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• <br /> • <br /> 2. Our second concern is that these guidelines do not provide enough flexibility for allowing <br /> local sponsors and the Corps' inspectors to allow increased vegetation and habitat in those areas <br /> of a project where flooding poses little or no threat to either life or improved property. To quote <br /> from the policy set forth within these guidelines, "It is the policy of the Portland District, U.S. <br /> Army Corps of Engineers to assure that flood control facilities are maintained and enhance the <br /> environmental values of levees consistent with the primary purpose of protecting lives and <br /> improved property from being damaged by flooding." Although,we agree with this policy, we <br /> would also agree that the various projects covered by these guidelines have relative levels of <br /> importance in the control of flooding and the protection of property. In comparison to the levee <br /> of the Columbia River for example,the channelized Amazon Creek is a relatively minor flood <br /> control facility. <br /> Within west Eugene,the lower Amazon flows through a large tract of undeveloped wetland <br /> designated for protection and/or enhancement under the West Eugene Wetlands Plan. Already, a <br /> number of properties in this tract are under the ownership of the City or the Bureau of Land <br /> Management, one of the City's wetland partners. The threat that flooding may pose to life and <br /> improved property in these areas is relatively minor compared to other areas along the Amazon. <br /> This is illustrated by the fact that the Planning and Engineering Division of the Corps is currently <br /> studying the feasibility of removing the dikes along one such stretch in order to restore the <br /> hydrology to the surrounding wetland areas. <br /> Although we realize these guidelines are intended to cover all levee projects under the <br /> jurisdiction of the Corps, we would like to see provisions made to allow greater flexibility in <br /> their application by the Corps' inspectors and the local sponsoring agencies. <br /> 3. One of the more frequent public complaints the City of Eugene receives when performing <br /> vegetation maintenance along the Amazon is that we are negatively impacting wildlife habit and <br /> posing a threat to rare and endangered species. We have attempted to address this concern by <br /> enlisting volunteers and utilizing manual removal methods in order to minimize any negative <br /> impacts caused by the use of mechanized equipment. Although these efforts have helped reduce <br /> the frequency of these complaints, they do not resolve the inherent conflict between the removal <br /> of vegetation for flood control purposes and the destruction of habitat necessary for protecting <br /> rare and endangered species. <br /> The Oregon Department of Fish and Wildlife is currently monitoring a population of Western <br /> Pond Turtles inhabiting lower Amazon Creek within the West Eugene Wetlands. It is very <br /> difficult for the City to achieve a level of vegetation maintenance along this stretch of the <br /> Amazon tjiat.tneets the Corps' maintenance guidelines and yet satisfies requirements for <br /> protecting necessary habitat for the turtles. Often,the suggestions and recommendations we have <br /> received fr'Tfish and wildlife biologists and consultants are in direct conflict with the Corps' <br /> guidelines. <br /> 3 <br />