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From: Stephanie Stewart [mailto:
[email protected]] Sent: Sunday, February 09, 2014 11:24 PM To: Commissioner Fritz; Commissioner Fish Cc: Bizeau, Tom; Schmanski, Sonia Subject: MTNA request regarding Tabor disconnect LU application Via email Feb 10, 2014 Dear Commissioners Fritz and Fish, The Mt. Tabor Neighborhood Association writes to express multiple concerns about the applications # LU 13-‐ 236792 and 13-‐240530 dated Jan 24, 2014 (one joint notice, which arrived Jan 28). We respectfully request that you direct the Water Bureau (PWB) and the Bureau of Development Services (BDS) to extend the comment period until at least March 30th. Citizens have been given a notably short comment period (just 13 business days, 10 if you adjust for storm related closures) for two complicated land use reviews (Historic Resources and Environmental) tied to a project with major implications for our local environment. Water Bureau failed to present detailed plans regarding these projects to any of the impacted neighborhood associations at our monthly meetings. Nor did Water Bureau contact other community stakeholders who have worked on preservation of the reservoirs for many years. The allotted comment period falls between monthly meetings, the customary venue at which the public expects to hear about and weigh in on issues such as these. In 2006, before beginning the reservoir upgrade projects at Tabor and Washington Park, there was public notice of the Water Bureau's pre-‐application meeting at the Bureau of Development Services where questions could be answered. Subsequently two meetings were held before the Water Bureau submitted their application. Today, the Bureau is less transparent proceeding with more significant land use impacts. Permanently disconnecting reservoirs from all water sources Water Bureau proposes to disconnect the open reservoirs from the supply system while also ceasing all flows between reservoirs. This proposal leaves these reservoirs without any water source at all, which is in direct conflict with their stated historic value (as City-‐Beautiful, deep-‐water vistas), the community's last "what goes on top" design process directive (which called for water features), and a protected scenic view corridor. The Water Bureau proposes no mitigation for the degradation that will occur as a result of this move. As these deep-‐water reservoirs are 1) the central design feature of Mt Tabor Park, created by landscape architect Olmsted, 2) listed on the National Historic Register which specifically calls out their place in the historic City-‐Beautiful movement, because designers intentionally chose to build deep-‐water, open reservoirs at these specific locations for their visual effects, and 3) a prominent part of one protected view corridor which specifically cites the water within these reservoirs, …we believe the construction decisions outlined in these land use reviews deserve a great deal more public input. Water Bureau's proposal will destroy protected historic aspects of these reservoirs, in defiance of one of historic preservation's most important ethics: reversibility. The approach proposed in the plans accompanying these land use reviews is not reversible, and it will not leave the underlying historic structure well maintained and intact, as is required by the protections offered to structures with preservation status. These structures will degrade exponentially without a water source. We may not use these structures to house our drinking water, but we do have a responsibility toward their historic preservation. It does not make economic sense to knowingly, degrade historic structures on which taxpayers recently spent millions of dollars so as to insure another 50, healthy years of life. We've been responsible stewards with these investments, let us continue to be so in this new phase of the reservoirs' life. Water Bureau consultant Rob Dortignacq, in his "Mt Tabor Reservoirs Historic Structures Report" dated
May of 2009, concluded that these assets, being in good condition, would have a predicted life of 50 or more years if maintained. City rules under FIN -‐ 6.11 Capital Assets require of the City that they must maintain Capital Assets in good working condition. The Water Bureau's plan to allow the historic structures/reservoirs to degrade is not compatible with the requirement that these assets be maintained. Conclusion Please direct the applicant to extend the public comment period until at least March 30 so recognized organizations enumerated in Title 33.910 can weigh in once they have all the necessary information to do so. In the next few years of reservoir decisions, transparency will benefit all. The appearance of a rushed-‐push at this point will at the very least inflame antagonism towards current governance, and at worst actually allow poorly thought out construction plans to be executed. Thank you, Stephanie Stewart MTNA land use chair ……………………………………. From: "Bizeau, Tom" Date: Monday, February 10, 2014 at 10:57 AM To: Stephanie Stewart Subject: RE: MTNA request regarding Tabor disconnect LU application Stephanie, Thanks for the information on the recent application. We had no knowledge of the application but it appears to be a requirement associated with the LT2 directives. You know where our Commissioner has taken a stand on these issues in the past and has had little success with altering the chain of events leading up to this application. It is my understanding that there are not easy alternatives to keeping water in the reservoirs and meeting the disconnect requirements of LT2. It would be good to explore those alternatives if they exist but Commissioner Fritz and Commissioner Fish have indicated that a public process for the reservoirs cannot occur until after the vote for a Water District has been decided. Mean while the requirements for LT2 continue. From our vantage point, we are not able to stop an application in process, public or private. The applicant can however choose to extend the timeline and provide more public input if they wish, beyond the minimum required in the law. The applicant in this case is the Water Bureau and the Commissioner in charge of that Bureau is Commissioner Fish. An extension of some sort, seems reasonable, but I am not privy to the Water Bureau challenges and constraints on the issue. I suggest you direct your entreaties for more time to the applicant. Sincerely, Thomas Bizeau Chief of Staff Commissioner Amanda Fritz Ph: 503-823-3990;
[email protected] ………………………..
From: Stephanie Stewart Date: Tuesday, February 11, 2014 at 10:07 AM To: "Bizeau, Tom" Cc: "
[email protected]" Subject: Re: MTNA request regarding Tabor disconnect LU application Dear Mr. Bizeau -‐ Thanks for your quick reply. As the Commissioner's office in charge of the Parks Bureau, we look to your office to be involved in this issue because it will dominate Mt. Tabor Park. As the Commissioner's office in charge of BDS, we look to your office to get involved in this issue at this moment to insure this case is getting the scrutiny it demands from BDS staff. We contacted Commissioner Fish's office the same time we contacted you (no response yet). We have also contacted the listed applicant (Tom Carter, no response yet) and the BDS planner assigned to the Historic Resources Review (no response yet). The plan to disconnect our reservoirs from our drinking water supply was expected, but what is new here is the plan to completely cut off all water to these reservoirs, and leave them dry. This is a definite change in course, counter to all past public discussions, and it was simply declared by PWB without any public process. I assert that this is the kind of decision a community should make in concert with their government. Or, at the very least, this is the kind of decision a government should more thoughtfully announce. As owners of registered historic assets, PWB is mandated to steward these structures properly. Without water, these facilities will degrade exponentially. Stewardship is a clearly defined maintenance obligation, and the plan to disconnect these reservoirs from the drinking water supply should come with a mitigation plan to provide water for proper stewardship of both the protected views and the historic structures. We look to your office to help the community press for a mitigation plan that protects the structures and this dominant feature of our park. Thank you, Stephanie Stewart MTNA land use chair
………………………………… From: Stephanie Stewart Date: Tuesday, February 11, 2014 at 11:21 AM To: Cc: Subject: Re: MTNA request regarding Tabor disconnect LU application Via email 2-‐11-‐14 Dear Commissioner Fish and Ms. Schmanski -‐ The Mt. Tabor Neighborhood Association is checking-‐in, regarding the request we made Sunday. As the Commissioner's office in charge of the Water Bureau, we look to your office to be involved in the details of this significant land use application generated by Water Bureau. We have two requests for your staff: 1) Please direct the applicant, listed as Tom Carter, to extend the public comment period. The community was offered just 13 business days (10 with storm related closures) to research, understand, host public processes and then formulate comments on this complicated issue. As Water Bureau doesn't intend to launch actual
construction related to this application until October, it seems reasonable to offer the public a longer comment period backed by more substantial public information distribution from Water Bureau. 2) Please press the applicant to engineer better mitigation. As owners of registered historic assets, PWB is mandated to steward these structures properly. Without water, these facilities will degrade exponentially. Stewardship is a clearly defined maintenance obligation, and the plan to disconnect these reservoirs from the drinking water supply should come with a mitigation plan to provide water for proper stewardship of both the protected views and the historic structures. The plan to disconnect our reservoirs from our drinking water supply was expected, but what is new in this application is the plan to completely cut off all water to these reservoirs, and leave them dry. This is a definite change in course, counter to past public discussions. We look to your office to protect the public process and to craft a mitigation plan that protects the structures and this dominant feature of our park. Thank you, Stephanie Stewart MTNA land use chair
[email protected]
………………………………… From: "Schmanski, Sonia" Date: Tuesday, February 11, 2014 at 11:42 AM To: Stephanie Stewart Cc: Commissioner Fish Subject: RE: MTNA request regarding Tabor disconnect LU application Hello Stephanie, Thank you for checking in on yesterday’s email, and for clearly describing your requests. That is very helpful for us. We share your commitment to honoring the important legacy of these historic sites and look forward to supporting Commissioner Fritz and the community conversation that will determine the future of this signature park. Commissioner Fish has asked for more information about options with regard to the timing of this Land Use Review, and intends to discuss the issue this afternoon with Commissioner Fritz. We recognize the abbreviated timing of this and will follow up with you no later than Thursday. Thanks, Sonia Sonia Schmanski Policy Director Office of Commissioner Nick Fish (503) 823-‐3592 portlandoregon.gov/fish ……………………………………………..
From: Commissioner Fish Date: Wednesday, February 12, 2014 at 5:09 PM To: Stephanie Stewart Cc: "Schmanski, Sonia" , "Shaff, David" , Commissioner Fritz , "Bizeau, Tom" Subject: Mt. Tabor Land Use Review Comment Period February 12, 2014 RE: Mt. Tabor Land Use Review Comment Period Dear Ms. Stewart, Thank you for brining your concerns about this Land Use Review matter to my attention. I appreciate your thoughtful feedback on this portion of the larger Mt. Tabor process. I have discussed your request with Commissioner Amanda Fritz and Director David Shaff – both of whom support an extension of the comment period. Accordingly, I am extending the comment period for this Land Use Review for a period of three weeks, until March 10. This additional comment period will allow extra time for review of the application without jeopardizing the overall project timeline. My goal is to ensure that you and other community members have adequate time to comment. If you have other questions or concerns, please feel free to contact Sonia Schmanski, who serves as my liaison to the Portland Water Bureau, at
[email protected] or (503) 823-‐3592. Sincerely, Nick Fish
