clean water services grants a permit to the golf club to clear the land
Despite promises of increased timely communication and transparency, CWS approved an erosion control permit for PGC on Thursday January 9, though the website still said in review, until 430PM Friday January 10. We discovered CWS plans to grant the golf club the permit during our weekly phone conference with a CWS Communications and Community Engagement Representative.
Although we were told they planned to grant the permit, CWS would not tell us what the terms of the permit are or its expiration date. We have to file a public records request to get a copy of the permit, and CWS generally takes three weeks to process such requests. We will not be able to report any permit violations because we don't know what the permit allows or prohibits.
We know generally that the permit authorizes PGC to continue to clear the uplands of all vegetation on either side of the wetland in preparation for the proposed dredge and fill project, which has not been approved by the state and federal agencies having jurisdiction.
CWS' Planning and Development Services Manager, who was on this week's call, said that CWS did not consider the permit to be contingent upon the proposed project, and that PGC could destroy the upland wildlife habitat as long as they maintained a 50' buffer around the wetland. We asked if CWS could delay approval of the permit, as DSL is likely to make a decision on the dredge and fill application within a month or two. The manager said that approval could not be delayed but could not tell us the rule, policy, or standard that contains that prohibition.
We let CWS know that a portion of the western upland is currently flooded. PGC did not disclose this information to CWS, and CWS apparently did not go out to the site before final approval of the permit to check current conditions. The manager said that working on the land while it was flooded would be contrary to the terms of the permit and said he would follow up on the issue but did not provide any specific actions CWS would take.
PGC's application for the erosion control permit states that the inlet to the wetland will be covered with a sheet of plywood so that the machinery used in vegetation clearing can be driven to the west side of the wetland. We asked if CWS' development standards provided that a sheet of plywood was adequate protection for the inlet. The manager said that the standards don't get that specific. He said that both PGC and CWS intended that the inlet would not be disturbed. He went on to say that CWS could require PGC to do restoration work if necessary. We asked how CWS has documented the current state of the inlet so that CWS would know whether it had been disturbed. The manager said, they had been out there before, they know how it is supposed to flow and CWS has documented it in the past. We asked him to get current photos of the inlet so that they could compare before and after the work accurately to know if restoration was necessary. He said he understood my request but did not agree to take any action.
We asked how CWS intended to monitor the vegetation removal. The manager said that CWS would be out on site weekly. This means that there will likely only be one inspection that could happen after the work is completed, as the project should not take more than a few days.
This is not our first time frustrated with CWS, communication, lack of transparency and lack of working with the public. See our blog post from a year ago with basically the same concerns.
Department of State Lands application status
In early-December, DSL deemed the Joint Permit Application as complete and moved it into the Public Comment phase. DSL will invited/accepted public comments for a 30 day period, that ended January 10, 2025.
Now DSL will review the public comments, give the golf club an opportunity to address concerns raised, and then DSL will make a decision on the application by March 9, 2025. To those who took the time to provide comments, THANK YOU.
If you would like to see the application that is pending with DSL, you can Read this application here:
In summary, the golf club proposes stacking fabric bags full of sludge/dredge tailings from their irrigation pond in a 1.1-acre area cleared of all vegetation just to the west of the corresponding wetland. The 5300 cubic yards in bags will not be covered with soil. The 7-12’ pile will be visible from the trail from SW 83rd Avenue to the east side of the wooden bridge at the pump station.
Despite bags being placed "to the side," the wetland will still be affected. They propose a sump pump will be dug at least 8’ deep into the north end of the wetland, necessitating the removal of about 44 cubic yards of earth (about 4 dump truck loads). The water seeping from the bags would be collected in the wetland to be pumped back to the irrigation pond.
PGC finally admits in their application that the wetland is connected hydrologically to downstream wetlands and to Fanno Creek, and propose the use of two check dams. However, these check dams will not prevent the contamination of Fanno Creek with silt or toxic substances from the sludge.
golf club submits application with DEQ
In early December, the golf club filed their application with DEQ.
DEQ, Army Corps of Engineers & Department of State Lands all use the same Joint Permit Application (referenced above) but each agency then has specific addendums they may require.
To be approved by DEQ, an applicant files a 401 Dredge-Fill Certification Application.
DEQ explains their process to us as follows:
The administrative process for 401 water quality certifications is outlined in OAR 340-48, as well as the Clean Water Acts Section 401. Through an agreement with USACE we have 6 months to review a 401 water quality application and issue a decision. Our review is to confirm that the project activity as described meets certain sections of the Clean Water Act and Oregon state water quality standards (OAR 340-41). DEQ also has a fee payment tied to the 401 application review and needs land use confirmation from the local Planning Department.
The application is quite long but it is posted here on our website, go to the section titled Documents & Articles.
Neighbors for Wetland Preservation
who we are
Our history
Our history
We are a 501 (c) (3) nonprofit.
We are committed to Fanno Creek, beautiful old growth trees, healthy wetlands and wildlife habitat.
Our focus is the greenspace & the wetland alongside the Fanno Creek Trail in Garden Home.
Our history
Our history
Our history
Portland Golf Club lies in Washington County, Oregon. Fanno Creek runs through their property. They have water rights to the Creek, they take & store water in their irrigation pond.
In 2021 they made public their intent to dredge the pond, pumping water & dredge to the southern portion of their property, immediately adjacent to the F
Portland Golf Club lies in Washington County, Oregon. Fanno Creek runs through their property. They have water rights to the Creek, they take & store water in their irrigation pond.
In 2021 they made public their intent to dredge the pond, pumping water & dredge to the southern portion of their property, immediately adjacent to the Fanno Creek Trail. The dredge tailings will be left in bags adjacent to the wetland. They estimate the equivalent of 500 dump trucks of dredge tailings will be permanently placed on top of the wetland.
This will destroy the wetland, eliminate wildlife habitat, create an eyesore, alter storm water flow and potentially contaminate Fanno Creek.
As a result, neighbors organized to provide a unified voice in opposition, requesting we work together with the PGC toward environmentally sound solutions.
Our goals
Our history
Our goals
The Portland Golf Club accepts the role of leaders in ecosystem preservation and sustainability within the golf club world. To do this, we ask the following:
- The Portland Golf Club care for and preserve Wetland A on the Pinger Property. In order to achieve this, they should not clear the property, they should not place dredge on the prop
The Portland Golf Club accepts the role of leaders in ecosystem preservation and sustainability within the golf club world. To do this, we ask the following:
- The Portland Golf Club care for and preserve Wetland A on the Pinger Property. In order to achieve this, they should not clear the property, they should not place dredge on the property. They should foster native growth and remove invasive species in order to maximize functionality of the wetland and the watershed.
- Stream restoration, of both Fanno Creek and Woods Creek, at the points they enter the Golf Club, they traverse the Golf Club, and they exit the Golf Club. Make real efforts to slow peak water flows which can be erosive. This will foster native wildlife and fish, particularly cutthroat trout.
- The Golf Club works with the public and community organizations to remove non-native, invasive species (English Ivy) which threatens old growth trees.