 5 resources subject to additional degredation, it jeopardizes the timeline for compliance with periodic review. Periodic review for the Lane Metro area is a partnership between Eugene, Springfield and Lane County. Springfield is on approximately the same timeline for adoption measures as Eugene was prior to the June 8 action, and Lane County has already conducted public hearings before its Planning Commission. Delaying action would jeopardize the partner jurisdictions' ability to complete periodic review. Option 2 - Direct the City Manager to review and update the Goal 5 wildlife habitat inventory for the South Hills, after completion of the current Goal 5 work program, using the safe harbor inventory methodology in OAR 660-023-0110 in light of new information concerning the presence of the sensitive species Pileated Woodpecker in substantial areas of the South Hills. Description: If the council disagrees with staff findings related to the Safe Harbor criteria for sensitive species in 2003, this option would allow the current Goal 5 process to move forward, and upon completion of that work, move forward on the review of pileated woodpecker data. L:\CMO\2005 Council Agendas\M050627\S050627C.doc This approach would require notification of affected property owners and a public hearing before the Planning Commission prior to coming back to the council if additional areas are added to the inventory. This option would include developing a work plan and budget to complete this work. This option does not provide the most defensible mechanism for adding areas to the inventory (see discussion under Option 1) and it does not give information to address other habitat types or species that are found in the South Hills (see attached memo). Option 3 - Direct the City Manager to add to the Goal 5 Inventory, after completion of the current Goal 5 work program, the remainder of the wildlife habitat areas in the South Hills that were proposed to be included in the inventory by the Planning Commission in 2003. Description: This option would involve amending the June 8, 2005, motion to direct the City Manager to complete the current Goal 5 process, and upon its completion, to apply the standard process (instead of the safe harbor process) significance criteria to all upland wildlife habitat areas that were removed from the inventory, and to complete the Goal 5 process for these areas. This approach would require notification of affected property owners and a public hearing before the Planning Commission prior to coming back to the council. To collect site data that will provide a more defensible basis for Goal 5 recommendations, this option includes additional inventory work. This option would include developing a work plan and budget to complete this work, including: · Updating mapping of upland habitat in the South Hills in the areas being added to the Goal 5 inventory using the City's revised stream mapping, 2004 color aerial photography and field verification. · Conducting new inventory work delineating key habitat areas for the pileated woodpecker in the South Hills. · Conducting inventory and mapping of distinct upland wildlife habitats, including native upland prairie, oak woodland, oak savanna, mature/old growth grand fir, old growth Douglas fir and Ponderosa pine stands. · Conducting an inventory of known rare plant sites and potential rare plant habitat within all sites being added to the Goal 5 inventory (Aster vialis, Cimicifuga elata, Aster curtus, Erigeron decumbens var. decumbens, Horkelia congesta var. congesta, Lupinus sulphureus ssp. Kincaidii). · Providing public notice (direct mailings, display ads and legal ads) and public involvement (public workshops) related to the areas proposed to be added to the Goal 5 inventory. Option 4 - Amend the June 8, 2005, motion to add to the Goal 5 Inventory, after completion of the current Goal 5 work program, the remainder of the wildlife habitat areas that were proposed to be included in the inventory by the Planning Commission in 2003, within the Eugene Urban Growth Boundary. · Description: This option would involve amending the June 8, 2005, motion to direct the City Manager to complete the current Goal 5 process, and upon its completion, to apply the standard process (instead of the safe harbor process) significance criteria to all of the upland wildlife habitat areas that were removed from the inventory (not just those in the South Hills), and to complete the Goal 5 process for these areas. This approach would require notification of affected property owners and a public hearing before the Planning Commission prior to coming back to the council. To collect site data that will provide a L:\CMO\2005 Council Agendas\M050627\S050627C.doc more defensible basis for Goal 5 recommendations, this option includes additional inventory work. This option would include developing a work plan and budget to complete this work, including the same tasks listed under Option 3. CITY MANAGER'S RECOMMENDATION To ensure timely completion of Eugene's last remaining Periodic Review task (completion of Goal 5) and to hasten application of protection measures to important, valuable sites that warrant protection, the City Manager recommends that the council direct the City Manager to continue with the current Goal 5 inventory and complete the Goal 5 Periodic Review Work Program as quickly as possible. The City Manager recommends Option 3 above in order to provide a thorough, comprehensive, defensible approach to evaluating upland wildlife habitat in the south hills. This option allows the staff to consider many factors and species that can lead to a more holistic approach to natural resource protection. SUGGESTED MOTION Move to direct the CiO;Manager to complete the current Goal 5 Periodic Review Work Task per the tentative schedule outlined in this Agenda Item Summary, and to bring forward a recommendation to include as a high priority work program item to amend the Goal 5 inventory to apply the standard inventory process to those wildlife habitat areas in the South Hill; to which the Safe Harbor inventory provisions were applied in 2003 and to complete the Goal 5 ESEE (Economic Social Environmental Energy analysi,) process for those areas. The City Manager ,'hall also determine if outside resources are needed as part of this work and determine or recommend a funding mechanism to complete the work in a timely manner. ATTACHMENTS A. Memo from Planning and Development Department dated June 20, 2005 FOR MORE INFORMATION Staff Contact: Susan Muir, Acting in Capacity Planning and Development Director Telephone: 682-6077 Staff E-Mail: susan.l.muir~ci.eugene.or.us L:\CMO\2005 Council Agendas\M050627\S050627C.doc Planning & Development Planning City of Eugene 99 West 10th Avenue MEMORANDUM (541) 682-5377 (541) 682-5572 FAX www. ci.eugene.or, us Date: June 20, 2005 To: Mayor Piercy and City Council From: Neil Bj6rklund, 682-5507 Senior Planner Subject: Goal 5 and Habitat in the South Hills Introduction On June 8, 2005, the Council approved the following motion: Council Motion: Ms. Taylor, seconded by Mr. Kelly, moved to direct the City Manager to review and update the Goal 5 wildlife habitat inventory for the south hills, using the safe harbor inventory methodology in OAR 660-023-0110 in light of new information concerning the presence of the sensitive species Pileated Woodpecker in substantial areas of the south hills. The vote on the motion was a 4:4 tie; Ms. Taylor, Mr. Kelly, Ms. Bettman, and Ms. Ortiz voting yes; Mr. Papd, Mr. Poling, Ms. Solomon, and Mr. Pryor voting no; Mayor Piercy cast a vote in support of the motion and it passed on a final vote of 5:4. This memo discusses the technical and process issues related to this motion. The June 8, 2005 Council motion related to Eugene's Goal 5 inventory refers to the adoption of the riparian and upland wildlife habitat inventories by the Eugene City Council in July 2003. The Eugene Planning Commission had recommended that the Council adopt the entire preliminary inventory, applying the %tandard" inventory process to all sites, including large areas of the South Hills. The standard process involves applying locally adopted significance criteria to determine which mapped resource sites will be further studied and considered for protection. The %afe harbor process" is a simpler, alternative approach, in which the local jurisdiction includes on the inventory only the specifically listed resources that are already mapped by state or federal agencies or by qualified professionals. At that time, the Council voted to apply the Goal 5 %afe harbor" inventory process to the areas in the South Hills outside of mapped stream corridors, and to apply the Goal 5 %tandard" inventory process to the remainder of the inventory recommended by the Planning Commission. Application of Goal 5 Safe Harbor Provisions in 2003 During City Council work sessions on Goal 5 on May 28, 2003 and June 23 2003, members of the Council raised the idea of using Goal 5 %afe harbor" provisions for the riparian and upland wildlife habitat inventories. The Council discussed applying safe harbor inventory provisions to all sites, which would have reduced the number of sites on the inventory, including riparian sites. The Council also discussed a %plit" approach of applying standard process inventory provisions to waterways, and safe harbor provisions to non-waterway upland areas on the draft inventory. At that time, staff reported back to the Council that application of the safe harbor inventory criteria for wildlife habitat sites to the areas outside waterway corridors in the South Hills would effectively remove those areas from further consideration for protection, as those areas did not meet the safe harbor criteria. The "Safe Harbor" provisions under Goal 5 provide a different methodology for local governments to meet the Goal 5 requirements with less staff work and process than is required in the "standard" Goal 5 process. The Safe Harbor provisions for the Goal 5 inventory process set out specific criteria for determining which sites will be considered significant, and rely on resources that are already mapped by state or federal resource agencies or other qualified professionals. The safe harbor provisions rely on existing inventory mapping and data in order to reduce the burden on local governments for conducting Goal 5 inventories. The "standard" inventory process, on the other hand, allows the local jurisdiction to create and adopt their own criteria for significance, and requires more detailed analysis. The sites that are considered "significant" under Goal 5 are those that will be considered for protection measures. Safe Harbor Inventory Criteria for wildlife habitat (OAR 660-023-0110(4) are as follows: "(4) Local governments may determine wildlife habitat significance under OAR 660-023-0040 or apply the safe harbor criteria in this section. Under the safe harbor, local governments may determine that "wildlife" does not include fish, and that significant wildlife habitat is only those sites where one or more of the following conditions exist: (a) The habitat has been documented to perform a life support function for a wildlife species listed by the federal government as a threatened or endangered species or by the state of Oregon as a threatened, endangered, or sensitive species; (b) The habitat has documented occurrences of more than incidental use by a species described in subsection (a) of this section; (emphasis added) (c) The habitat has been documented as a sensitive bird nesting, roosting, or watering resource site for osprey or great blue herons pursuant to ORS 527.710 (Oregon Forest Practices Act) and OAR 629-024-0700 (Forest Practices Rules); (d) The habitat has been documented to be essential to achieving policies or population objectives specified in a wildlife species management plan adopted by the Oregon Fish and Wildlife Commission pursuant to ORS Chapter 496; or (e) The area is identified and mapped by ODFW as habitat for a wildlife species of concern and/or as a habitat of concern (e.g., big game winter range and migration corridors, golden eagle and prairie falcon nest sites, or pigeon springs)." The term "documented" as applied in this subsection is defined at OAR 660-023-0110(1)(a): "Documented" means that an area is shown on a map published or issued by a state or federal agency or by a professional with demonstrated expertise in habitat identification. Criterion (4)(b) is the focus of the issue raised before the Council and which the Council motion addresses. In order for an area of land to meet the requirements of OAR 660-023-0110(4)(b), one of two forms of documentation was needed, either: (1) the area was shown on a map of habitat with "documented occurrences of more than incidental use" by pileated woodpeckers issued by a state or federal agency, or (2) the area was shown on a map of habitat with "documented occurrences of more than incidental use" by pileated woodpecker issued by a professional with demonstrated expertise in 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 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. 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.