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• <br /> • <br /> ',EUGENE Public Works <br /> Maintenance <br /> 1820 Roosevelt Boulevard <br /> December 9, 1994 Eugene,Oregon 97402 <br /> (503)687-5220 <br /> John F. McMillan <br /> Operations Division <br /> Department of the Army <br /> Portland District,Corps of Engineers <br /> P.O. Box 2946 <br /> Portland, OR 97208-2946 <br /> This letter is in response to Kenneth H. Patterson's letter of September 8, 1994, soliciting the <br /> City's comments and concerns related to the Corps' 1993 "Interim Guidelines for Selective <br /> Vegetation Maintenance on Flood Control Levees." I would like to express the City's <br /> appreciation of the initiative and effort the Corps has undertaken in developing these new <br /> guidelines and wish to thank you for the opportunity to provide our input for your review. The <br /> comments and concerns set forth in this letter are made on behalf of the City of Eugene as a <br /> whole and express the views of internal staff as well as those of a number of concerned citizens. <br /> Background <br /> The City's interest and concern regarding these interim guidelines relate to our responsibility for <br /> maintaining Amazon Creek, a federally funded flood control project. As the local sponsor,the <br /> City of Eugene performs routine vegetation management and sedimentation control activities <br /> along the approximately 13 miles of the Amazon project. This is done to comply with our <br /> maintenance agreement with the Army Corps of Engineers to preserve the flood control intent of <br /> this channelized creek. Our maintenance efforts also provide for site access, improve visual <br /> clearance for inspections, help curtail the intrusion of non-native plant species,and reduce public <br /> complaints regarding obnoxious vegetation and possible fire hazards. <br /> In response to federal and state regulations and/or mandates related to the protection of wetlands <br /> and stormwater quality,the City recently adopted a West Eugene Wetlands Plan and a <br /> Comprehensive Stormwater Management Plan. In addition, the City has participated in the <br /> development of a metropolitan-wide Natural Resources Functional Plan and is in the process of <br /> adopting a number of local natural resource protection ordinances. The goals and policies <br /> embodied in these plans as well as the intent of the proposed ordinances are to promote the <br /> management of natural drainages and the stormwater system in a manner that addresses the <br /> multiple objectives of flood control, water quality enhancement, and natural resource protection. <br /> This has rrecegsitated the City's Maintenance Division to review and, where necessary, revise our <br /> existing operations and maintenance practices with regard to natural drainages as well as flood <br /> control charnels. <br /> The City is currently involved with the Corps of Engineers on two projects that are intended to <br /> enhance water quality and wildlife habitat in the lower Amazon Creek. The first of these,to <br /> restore approximately 1.2 miles of the Amazon within the West Eugene Wetlands, is part of a <br />