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, <br /> • "Potential Concern" list by DEQ from mouth to headwaters for the following parameters; <br /> toxics, pesticides, metals, and phthalates. The DEQ has indicated it will seek follow-up . j ; ,, <br /> data to verify their assessment of streams with a Potential Concern status. When all <br /> available data is submitted to DEQ, it will almost certainly result in Amazon Creek being <br /> placed on the updated Section 303(d) list for some or all of the above parameters. <br /> For listed streams, anthropogenic sources of pollution that would contribute to further <br /> • <br /> declines in water quality for the listed parameters would be a violation of the Clean Water <br /> Act. The 303(d) list is viewed as a way to identify problems and develop and implement <br /> watershed recovery plans to protect beneficial uses while achieving federal and state water <br /> quality standards. Agencies with jurisdiction over 303(d) listed streams are required to <br /> produce water quality management plans to achieve the water quality standards. <br /> Development of this sensitive headwater area would be another incremental step <br /> significantly contributing to the further degradation of water quality and aquatic habitat <br /> within the headwaters of Amazon Creek and would contribute to adverse effects along the x <br /> entire length of this stream. <br /> If this area is developed it would contribute to the further degradation of Amazon Creek <br /> by adversely affecting to both water quality and water quantity. The proposed <br /> development area has many important hydrologic functions. Forested areas like those <br /> currently found in the Amazon headwaters area can be thought of as acting like a sponge. <br /> These areas are important for slowing the rate of runoff during storm events and retaining <br /> water for release during low stream flow periods. Several streams tributary to Amazon NJ <br /> Creek flow through the area and important wetland habitat exists during winter months. If <br /> this area is developed, the amount of soil surface permeable to rainwater would be <br /> reduced. Storm runoff would quickly be routed over paved and otherwise hardened <br /> surfaces into Amazon Creek. This will cause higher winter flows and will result in more <br /> downstream bank erosion. The downstream erosion will further degrade water quality. In <br /> addition, Army Corps of Engineers and the City of Eugene manages Amazon Creek for <br /> flood control. Efforts to keep the channel free of debris are conducted each year for fear <br /> • <br /> that Amazon Creek will not be able to contain winter flows. An increase in winter flows <br /> would further exasperate these problems. Changing hydrologic conditions on the wet 3 <br /> steep soils of the area may also aggravate landslide and soil movement. If this property <br /> were to be developed, the important functions of streamside areas and wetlands will be <br /> severely impacted. Development would result in lower summer stream flow when water <br /> quality concerns for parameters such as temperature and dissolved oxygen would be <br /> greatest. <br /> Many restoration efforts have and continue to occur along Amazon Creek. Including large <br /> expensive restoration effort just downstream from the headwaters. The City of Eugene <br /> has developed the Stream Team Program where many volunteers throughout the <br /> community work on restoration projects along Amazon Creek. This program has been <br /> very successful in educating local residents about the importance of water quality and <br /> healthy stream channels. I am outraged that money, time and energy will continue to be <br /> spent on downstream restoration projects while the headwaters that contain the best <br /> 2 <br />