Overview and Background
In December 2020, City Council adopted a set of updates to Title 21. Title 21 is the section of Portland City Code that guides our work at the Water Bureau. The Bull Run portion of these code updates help implement the charter amendment passed by Portland voters in 2019.
The Bull Run Code updates add new environmental protections for City-owned land in the Bull Run Closure Area. The Closure Area is the protected area that includes the entirety of the federally designated Bull Run Watershed Management Unit plus some directly adjacent City-owned land.
The Water Bureau has drafted administrative rules to describe methods and processes to implement Section G of City Code 21.36.050. Section G requires a new process for assessment and mitigation of potential environmental impacts of Water Bureau projects on City-owned land in the Closure Area. We are inviting the public to review these new administrative rules and submit public comments.
The public comment period is now closed.
The public comment period closed at 5 p.m. on September 2, 2021. A Portland City Council hearing on the rules will take place in late fall.
Frequently Asked Questions
What is Title 21?
Title 21 is the section of Portland City Code that guides our work at the Portland Water Bureau.
What are the administrative rules for the Bull Run Protection section of Title 21?
City Code 21.36 is the section of Title 21 that inform the rules and laws that direct our work in the Bull Run Watershed. These administrative rules implement Code Section 21.36.050, which is called Bull Run Watershed Protection Policy.
Why are you writing new rules?
In December 2020, City Council adopted a set of revisions to Title 21 that included new environmental protections for City-owned land in the Bull Run Closure Area, an area that includes the entirety of the Bull Run Watershed. This updated code included adding details to implement what voters approved by Charter Amendment in November 2019. For work performed in the Bull Run Watershed, Title 21 now includes rules about riparian protection, stream crossings, wet weather construction, and fire prevention. One of the new sections, G. Project Impact Assessment and Mitigation Process, requires administrative rules to provide additional details and guidance that are not included in the code.
What do the new rules include?
The new administrative rules, as required by the revisions to Title 21, provide a way to assess environmental impacts of capital and non-routine projects on City land in the Bull Run Closure Area, and a way to define and summarize project mitigation.
The Charter Amendment directed the Water Bureau to avoid environmental impacts to the greatest extent practicable, and to minimize and mitigate impacts that can’t be avoided. The rules include definitions and templates for a Project Impact Assessment and a Mitigation Summary.
Will this give me more opportunity to comment than I have now, or less?
The updated code and rules will give the public more opportunity to comment on significant projects on City land in the Bull Run Closure Area. The definitions and templates for the project impact assessment and mitigation process provide for easier access to project information. The code requirements also provide a new process and opportunity for the public to comment on Water Bureau projects on City owned land. Details of the new public comment process are described in Title 21.
Will these code changes and new rules provide more or less environmental protection for the Bull Run Watershed?
More. The Code changes and administrative rules create new protection requirements on City land that did not exist before the 2020 code updates and strengthen the Water Bureau’s commitment to good stewardship of Portland’s water and of the Bull Run watershed.
Draft Administrative Rules, Aug. 4, 2021
DRAFT Administrative Rules – PCC 21.36.050 Sections G.1 and G.2
Draft Administrative Rules
August 4, 2021
Project Impact Assessment and Mitigation Summary Requirements for City-owned Lands in the Bull Run Closure Area
A. These rules implement Portland City Code (PCC) 21.36.050 Sections G.1 and G.2, which require: (i) a methodology to assess environmental impacts of capital and non-routine projects on City-owned lands in the Bull Run Closure Area that have significant impacts on the watershed; and (ii) a methodology to define and summarize mitigation for those projects. See Exhibit A for a process flowchart. The rules seek to avoid, then minimize and mitigate, impacts on environmental and cultural resources to the greatest extent practicable, as required in Portland’s City Charter, Section 11-107.
B. Because uses of City-owned lands in the Bull Run Closure Area are restricted by Portland’s City Charter and City Code, the activities regulated by these rules will be: (i) Water Bureau projects to operate, maintain and protect the water supply and water system; and (ii) Bureau of Hydropower projects to operate and maintain the hydroelectric system.
A. These rules apply to City-owned lands in the Bull Run Closure Area. These rules do not apply to federally-owned lands in the Bull Run Closure Area or to City-owned lands outside the Bull Run Closure Area.
B. City projects on federal lands are governed by federal rules and requirements, including the National Environmental Policy Act (NEPA).
A. Infrastructure project. Construction, maintenance, repair or replacement of facilities necessary for operation of the water system and electric power generation and transmission, including maintenance of existing dams, roads, culverts, pipelines, powerlines, trestles and bridges.
B. Land or vegetation management project. Managing the forest or the natural landscape (e.g., stabilizing hillslopes) in accordance with Portland City Charter 11-107 and Public Law 95-200, clearing forest land to build infrastructure, or clearing forest adjacent to structures and powerlines to reduce the risk of fire starts and fire spread.
C. Mitigation measures. Actions or modifications to avoid an impact altogether, to minimize the extent of the impact, to rectify the impact by repairing and restoring the site to a pre-impact condition, or in limited circumstances to restore previously-disturbed resources elsewhere.
D. Previously developed, paved or otherwise non-forested areas. Areas that have been, and will continue to be, disturbed by human activity over the life of the water system and are no longer in an undisturbed natural forest condition, including but not limited to Dam 1, Dam 2, Reservoir 1, Reservoir 2, Headworks, Bear Creek houses, road corridors, powerline corridors and conduit corridors. Previously developed areas include water supply operation areas that have been cleared, graveled, graded, excavated or built upon.
E. Reasonable range of alternatives. Alternative project designs or alternative strategies to avoid or minimize the environmental and cultural resource impacts identified in a Project Impact Assessment. If an alternatives analysis is required for a project, the range of alternatives considered must include at least: (i) not proceeding with the project (no action alternative); and (ii) at least one (1) project design alternative with a lesser level of impact.
F. Significant impacts on the watershed. Impacts are adverse effects on water quantity, water quality, cultural resources and the natural environment, including soils, vegetation, and fish and wildlife and related habitat. Significant impacts on the watershed are limited to impacts on City-owned lands in the Bull Run Closure Area. The following criteria are to be used to assess the potential for significant impacts to the watershed:
1. Magnitude. The amount of new ground disturbance or vegetation removal is 0.5 acres or larger
2. Location. The effects are outside previously developed, paved or otherwise non-forested areas, or the effects are within the stream channel of the Bull Run River or its tributaries.
3. Unusual circumstances. The effects are not anticipated in existing regulatory compliance plans and are not easily addressed with anticipated permits or existing Standard Operating Procedures (SOPs).
4. Cumulative. The effects are not significant within the planned project, but may be significant when considered in addition to past projects or future planned projects.
5. Irreversible. The effects cannot be reversed with post-project restoration and revegetation.
IV. Project Impact Assessment
A. Projects Requiring Assessment. Projects in each of the following categories may have the potential to result in significant impacts to the watershed:
1. Infrastructure projects, ancillary structures or construction staging located outside previously developed, paved or otherwise non-forested areas2. Construction of new roads outside existing road corridors, or reconstruction of existing road segments, if the total area of new ground disturbance or vegetation removal is 0.5 acres or larger
3. Projects affecting the Bull Run River and tributary streams including flow, water quality and instream habitat (unless the project’s impacts are addressed in the Bull Run Water Supply Habitat Conservation Plan (HCP) and thereby excluded in Subsection C)
4. Land or vegetation management projects not excluded in Subsection C
5. Other projects not excluded in Subsection C
B. The Water Bureau must evaluate these projects in a Project Impact Assessment (using a template substantially in accordance with Exhibit B), determine if the potential impacts are significant, and prepare a map of the project location. The Water Bureau must post the Project Impact Assessment online and notify stakeholders, in accordance with PCC 21.36.050 F.2.
C. Exclusions. The following types of projects are not expected to have significant impacts on the watershed, and a Project Impact Assessment is not required. The general direction to avoid, then minimize and mitigate, impacts still applies, but is accomplished by implementing applicable regulatory management plans, best management practices (BMPs) as documented in SOPs, and by obtaining and complying with applicable permits.
1. Repair or reconstruction of buildings and facilities located wholly within previously developed, paved or otherwise non-forested areas.
2. Repair or reconstruction of road segments within existing road corridors if the total area of new ground disturbance or vegetation removal is less than 0.5 acres (including removal of hazard trees according to Occupational Safety and Health Administration requirements)
3. Repair or replacement of road culverts consistent with PCC 21.36.050 Section J requirements for aquatic organism passage.
4. Routine projects listed on the quarterly Bull Run Project List prepared to comply with PCC 21.36.050 Section E, including road and powerline maintenance and hazard tree removal.
5. Vegetation management within established powerline corridors to prevent fire and to reduce risk to powerline infrastructure in accordance with agreements with Portland General Electric or by Federal Energy Regulatory Commission (FERC) license requirements.
6. Vegetation management around buildings and facilities for fire hazard reduction to comply with county land use requirements or state and federal fire safety guidelines and requirements.
7. Safety-related repairs of dams and hydropower facilities resulting from orders from the FERC Regional Engineer pursuant to CFR Title 18 Section 12.4
8. Vegetation management to meet state and federal dam safety requirements and related inspection requirements.
9. Treatment of invasive plant species according to the Water Bureau’s Integrated Vegetation Management Plan.
10. Revegetation of previously-disturbed sites, consistent with PCC 21.36.050 Section I.
11. Implementation of conservation measures contained in the Bull Run Water Supply HCP.
12. Maintenance and repair of existing structures to meet the requirements of the Historic Properties Management Plan (HPMP).
D. Emergency projects will proceed in accordance with PCC 21.36.050 Section M.
E. Sensitive Species. The Water Bureau will periodically review the most recent information available from the Oregon Biodiversity Information Center, the Oregon Department of Fish and Wildlife Sensitive Species List, and the Oregon Conservation Strategy Species List to identify species that might be present on City-owned lands in the Bull Run Closure Area. Project Impact Assessments will include an assessment of the feasibility of surveys to identify the presence of relevant species at or near the project site. The feasibility assessment will evaluate the availability of suitable survey protocols, the availability of staff or contractors qualified to implement the survey protocol, the practicality of survey timing and duration, the estimated costs of the survey effort , and the probable value of the resulting data. If species presence is likely, adverse effects are likely, and surveys are feasible, the Water Bureau must conduct surveys to identify the presence of the relevant species. The purpose of the surveys is to enable design modifications or other mitigation to avoid, minimize and mitigate potential effects to the relevant species.
F. Riparian Reserves. Location of a project in a riparian reserve does not by itself require preparation of a Project Impact Assessment or Mitigation Summary, but does require a riparian reserve protection plan. Requirements for projects located in riparian reserves, including reserve dimensions, prohibitions and exclusions from prohibition, are identified in PCC 21.36.050 Section H.
V. Mitigation Summary
A. If a Project Impact Assessment identifies significant impacts, then the Bureau must prepare a Mitigation Summary (using a template substantially in accordance with Exhibit C).
B. The Water Bureau must seek to avoid impacts to the greatest extent practicable in the project design, including impacts to water quantity and quality, cultural resources, and the natural environment including soils, vegetation, and fish and wildlife and related habitat.
C. For significant impacts that cannot be avoided, the Water Bureau must seek to minimize those impacts using mitigation measures. The Mitigation Summary must include the following, as applicable:
1. Permits and Standard Operating Procedures. The Water Bureau must mitigate significant impacts using measures required by federal, state, county and local permits and by using Water Bureau best management practices (BMPs) as documented in standard operating procedures (SOPs) and provisions of existing regulatory compliance plans (e.g., HPMP or HCP). Exhibit D lists the SOPs and regulatory compliance plans that exist or are planned at the time these rules were adopted.
2. Project Specific Mitigation. For projects with significant impacts not addressed by permits or existing SOPs and regulatory compliance plans, the Water Bureau must seek to reduce or mitigate the impacts with project-specific measures. Mitigation can also include restoring land previously disturbed elsewhere, but opportunities for compensatory mitigation inside the Bull Run Closure Area are very limited and mitigation at a location other than the project site should be considered only after avoiding and minimizing impacts at the project site to the greatest extent practicable.
3. Alternatives. If significant impacts to the watershed cannot be effectively avoided, minimized or mitigated in the proposed project design, then the Mitigation Summary must identify those remaining significant impacts, identify alternatives that would lessen the impact, and describe why those alternatives were not selected. The alternatives analysis must include: (i) not proceeding with the project (no action alternative); and (ii) at least one (1) project design alternative with a lesser level of impact.
D. Objections and Appeals. The Mitigation Summary is subject to objection and appeal pursuant to PCC 21.36.050.F 5-7. The Project Impact Assessment is not subject to objection and appeal.
1. Objections. Objections must identify: (i) why the proposed mitigation is inadequate; and (ii) what additional mitigation should be required.
2. Appeals. PCC 21.36.050.F 7 sets forth a process for appeals of a Water Bureau decision on an objection. Appeals must describe: (i) why the Water Bureau’s response to the objection is inadequate, and (ii) what additional mitigation should be required.
VI. Administrative Review and Update
These rules are new for the Water Bureau and interested stakeholders. Accordingly, the Bureau will review and update the rules no later than five (5) years after adoption to incorporate lessons learned.
Exhibit A - Process Flowchart for Project Impact Assessment, Mitigation Summary, Objections and Appeal
(Flow chart in PDF)
Exhibit B - Project Impact Assessment
The intent of the Project Impact Assessment is to identify impacts early to enable Water Bureau staff to subsequently avoid, minimize or mitigate those impacts in the project design, and to enable public review and comment. A Project Impact Assessment is not required for all projects. See exceptions identified in the administrative rule.
A Project Impact Assessment will vary in length and detail depending on the project type and the level of associated impacts. A typical Project Impact Assessment document is anticipated to be less than 15 pages. Larger projects with greater potential impact might require longer documents. In some cases, county land use approvals (with approval conditions) and/or federal NEPA documents will also be required. The Project Impact Assessment must focus on environmental impacts defined in City Charter 11-107 and PCC 21.36.050, be summarized for the layperson, and be presented in a format that can be made available as an email attachment.
The Project Impact Assessment must be prepared in consultation with these Water Bureau staff or their designees: Engineering Supervisor for Supply Program, Bull Run Watershed Protection Manager, Environmental Compliance Manager, Cultural Resource Manager, and Land Use Coordinator.
The Project Impact Assessment is not intended to duplicate detail that might be prepared for an applicable Riparian Reserve Protection Plan, Erosion Control Plan, Tree Protection SOP project plan, permit application, or other similar documents. Those documents can be referenced in the Project Impact Assessment as existing or planned.
The Water Bureau must also prepare a map of the project location that identifies infrastructure locations, area previous disturbed, developed or deforested, riparian reserve dimensions, known sensitive habitat features, and known cultural resources in accordance with the Bull Run Historic Properties Management Plan. This locational information is needed internally to enable avoidance of impacts, but sharing the information may be sensitive for reasons of water system security and resource protection. Before sharing location information externally, the Water Bureau will consider sensitivity of the location information in cooperation with relevant management staff, regulatory agencies, Tribes, and partners, and will withhold sensitive location information from public review as necessary.
Template - Project Impact Assessment
Purpose of the Project:
Date of the Impact Assessment:
Anticipated Project Timing (including approximate duration and season of construction):
Describe the permit or agency reviews likely required, including the potential for federal NEPA analysis:
Is this project part of a larger phased project? If yes, describe the larger project:
Project Location (attach map):
Project Size (approximate number of acres, and longest linear dimension):
The purpose of the following questions is two-fold: 1) to enable Water Bureau staff to avoid, minimize and mitigate impacts in the project design, and 2) to identify which impacts are deemed potentially significant and must be addressed in a Mitigation Summary.
Water Flow and Water Quality
• Describe the potential for the project to adversely affect any surface waterbody (perennial and intermittent streams, wetlands, lakes/reservoirs) on or in the immediate vicinity of the site
• Will drainage at the project site be affected during or after completion of the project?
• Describe the potential for the project to adversely affect water quality, including water temperature and turbidity, at the site or downstream
• Describe the likelihood and duration of in-water work as part of the project
• Describe any aspects of the project that will remain in or on a water body after the project is complete
• Is the area of potential vegetation removal 0.5 acres or larger? (yes/no)
• Describe the type and approximate number of trees that might be removed
• Describe the type and amount of native vegetation that might be cleared
• Describe the potential for adversely affecting late successional forest habitat
• Describe any known rare plant species or habitats present or near the site
• Describe the potential for importing invasive species in fill material (or rock/gravel) and for disturbing or spreading invasive plant species already present at the site.
• Describe riparian reserves present or near the project site (see dimensions defined in PCC 21.36.050.G)
• Describe if and how the riparian reserve might be adversely affected by the project, including facility construction or subsequent facility operation
Fish and Wildlife Habitat
• Describe any species listed under the federal Endangered Species Act known to be present at or near the project site. Describe the likelihood that the project will adversely affect habitat for these species.
• Describe the potential for sensitive species identified using information from the Oregon Biodiversity Information Center, the ODFW Sensitive Species List or the Oregon Conservation Strategy Species List to be present at the project site and to be affected by the project. If there is potential for these species to be present, describe the feasibility of conducting surveys to identify the presence of these species. If surveys are then conducted, describe the results of the surveys. Describe the likelihood that the project will adversely affect habitat for these species.
Soils and Hillslopes
• Describe the extent (in acres) of ground disturbance anticipated, including construction staging areas.
• Is the area of potential ground disturbance 0.5 acres or larger? (yes/no)
• Describe the potential for the project to adversely affect previously undisturbed soils and to cause compaction that would inhibit site restoration post-construction
• Describe the potential for erosion during and after construction, including the presence of erosion-prone soils
• Describe steep and/or known unstable hillslopes present at or near the project site, including previous shallow or deep landslides identified in 2014 DOGAMI mapping
• Describe the approximate amount of soil disturbance, grading, cut and fill, and/or excavation anticipated
• Identify and describe the anticipated disposal area for excavated spoils if located within the Bull Run Closure Area
Noise and Disturbance
• Describe the types of large equipment likely to be needed for the project (cranes, excavators, etc.)
Are drones or helicopters likely to be needed at any point during the project?
• Describe type and location of any toxic or hazardous chemicals that might be stored or used during the project construction, or during the operating life of the project.
• Describe aspects of the project that might create a risk of fire (e.g., use of vehicles and powered equipment during the fire season, storage of fuel for equipment, burning of vegetation or debris)
• Identify and describe buildings, structures, or sites located on or near the site that are 45 years old or older and are listed or eligible for listing on national, state, or local preservation registers
• Describe any known or likely areas of historic use or cultural importance at or near the site (e.g. evidence of previous use and occupation by Indigenous peoples)
• List any professional studies or surveys conducted at the site that identified historic or cultural resources
• Describe the methods used to assess if there are potential impacts to cultural and historic resources on or near the project site. Examples include consultation with Tribes, archeologic surveys, historic maps, GIS data, etc.
• Describe the potential for the project to adversely affect cultural resources
Identification of Potentially Significant Impacts
Significant impacts to the watershed require preparation of a Mitigation Summary document per PCC 21.36.050 Subsection G.4. Use the following criteria to assess the potential for significant impacts to the watershed:
• Magnitude. The amount of new ground disturbance or vegetation removal is 0.5 acres or larger.
• Location. The effects are outside previously deforested, disturbed and developed areas. The effects are within the stream channel of the Bull Run River or its tributaries.
• Unusual circumstances. The effects are not anticipated in existing regulatory compliance plans and not easily addressed with anticipated permits or existing SOPs.
• Cumulative. The effects are not significant within the planned project, but may be significant when considered in addition to past projects or future planned projects.
• Irreversible. The effects cannot be reversed with post-project restoration and revegetation.
Describe in a summary narrative the overall potential effects of the project on the resources to be protected per PCC 21.36.050. Consider in the summary, for example, the combined effect of multiple different impacts from the project on a single sensitive species, area of land, or water body, and indirect effects such as reduction of a key food source for a sensitive species.
Exhibit C Mitigation Summary
A Mitigation Summary is not required for all projects. A Mitigation Summary is only required for projects for which a Project Impact Assessment is required and potentially significant impacts are identified.
The Mitigation Summary is not intended to replicate detail in existing SOPs, or related documents. Those documents can be referenced and the relevant aspects briefly summarized.
The Project Mitigation Summary should be prepared in consultation with these Water Bureau staff or their designees: Engineering Supervisor for Supply Program, Bull Run Watershed Protection Manager, Environmental Compliance Manager, Cultural Resources Manager, and Land Use Coordinator.
A Mitigation Summary document will vary in length and detail depending on the project type and the level of associated impacts. A typical Mitigation Summary is expected to be less than 15 pages. The Mitigation Summary can include excerpts from project specifications and construction drawings, but the document is not intended to include the entirety of those other documents. The Mitigation Summary must focus on environmental or cultural resource mitigation, be summarized for the layperson, and be presented in a format that can be made available as an email attachment.
Template – Mitigation Summary
Date of the Mitigation Summary:
Changes since Project Impact Assessment
Was the Project Impact Assessment substantially amended in response to public comment or based on project revisions by the Water Bureau? If yes, attach the amended Project Impact Assessment.
Has the footprint of the project design changed substantially since the Project Impact Assessment was prepared? If yes, attach an updated map.
Has the purpose of the project changed substantially since the Project Impact Assessment? If yes, describe the changes.
Have conditions in the watershed changed since the Project Impact Assessment (e.g., a large natural disturbance or discovery of a new sensitive resource)? If yes, describe the changes and update the impact assessment if needed to accommodate the change.
Mitigation of Potential Impacts
The Mitigation Summary should include the following content:
• Summarize mitigation measures to comply with City, county, state and federal regulations and permits as they apply to potentially significant impacts identified in the Project Impact Assessment
• Summarize provisions of existing regulatory compliance plans that apply to potentially significant impacts in the Project Impact Assessment the project and summarize how they will be implemented
• List the Water Bureau SOPs that apply to the project and summarize how they will be implemented to mitigate potentially significant impacts identified in the Project Impact Assessment
• Summarize additional planned mitigation measures, if any, that surpass what is required by the regulations, permits and regulatory compliance plans listed above
Alternatives to the Water Bureau Project Design
If potentially significant impacts described in the Project Impact Assessment cannot be effectively avoided, minimized or mitigated, then the Mitigation Summary must also:
• Describe the no action alternative, including any consequences to the Water Bureau or water system if the project does not proceed
• Describe at least one alternative project design or mitigation strategy with less impact than the Water Bureau’s chosen project design, including any consequences to the Water Bureau or water system if the alternative were to be implemented
Exhibit D Water Bureau Best Management Practices, Standard Operating Procedures and Regulatory Compliance Plans
The following documents describe best management practices, protocols and procedures routinely applied to avoid, reduce or mitigate the environmental impacts of City projects inside the Bull Run Closure Area. Best management practices are documented in standard operating procedures (SOPs) and in standard contract specifications (Bull Run Special Provisions).
PCC 21.36.050 G3 requires the Bull Run Special Provisions to include relevant requirements from PCC 21.36.050 so that those requirements can be incorporated into project-specific contract specifications. PCC 21.36.050 G4 requires that:
“The Portland Water Bureau must establish best management practices (BMPs), on an ongoing basis, to be employed in the implementation of ongoing routine programs and during emergency responses. The BMPs must avoid, then minimize and mitigate, impacts to City land in the Closure Area to the greatest extent practical. The BMPs must be consistent with, and at least as protective as, comparable BMPs on national forest land in the Bull Run Watershed Management Unit. BMPs must be documented in standard operating procedures. BMPs must enable compliance with applicable City, county, state and federal requirements and permits.”
• Bull Run Closure Area Security Procedures (Section 00202, Bull Run Special Provisions)
• Bull Run Watershed Closure Area Special Requirements (Section 00203, Bull Run Special Provisions)
• Bull Run Watershed Closure Area Seeding (Section 01030, Bull Run Special Provisions)
• Tree Protection SOP
• Invasive Plants SOP
• Aquatic Invasive Species SOP
• Wet Weather Construction SOP
• Hazardous Materials Spill Reporting, Storage and Disposal SOP
• Northern Spotted Owl Guidelines
• Human Sewage Containment SOP
• Bull Run Access SOP
• Industrial Fire Precaution Level (IFPL) and Fire Season Requirements
• Bull Run Water Supply Habitat Conservation Plan
• Riparian Reserve Protection Plan SOP
• Revegetation/Site Restoration SOP
• Updates to Bull Run Special Provisions to incorporate code requirements (i.e., PCC 21.36.050 Sections H, I, J and K and any relevant SOPs created after adoption of this rule)
• Inadvertent Discovery Protocol (for protection of cultural artifacts)
• Historic Properties Management Plan
• Manual for Built Resources
• List of sensitive species that are likely to be present on city-owned lands in the Bull Run Closure Area as identified using information from the Oregon Biodiversity Information Center, the ODFW Sensitive Species List or the Oregon Conservation Strategy Species List