DTA Submits Public Comment on WWSP Permit Application
On April 30, 2021, DTA submitted a public comment on the Willamette Water Supply Program’s request for a major modification to USACE permit #NWP-2015-0041and DSL permit #60102-RF submitted by the Tualatin Valley Water District based on the ecological impacts of the proposed modifications.
Relying on a Biological Opinion issued in 2018, the applicant asserts that the proposed modifications provide environmental and seismic resilience advantages. However, the proposed modifications - including among other changes an entirely new route - are significantly different than the previously permitted project. The impacts of such changes have not been evaluated in a manner sufficient to understand the potential impacts of the project on listed species as required by the Endangered Species Act.
Considering the volume and nature of the proposed work, the inherent risks of manipulating soils and aquatic resources, and the increasing concerns over the well-being of treasured flora and fauna, a thorough analysis to ensure that proposed activities will not jeopardize any endangered or threatened species nor result in adverse modification of critical habitat is essential. Regardless of the specific construction method selected, the installation of a pipeline up to 66 inches in diameter poses significant risks to wildlife. Removal of vegetation including large trees, increased sedimentation, and other pollutants, as well as increased noise pollution are extremely concerning in a context where species are already under heightened pressure to climate change and other compounding human induced factors.
The ecological value and potential presence of listed species in areas not previously considered in the 2018 Biological Opinion may have been underestimated. The upland and riparian areas in and around the Fanno Creek Watershed where the MPE_1.0 route change would occur is known by residents to be home to a broad spectrum of plant and animal species including many migratory birds. While the area is developed and various levels of degradation have occurred over time, new construction is rare and well-established landscapes are common. As such, mature trees provide ideal habitat for birds, squirrels, and many other species. A noticeable abundance of frogs, bats, beavers, and waterfowl are frequently observed in and around Fanno Creek and surrounding wetlands. The extent and quality of available habitats have been further enhanced by the recent expansion of the Portland Audubon’s Backyard Habitat Program in the City of Beaverton and unincorporated Washington County.
The proposed site for the receiving shaft to be installed on SW Mary Lane adjacent to the Upper Fanno Creek Crossing is in close proximity to several large trees including one believed to be Giant Sequoia (Sequoiadendron giganteum); a species classified as Endangered by the IUCN due to regeneration challenges. Root systems of this Giant Sequoia are known to grow near the surface of the ground in every direction for 100 feet or more (see National Park Service, 2017). Therefore, adverse effects associated with the installation of a pipeline are not unreasonable. Nonetheless, it is unclear whether the direct and indirect impacts of the project on these trees and this ecosystem in their absence have been considered.
On April 21, 2021, DTA submitted a formal request for documents prepared for, or used in determining the impacts of the Willamette Water Supply Program and the proposed modifications on listed species or critical habitats.