Wednesday, September 16, 2009

DLCD Letter of Support

Department of Land Conservation and Development
635 Capitol Street NE, Suite 150
Salem, Oregon 97301-2540
www.oregon.gov/LCD

September 15, 2009

Eric Hackett
Idaho Power Project Analyst

RE: Boardman to Hemingway 500 kV Transmission Line

Dear Eric:

Thank you for this opportunity to comment on the proposed Boardman to Hemingway 500 kV Transmission Line project. As the route was initially envisioned, the transmission line extended through Malheur, Baker, Union, Umatilla and Morrow counties in Oregon. I understand that the project has been temporarily suspended while Idaho Power conducts public outreach through its Community Advisory Process (CAP). I also understand that the purpose of the CAP is to develop an alternate route in response to community concerns.

The Department of Land Conservation and Development strongly recommends that Idaho Power consider a number of significant local and regional impacts as it decides where to site the proposed transmission line.

The economy of eastern Oregon counties is strongly tied to agriculture and outdoor recreation. The siting of a major transmission line through these counties would have significant and long-term consequences for several counties and cities, including potential adverse impacts to high-value agriculture, sensitive wildlife habitat and the recreational tourism industry.

My staff has been in contact with the planning directors of the affected counties, who feel strongly that any proposed transmission corridor should avoid high-value farmland and scenic Oregon view sheds. This office has also received several letters from farmers in Malheur and Baker counties, including a letter from the Malheur County Onion Growers Association, all of which express concerns with the routing of the transmission line through private farmland in the Treasure Valley and Baker Valley. The letters raise specific concerns about the likely need to alter irrigation practices, modify aerial application of chemicals, and change tilling practices, all of which would disrupt and add additional costs to farming operations. In addition, high-value farmland would be lost. We share these concerns from counties and farm interests.

Oregon’s statewide land use planning program as set forth in statewide planning goal 3, “Agricultural Lands,” and ORS Chapter 215 requires counties to protect agricultural land, with preference given to high-value soils such as those found in the Baker, Grande Ronde and Treasure valleys and the irrigated row crop-producing areas of Umatilla and Morrow counties. These areas boast some of the best farmland in Oregon and are subject to strict safeguards protecting them from conflicting nonfarm development. The farmers who are stewards of Oregon’s working landscape now and into the future deserve our commitment to make every effort to accommodate agricultural production needs.

Other parties, including the Oregon Department of Fish and Wildlife, raise concerns with potential impacts to sensitive wildlife habitat, including highly sensitive sage grouse habitat. Statewide planning goal 5 calls for local jurisdictions to inventory and protect a variety of resources including wildlife habitat, wetlands and riparian corridors. In some cases, the best wildlife habitat or natural areas are found on land that would be considered poorly-suited for agricultural production. In eastern Oregon, significant areas of sensitive habitat are also located largely on public lands. Idaho Power must work to find an appropriate balance between protection of agricultural lands and wildlife habitat.

Tourism also provides a significant contribution to eastern Oregon’s rural economy. The tourism and outdoor recreation industry also has tremendous opportunity for growth. Statewide land use planning protections maintain and enhance recreation opportunities such as the proposed 870-mile multi-county Blue Mountain Heritage Trail, the Oregon Trail and its historic view shed, and the Snake River through Hells Canyon. The siting of a major transmission corridor in any of these areas could significantly detract from the scenic, cultural and historic values of these unique places, and could impact tourism and economic values as well.

Thanks again for the opportunity to comment and please enter this letter into the record of proceedings on this matter. I would be happy to answer any questions or provide any additional information to you. You may contact me at 503-373-0050 ext. 280 or richard.whitman@state.or.us.

Sincerely,
Richard Whitman
Director

ec: Adam Bless, ODOE
Rep. Greg Smith
Bob Valdez, OPUC
Rep. Cliff Bentz
Lucas Lucero, BLM
Scott Fairley, Governor’s Office
Mark Bennett/Holly Kearns, Baker County Planning
Jim Johnson, ODA
Roy Elicker, ODFW
Jon Beal, Malheur County Planning
Todd Davidson, Oregon Tourism Commission
Hanley Jenkins, Union County Planning
Tamra Mabbott, Umatilla County Planning
LCDC Commissioners
Carla McLane, Morrow County Planning
DLCD regional and technical staff
Sen. Dave Nelson
Rep. Bob Jenson
Sen. Ted Ferrioli

Download the letter HERE