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HomeMy WebLinkAboutG-515 Reid 08-02-2023 4959 Oakridge Rd. Lake Oswego, OR 97035 8/1/2023 Planning & Building Services Dept. City of Lake Oswego P.O. Box 369 380 "A" Ave. Lake Oswego, OR 97034 Attn: Ellen Davis, AICP. Associate Planner Re: Comments on LU 23-0002 Dear Ms. Davis: I submit for the public record the following comments regarding application LU 23-0002. (1) The decision to route a sewer line extension through the wetlands of West Waluga Park seems somewhat perfunctory. It fails to recognize the primary importance of wetlands, and the City's responsibility to protect designated wetlands. Instead a variety of statutes and exemptions to wetland protections are used to justify the proposed sewer route as "unavoidable". The applicant's report mentions an existing sewer line along Baliene St. to the west between Parker Rd. and Kimball St., as well a sewer line on Inverurie Rd. Upgrading and utilizing either of these options would appear to impact significantly less wetland area, and potentially none of the West Waluga wetland. In addition it seems like the cost to connect to and upgrade those alternatives would be less than the proposed alignment through West Waluga Park. One wonders if the City's long range planning for utility development necessarily includes running a sewer line through the West Waluga wetland. (2) The discussion of mitigation for wetland disturbance is troublesome. The vegetative restoration plan is commendable, however it seems at odds with the requirement of maintenance and inspection of the proposed sewer line through the wetland. The presence of multiple manholes or sewer cleanouts would seem to indicate that there will be permanent access through the wetland. Such a road would not meet the requirements for full mitigation of the temporary construction impacts. All mitigation should occur onsite and constitute complete restoration. In summary, I believe the City should recognize the high value of the West Waluga park wetland. Priority should be given to its preservation. Alternatives to the sewer line development proposed in LU 23-0002 should be seriously investigated. Mitigation for any wetland disturbance should be 100%, and on-site. Sincerely, //4tj Ian J. Reid