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• <br /> Corps of Engineers program to replace habitat lost as a result of the channelization of the creek. <br /> The City's role is that of the local sponsor. Currently in the feasibility study phase, the Corps' <br /> preferred alternative will be to remove existing dikes and levees along this stretch and restore the <br /> hydrology to the surrounding wetland areas. <br /> The second of these two projects,currently in the design phase, is the Amazon Creek <br /> Enhancement project. Funded by grants obtained through the Intermodal Surface Transportation <br /> Enhancement Act,the goals of this project are to extend the bike path and to widen or otherwise <br /> enhance water quality and habitat values along approximately 2.4 miles of Amazon Creek. The <br /> City has solicited the participation of staff from the U.S. Fish and Wildlife Service, the Oregon <br /> Department of Fish and Wildlife,the Bureau of Land Management,the Oregon Division of State <br /> Lands,the Department of Environmental Quality, and the U.S. Army Corps of Engineers in <br /> developing the conceptual design for enhancing this stretch of the creek. <br /> Concerns Regarding Existing Guidelines <br /> We view these guidelines as a positive step by the Corps to ensure that the environment becomes <br /> an integral part of their engineering ethic. The guidelines make a good first attempt at striking a <br /> balance between environmental concerns and the need to ensure the structural integrity of flood <br /> control facilities. The following comments address both our concerns with the general <br /> vegetation management policy exemplified by these guidelines and with their ability to achieve <br /> the desired balance between these competing objectives. <br /> I. Amazon Creek and the adjacent wetlands fall under the jurisdiction of several federal and <br /> state regulatory agencies with respect to management of flood control,water quality, wildlife, <br /> and resource protection. Primary among these is the Army Corps of Engineers,whose <br /> Operations Division has responsibility for regulating wetland development as well as <br /> management of the federally funded Amazon flood control project. Also, as mentioned <br /> previously, the Corps' Planning and Engineering Division is currently involved with the City on <br /> two environmental restoration projects to enhance water quality and wildlife habitat values along <br /> lower Amazon Creek. Due to differences in the focus and management perspective of these <br /> divisions, there are inherent conflicts between the goals and objectives each promotes for <br /> managing areas under the Corps'jurisdiction. <br /> It is difficult for us as a municipality to balance these conflicting regulatory requirements and <br /> restoration goals established by the various divisions and branches of the Corps. While <br /> attempting to minimize vegetation to preserve flood capacity,we are simultaneously attempting <br /> to find ways to maximize native vegetation to improve water quality and enhance wildlife <br /> habitat. It would greatly enhance the City's ability to plan for and achieve a multiple objective <br /> approach i m aging Amazon Creek if the separate divisions and branches within the Corps <br /> worked more closely in developing consistent criteria and guidelines for managing vegetation <br /> and wildlife habitat along levees and flood control works. <br /> 2 <br />