PO Box 28454 Portland, OR 97228PHONE: (503) 626-8197

oapa@oregonapa.org ● http://www.oregonapa.org

July 29, 2014

Scott Ashford, Chair, Oregon Resilience Task Force

Via email: scott.ashford@oregonstate.edu

RE: Comments on DRAFT ORTF Recommendations short list

SUMMARYThe Oregon Chapter of the American Planning Association (OAPA) welcomes the opportunity to review of the Oregon Resilience Task Force Draft Recommendations. We applaud the ongoing work of the Oregon Resilience Task force. The current (June 2) list of recommendations includes a number of recommendations that topically align with OAPA’s mission and current legislative agenda. We offer comments on ORTF’s recommendations in the spirit of creating a resilient Oregon.

BACKGROUNDThe American Planning Association (APA) is an independent, not-for-profit educational organization. At the local level, the Oregon APA chapter supports the APA mission by providing leadership in the development of vital communities. Specifically, OAPA advocates for (1) excellence in community planning, (2) promoting education and citizen empowerment, and (3) providing the tools and support necessary to meet the challenges of growth and change.

OAPA’s mission statement also includes the following specifics:

A. Promote the art and science of planning in Oregon.

B. Help planning professionals in their profession.

C. Advance the practice of planning and opportunities for planners.

D. Emphasize the importance of achieving the final vision/goal over mere procedure.

E. Protect the legacy of our state's natural environment.

F. Nurture the improvement of our built environment.

G. Foster social and environmental equity.

H. Advocate for every citizen’s opportunity to participate.

OAPA applauds the work of the Oregon Resilience Task Force. Specifically, we commend your focus and prioritization of land use as a critical element of community resilience. If you are not already aware, your specific focus on land use planning for resilience aligns with OAPA’s 2014 legislative agenda.

OAPA, Page 2 of 6

OAPA 2014 Legislative AgendaSustainability and Resilience Position Statement:OAPA has long recognized the need for state and local governments to more directly address the causes and impacts of climate change, economic challenges and demographic shifts, as well as more traditional planning issues. We have supported language adding overarching sustainability principles to the State Planning Program, but recognize the urgent need to make those principles enforceable through further planning requirements, and to develop programs and projects that will make our communities more sustainable and resilient over the coming decades.

Recommendations:a. Support legislation and/or rule changes that provide clarity to cities and counties on how to: effectively mitigate and respond to climate change; make their communities more secure from changes in the economy and energy markets; secure reliable access to healthy food and water; and incorporate disaster preparedness into planning.

b. Support funding for additional research and technical assistance – through DLCD, ODOT or other state agencies – that supports local and regional government planning to address climate change, energy, food, community health, disaster preparedness and other planning best practices.

c. Support legislation to replace and move beyond the provisions of SB 1059 and HB 2001 (which expires in 2015) and implement all recommendations of the 2009 Green House Gas Reduction Task Force.

d. Support legislation and funding for implementation of the State Resilience Plan.

OAPA Legislative and Public Affairs CommitteeIn late 2013, OAPA revitalized its Legislative and Public Affairs Committee (LPAC). Specifically, we recruited new committee members with specific experience in public infrastructure, sustainability and community resilience. The LPAC is actively tracking state and local land use issues related to climate change and natural hazards. The work of the Oregon Resilience Task Force is of primary interest.

COMMENTS ON THE ORTF DRAFT RECOMMENDATIONSOAPA offers the following specific comments on the Task Force’s original (May) Recommendations Short List. These comments are informed by OPA’s mission, legislative priorities and best practice in the field of land use planning.

Recommendation A (June “Oversight” recommendation): Establish a State Resilience Office to manage Oregon’s Earthquake Hazards Reduction Program long term (ORP 5.1.1 and ES 2.c).Comment SummaryOAPA supports the general spirit of this recommendation. However, proposing a statewide resilience office that focusses exclusively on the earthquake hazard ignores the interconnected nature of hazard risks and statewide vulnerabilities. We strongly encourage the task force to propose a State Resilience Office that addresses all hazards.

OAPA, Page 3 of 6

Comment JustificationThe Cascadia Earthquake poses a significant catastrophic threat to the state of Oregon. Most, if not all, critical infrastructure and services west of the cascades will be impacted when Cascadia occurs. There is a clear and urgent need to improve Oregon’s overall resilience to Cascadia.

However, Oregon also faces a number of other large-scale threats of statewide consequence. Climate change will continue to impact Oregon in ways we are only now coming to understand. Prior to the Oregon Resilience Plan, the state developed the Oregon Climate Adaptation Framework which addresses many of the same vulnerabilities being considered by the ORTF. We also face significant impacts from wildfires, flooding, landslides, coastal erosion and winter storms. Not to mention significant man-made, technologic and public health dangers.

Focusing on any one of these hazards in isolation runs the risk of missing opportunities for multi-objective strategies. For example, one potential outcome of an earthquake-centered approach to mitigating impacts to the state’s energy infrastructure could be the hardening of infrastructure in the Portland fuel hub. This type of engineering solution would have significant benefits to the state by ensuring that liquid fuel remains available to the state following a major earthquake event. However, such an approach runs counter to other state-wide policies that encourage long-term energy and transportation strategies that rely less heavily on fossil fuel. OAPA’s concern is that by narrowing the focus of a State Resilience Office to the earthquake hazard, we will miss opportunities to think more holistically about the risks and vulnerabilities facing our state.

Recommendation D (deleted in the June recommendations set): Require all full service grocery stores and pharmacies in the Valley and Coast regions of the State to submit a Cascadia Earthquake Business Continuity Plan to the State Resilience Office and to certify that all of its sites either have standby power available or have a manual transfer switch so that mobile backup power generators can be quickly installed (ORP 5.2.1).Comment SummaryOAPA recommends reconsideration of this recommendation in its current form. The food and pharmaceutical systems are fundamentally reliant on the transportation and fossil fuel systems. OAPA recommends working with major grocery and pharmaceutical chains to determine both the feasibility and benefits assumed by this recommendation. In addition to these concerns, OAPA fears this recommendation will pose equity issues for small, independent food and pharmaceutical retailers.

Comment JustificationSensitivity of the food sector to a M9.0 Cascadia earthquake is very high. A major earthquake will have catastrophic impacts to the food sector.

The loss of electricity, availability of diesel fuel, and damaged transportation infrastructure are the primary concerns for grocers. Existing grocery stores are mostly new and should remain standing, however shelving is not typically bolted down. Broken food containers and defrosting foods are likely to result in spoilage of significant amounts of stock. This loss of product, coupled with disrupted distribution and expected runs on food suggest grocery stores will likely be out of food within a day or two of a major earthquake.

OAPA, Page 4 of 6

Similarly, Risks to the health sector from a M9.0 Cascadia earthquake are very high. A major earthquake will have catastrophic impacts on multiple parts of the health care sector.

An earthquake event would significantly impact the health system’s staffing, supply chain of critical supplies, and essential equipment. A surge of patients is expected overwhelm the local system, forcing existing staff to work long and continuous shifts. Staff reductions beyond 20% are not sustainable long-term, particularly in certain skill positions. The need to bring in medical staff from outside the region following this event is almost certain.

With crippled transportation systems, ability to receive medications, medical supplies, equipment and lab services will be compromised. As noted above, the sector also relies heavily on the waste stream. If wastewater and medical waste pickup is not available, the ability of the hospitals to function is severely compromised.

Finally, stakeholders expect that essential equipment for imaging and diagnosis could be damaged or destroyed limiting both the functionality of labs and ability to meet a minimum standard of care. These losses are primarily related to the loss of secondary (non-structural) systems within the hospital. For example, the pharmacy uses a giant robotics system and runs 24-hours a day, seven days a week. Earthquake shaking is expected to damage that system. Numerous other examples of equipment losses, either from damage or needed recalibration, are expected. Some highly specialized equipment (e.g. the Gamma Knife) may take years to replace due to cost. Insurance claims and payees ability to provide revenue into the system may be suspended to provide immediate care and may never be recovered. Patient tracking and billing systems are off site, so communication infrastructure becomes a critical vulnerability. Local communication is also a key vulnerability because a small number of calls can overwhelm the 911 system.

In summary, there appear to be multiple issues that need to be addressed before a recommendation of this level of specificity would be effective.

Recommendation M (June “Land Use” recommendation): Recommend that local governments use/adopt hazard maps to limit development in hazard areas via 5-yr Comprehensive Plan review (Goal 7).

a. Recommend that DLCD pursue and focus funding support toward coastal communities to incorporate new line in their 5-yr review process.

b. Allow pre-determined UGB expansion for faster and more resilient recovery (post-disaster) and to encourage pre-disaster development outside of hazard zones.

Comment SummaryOAPA supports the use of hazard information, including maps, studies, historical data and development trends, in the update of local comprehensive plans. However, comprehensive plans, particularly in small jurisdictions (e.g. many coastal communities) are not updated or reviewed on a five-year cycle. In fact, jurisdictions with populations under 2,500 (i.e. many coastal communities) are not subject to periodic review. In short, this recommendation does not reflect reality as currently written.

OAPA, Page 5 of 6

Comment JustificationOAPA supports amending this recommendation to focus on the development and adoption of Administrative Rules to address Statewide Planning Goal 7: Areas Subject to Natural Hazards. Currently, there are no OARs related directly to implement Goal 7. OAPA strongly believes that developing an administrative framework is an important first step to ensure reasonable use and incorporation of natural hazard information into local comprehensive planning.

OAPA also supports expanding the language in subsection (a) to include the formal adoption of tsunami overlay zones and/or districts in there comprehensive plans and zoning ordinances. These comments are related to RTF Recommendation L.

Regarding sub-recommendation (b) OAPA supports the use of “hazard reserve areas” as part of a comprehensive approach to UGB expansion post disaster. This is particularly important for coastal communities in Oregon.

Additional Comments:

Jay Raskin, Mark Labhart and Josh Bruce presented the Oregon Resilience Plan and the ORT Recommendations Short List to assemble planners at the 2014 OAPA Planning Conference. The panel solicited comments and feedback from the participants. Specific suggestions included:

Consider a recommendation that supports utilizing a “regional solutions” approach.

Consider a recommendation to develop a “resilience rating” for communities.

Consider a recommendation to adopt OARs for Goal 7 (reflected in comments above).

CONCLUSIONOAPA supports the work of the Oregon Resilience Task Force and remain willing to assist. We hope these comments are helpful. We share your desire to create a resilient Oregon.

If you would like to discuss any of these comments, please contact me directly at:

Jasonwfranklin@gmail.com or 503-341-6246

Thank you for your time, consideration and service to our state.

Sincerely,

Jason Franklin, AICP

OAPA, Page 6 of 6

President, Oregon APA