Letter sent by Rebekah Phillips, Mazama Executive Director on behalf of the Mazamas to Morgan Steele, City of Portland Environmental City Planner
Dear Ms. Steele,
Established in 1894 on the summit of Mt. Hood, the Mazamas is an Oregon-based 501(c)3 with a proud tradition of providing excellence in climbing education, leadership, and conservation in the Pacific Northwest. Our mission – to build a community that inspires everyone to love and protect the mountains – is carried out in partnership with more than 300 highly dedicated volunteers through education programs, climbs and hikes, stewardship activities, and scientific research. Current membership includes about 3,000 individuals.
Many Mazama members have been involved with Portland’s Forest Park from the beginnings of the park in 1946; in fact, many of the original committee of 50 that urged the city to make this area a city park were Mazama members, including the founder and chair of this committee, Ding Cannon. Our roots run deep with Forest Park, and we continue today to host many of our local outdoor activities in the park.
We are deeply concerned with PGE’s revised land-use application in the north end of the park, which proposes to clear cut 4.7 acres of 150+ year old Douglas fir and bigleaf maple trees and proposes to remove five white oak trees estimated to be 170-500 years old. In total, the proposal includes the removal of 376 living trees and 21 dead trees. It will permanently fill at least two wetlands and disrupt two streams that support multiple species of aquatic wildlife.
According to PGE, Phase 5 of this project may impact another 15 acres of Forest Park to the northwest and west potentially disrupting the Miller Creek watershed which contains salmon habitat. Should Phase 3 be approved, it will pave the way to Phase 5 as the “least expensive” alternative.
This area of land lies within the City’s Environmental Conservation and Environmental Protection overlay zones, and also within the City’s Forest Park Natural Resources Management Plan (FPNRMP). Legally, PGE must comply with this plan unless they can prove that there is no alternative to meet their obligation to provide reliable power. We are not convinced that PGE has investigated alternatives, nor have they been forthcoming with convincing information that they have tried to do so. Such information was requested as far back as 2022, and although a report on this was delivered to PGE by a private consultant at that time, it was not made available until a few weeks ago. Now PGE has released the report after withholding this information from the public for two years, and is requesting urgency on this matter to be decided.
As documented in the City of Portland’s 2012 Forest Park Wildlife Report, the northern area of Forest Park is home to over 200 species of interest, either listed, candidate, sensitive, or of concern at the State and Federal level. It is rich in wildlife structural diversity including larger trees, standing snags, and native understory. One of the streams that would be denuded is habitat for the northern red-legged frog, an at-risk species as noted in the Special Status and At-Risk Species List prepared by the City of Portland in 2022.
Ecological impact on the protected area of Forest Park would not be restricted to the area targeted for clear-cut. The edges of this pristine coniferous forest would be susceptible to plant invasions (ivy, blackberry, garlic mustard and others) that degrade forest health and limit diversity of species supported by the Park, tree blow-down from storms, land-slides, temperature increases which can weaken the forest making trees susceptible to insect and disease invasions. The slopes in this area of the Park are extremely steep, as documented in the Toth report, making this landscape prone to landslides when vegetation is removed.
Mitigation is not a solution for the environmental impact caused by power lines. Once a corridor is widened or opened, it is continually maintained in a manner that does not resemble the original natural state of the land. Proposing that this can somehow be compensated by improving other areas is ludicrous.
There are two more phases that PGE wants to follow up with. If this proposal is approved, against the overlay zones and long-ago approved FPNRMP, it will become a slippery slope – there would be an expectation that the following two phases could also be approved, incrementally increasing total impact to the north end of the park.
On behalf of the Mazama Board of Directors, Conservation Committee, and membership, I urge the City of Portland to reject this proposal.
Sincerely,
Rebekah Phillips
Executive Director