[Originally published in the OTHER paper, Eugene, Oregon in December, 1995.]

Plans are made by hired hands, but only God creates wetlands.
[Apologies to Joyce Kilmer]

The mitigation plan Hyundai Electronics America (HEA) submitted to the Dept. of Environmental Quality (DEQ) to replace wetlands destroyed by its proposed plant was described in Citizens for Public Accountability's Petition for Stay as "a fanciful creation of a perennial mountain stream" -- appropriate perhaps for salmon restoration, but not for wetlands.

The 1856 site survey providing the best record of pre-disturbance conditions was ignored. The hydrological needs of rare plants -- soil neither too wet nor too dry -- were ignored. Essential baseline information necessary to monitoring progress of the mitigation is not provided or required.

There is no commitment to maintaining present wet prairie plant diversity [perhaps 110 species], while grading dozens of acres, compacting soils, and rearranging drainages guarantees a sea of weeds. HEA commits only to seeding with deschampsia and planting potted shrubs on the periphery, seeding other plants only if seeds can be conveniently obtained.

Historically, burns have been used to maintain wetland health, but DEQ does not require them. The Integrated Pest Management plan HEA proposes is not spelled out but boils down to herbicide spraying -- which has limited effectiveness in controlling invasive weeds. DEQ approval of the plan -- to ensure species and groundwater protection -- is not required.

HEA names DAG Trusts Partnership (DAG Trusts) as the mitigation project manager. DAG Trusts has no such expertise, is not a legal entity (neither an individual nor a corporation), and will have no tie to the property after it is sold to HEA. DEQ has not identified a successor trustee or a chain of responsibility if DAG Trusts dissolves. Yet HEA promises the mitigation area will be protected in perpetuity, while making no budgetary commitment for even the five years of required follow-through. (Spectraphysics' 5-year mitigation cost over a million dollars, failed, and is now the City's problem.)

The Division of State Lands and the Army Corps of Engineers are the agencies authorized to monitor and enforce mitigation projects, but currently lack the funds for systematic staff follow-up. DEQ does not provide adequate information as to how the necessary monitoring and enforcement will occur.

The Willow Creek wetlands are of national significance. The HEA plan promises both hydrological and biological failure.