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b. Any planned wetland losses shall be fully offset by creation, restoration, or <br /> enhancement of wetland functions and values or in an estuarine area, estuarine resource <br /> replacement is consistent with ORS 196.830. <br /> The Plan allows needed development by requiring mitigation for anticipated wetland <br /> losses in a planned manner (Chapter 4). Wetland resource losses are allowed to be <br /> replaced by different types according to ratios that vary according to mitigation action <br /> (restoration or enhancement) and wetland type (Table 1). The Plan's proposed actions <br /> maintain full compensation of planned wetland losses caused by fill, resulting in a net <br /> overall gain of 100 -300 acres of wetland. Overall, there is a net gain of wetland functions <br /> in the plan area. A Mitigation Manual has been prepared that provides detailed <br /> altemative approaches for restoring or enhancing the wetland system. <br /> c. Practicable, less damaging alternatives, including alternative locations for the <br /> proposed use are not available. <br /> The evaluation of practicable alternatives requires a review of the City's <br /> acknowledged comprehensive plan, evaluation of public need (as defined in the <br /> comprehensive plan), a determination that wetland losses will be fully offset, and <br /> availability of altemative uses. <br /> The following analyzes first alternatives to the development scenario proposed by <br /> the Plan, then addresses site - specific alternatives. <br /> Simply avoiding development in all wetland areas would be impracticable because it <br /> would create pressure to develop to the edge of each wetland. The result would be <br /> wetlands isolated between industrial development without buffers or connections. <br /> Although this option would retain wetland area, it would result in a significant loss of <br /> wetland functions and values and increased fragmentation of the resource. <br /> Development under existing federal permitting standards alone would allow fills of <br /> isolated or "headwaters" wetlands without federal review and, for fills requiring individual <br /> permits, would be subject to EPA Region X policy preferring on -site, in -kind mitigation. <br /> Under this alternative, the future development or protection of any wetland areas would <br /> be unplanned and subject to individual desires. <br /> Permits have been issued for the development of a portion of sites C3a, and C5. <br /> These projects account for 16.9 acres of wetland. Mitigation has been required for the <br /> projects in general accordance with the plan. This approval does not affect the terms <br /> and conditions of the permits issued by the Division. <br /> Permit applications have been received for sites C6g, A4a, A4e, and A4h. These <br /> applications account for an impact of approximately 5.9 acres of wetland. On -site <br /> mitigation has been proposed for each project in a manner consistent with the Plan. <br /> Approval of the Plan does not affect the permit applications for these projects. <br /> Fill sites E2d, E2c, E2b, and E2a will be impacted by the first phase of the West <br /> Eugene Parkway project. An individual permit application will be submitted for this <br /> project by the Oregon Department of Transportation. Fill sites A5, Al a, A2a, Alb, A4a, <br /> A2d, A4d, A4e, A4f, C3a, and C3b are development sites for the west phase of the <br /> project. The Oregon Department of Transportation is evaluating alternatives to impacting <br /> these wetland sites. The impact of the West Eugene Parkway Project ranges from 32.2 <br /> to 37.8 acres of impact. Approval of fill for these sites will not be authorized by approval <br /> of the Plan. An individual permit application will be required for the selected alignment. <br /> . .. <br /> Page 7 - PROPOSED ORDER AND CONDITIONS - City of Eugene <br />