350PDX Letter to Hearing Officer RE PGE Harborton Project Proposal

TO: Hearings Officer

Cc: Morgan Steele, Sr. Environmental Planner, City of Portland

FROM: 350PDX

DATE: 29 January, 2025

RE: LU 24-041109 CU EN GW PGE and Harborton Reliability Project Proposal for more Transmission Lines through Forest Park

Dear Hearings Officer,

350PDX, a climate justice organization based in Portland, opposes the proposed new power transmission lines near existing transmission lines within Forest Park. We strongly encourage you to deny the PGE the ability to construct these additional lines. While PGE does have an easement for its existing transmission lines, its proposal still must comply with the City’s Natural Resources Management Plan (NRMP) for Forest Park. The first Goal in the Forest Park NRMP states:

Protect Forest Park’s native plant and animal communities, its soil and its water resources while managing the forest ecosystem in order to grow a self-sustaining ancient forest for the enjoyment and benefit of future generations.

While PGE proposes several well-considered mitigation strategies within Forest Park, the truth is that tall trees cannot grow under power lines means that the loss of 4.7 acres of forest will be permanent. In this instance, mitigation measures are not enough to “grow a self-sustaining ancient forest”. And, while we appreciate the forward-thinking approach to planting trees that may be more resilient to the changing climate, the most important thing we can do to minimize the impacts of climate change in the region is proforestation – retain existing mature forests as both climate change refugia and carbon sinks.

PGE’s proposal does not satisfy the Approval Criteria for Exceptions to the goals and standards in the NRMP . See NRMP at 217. Criterion B requires the proposal is a park-related development or that no alternative locations exist outside of Forest Park. Importantly, in this case there is an alternative route that could be chosen to meet PGE’s expressed needs without compromising the ecological integrity of part of a beloved public forest. While it does not meet every criteria that PGE laid out in its analysis, the NW Marina Way route meets most of the project criteria, with the important benefit of not impacting Forest Park. See Appendix C, p.10-11. It is in PGE’s interest to select the fastest and cheapest alternative, but it is not in the best interest of the public and NW Marina Way meets all other project criteria.

As noted above, it is not possible to “fully mitigate” the impacts of this project, thus it does not meet Criterion D, which requires that any long-term adverse impacts of the proposed action onresource values be fully mitigated. Additionally, the proposal does not meet Criterion E, which requires the proposal be consistent with the purpose of the Environmental Zone.

It is important to view this proposal in its greater context as it is explicitly part of a larger project that could lead to even greater encroachment into Forest Park with future PGE proposals. See Appendix C. at 18: “Full build of the Harborton-Trojan Lines 3 and 4 may be needed in the Future….”.

This future work must be considered as an inevitable impact resulting from this project as it will all but guarantee future phased energy development in Forest Park. We do not believe this proposal serves the best interests of Portland, nor does it comply with the Forest Park NRMP . We recommend you deny PGE’s request to move forward with this project.

Thank you,
Brenna Bell
Forest Climate Manager, 350PDX