Big power, small fly

PGE must justify 5-acre clearcut through Forest Park

Portland General Electric plans to clear a five-acre swath in Forest Park near Linnton to erect transmission towers.

It’s called the Harborton Reliability Project and involves clear-cutting trees and shrubs on a slope beginning near Highway 30 stretching about 250 feet wide and 1,000 feet long. Reliability, in industry terms, has to do with the uninterrupted flow of electricity, but PGE publicly justifies the project as needed to meet generally increasing demand for power.

Critics say it will despoil the forest and its living systems perhaps irreversibly.

An application was filed with the city of Portland on May 10, triggering a process that could lead to approval as soon as August. A 103-day timetable begins when the Bureau of Development Services deems the application to be complete, which it had not done when this edition went to press.

That is the first of several hurdles, which include compliance with city codes and policy plans, including an environmental conservation district, the Northwest Hills Plan District and the Forest Park Natural Resources Management Plan. Because the project does not conform to underlying zoning, it must mitigate negative impacts introduced to the area.

Seven city bureaus responded to a preliminary form of the proposal submitted two years ago, each outlining specific standards that must be met. Nothing on these checklists would likely have come as a surprise to PGE experts and attorneys.

PGE is well aware that nearby wetlands are home to red-legged frogs, made famous by scores of volunteers who hand-collect the frogs in the middle of the night to carry them across the highway to their spawning grounds, a project called the Harborton Frog Ferry.

One thing PGE may not have bargained for is an even smaller and more vulnerable species, a rare 1-inch stonefly observed in Forest Park in about 2012.

Rob Lee, a Linnton Neighborhood Association activist who spearheads the Harborton Frog Ferry, tells a story that might complicate things:

About a dozen years ago, I took a walk in the park with my brother Jon, who's a stonefly/caddisfly expert. He can tell a lot about an ecology by the bugs in it. He lives in Eureka, Calif., and visits me occasionally in pursuit of new species of stonefly and caddis fly.

I'd wanted him to look in the park, which is right behind where I live, but second-growth forest doesn't interest him much. Then one day he surprised me and suggested we take a walk above my place.

He sampled in four places.. … Then, he beat the bushes up along the two southernmost tributaries of South Miller Creek, coming back down from each tributary with a very large stonefly, [which he identified as] Megaleuctra kincaidi Frisson, 1942.

We continued the walk, until we got to Marine Way Creek, where it crosses Newton Road. He went up that little creek and came down with another Megaleuctra.

The last time this insect was identified around here was in 1937 between St. Helens and Vernonia. It's not only a very rare insect, it requires pristine habitat and clean water.

I'd be willing to bet the upper reaches of Harborton Creek are likely habitat of this quality, the point being that PGE may very well want to despoil some of the finest habitat, not only in Forest Park, but in the whole vicinity.

Jon Lee confirms the story.

“I’m glad Rob has a good memory,” he said, “as I was concerned he didn’t remember we collected Megaleuctra at two separate areas. I hope my comments don’t make it too scientific, but here they are.”

Regarding their requirement of pristine conditions: “I know they need cold springs/seeps with good water quality,” he said. “I saw in Washington that it is a Species of Greatest Conservation Need.”

That classification is part of nationwide system in which each state develops a State Wildlife Action Plan to conserve wildlife and habitat before they become too rare or costly to restore. SGCN-classified species include both those with and without legal protection status under the Federal or State Endangered Species programs.

Will any of this matter as PGE seeks approval to deforest the land and erect transmission towers?

The Harborton Reliability Project would not be covered by the National Environmental Protection Act or need to produce an Environmental Impact Statement unless it receives substantial federal funding, which PGE says it will not.

That means Portland land-use law will determine the result.

The Bureau of Development Services warned the company that it would have to do better than its 2022 preliminary submission.

“The Environmental Protection Zone provides the highest level of protection to the most important resources and functional values,” wrote senior environmental planner Morgan Steele of the Bureau of Development Services.

“The current proposal does not appear to meet applicable approval criteria based on its impacts to high-value resources and their functional values. Staff encourages the applicant to explore alternative locations (including and, most important, outside Forest Park), layouts, corridors and construction methods that do not require the clearing of six acres of pristine upland forest habitat.”

“Removal of trees, impacts to waterbodies/wetlands and disturbance of soil within the Natural Resources Master Plan must be mitigated. Mitigation must fully compensate for any long-term adverse impacts of the proposed action on resources and functional values. The area of impacts is currently a pristine, upland forest habitat which houses eagle nests, streams and mature trees, and provides habitat for several other wildlife species. Currently, the scale of impact may be too large to successfully mitigate, given the value of the resources in the project area.”

PGE spokesperson Andrea Platt acknowledged that the 2022 plan received “frank” feedback, which was accounted for in the revised plan submitted last month.

The area to be cleared has been reduced from six acres to five, the number of transmission towers reduced to three and a safe migration path for the frogs will be presented, Platt said.

“This project needs to happen, with construction beginning in 2025 and in 2026 for Phase III,” Platt said.

The five-phase project would seem to necessitate similarly broad clearings to come for the extension of the transmission line from where Phase II ends in the heart of the park.

Forest Park Conservancy is a nonprofit funded by the city of Portland and receiving grants from PGE. Its executive director, Marianne Wilburn, posted a newsletter report on the Harborton project in April.

“Earlier this year, our staff toured the site and remarked upon the remarkable forest habitat in that region, as well as the existing blackberry cover underneath the already existing power lines owned by the Bonneville Power Administration that run through Forest Park. The area of the proposed project features rich plant diversity and streams frequented by native wildlife, all of which could be greatly disturbed, if not outright removed, by a project cutting acres of forest.”

“Forest Park Conservancy is deeply concerned about the potential impact of PGE’s proposed work in the northeastern part of Forest Park. … This area is rich in wildlife diversity and larger trees, and has a stream running through it where the northern red-legged frog, an at-risk species as noted in the Special Status and At-Risk Species List 2022 Preliminary Update Report prepared by Environmental Services, has been observed.

“FPC wants to see alternatives presented by PGE—where else can this work be done? Additionally, we would like to see why this site is being favored over these alternatives and how PGE proposes to minimize their impacts in Forest Park.”