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Edward Abbey memorialized environmental resistance to mindless development in his tome The Monkey Wrench Gang.

It essentially endorsed sabotage to thwart degrading of the natural world, for instance, putting sugar in the gas tanks of bulldozers that are about to plow under a nice area.

However, advances in surveillance make traditional monkey wrenching almost suicidal.

But we can still cram a stick into the spokes of “progress”  by submitting lengthy criticisms of poorly planned projects, and even defeating them in the permit stage.  I refer to this tactic as “monkeywrenching” with paper.

A rich guy want to build yet another gas station right next to precious wetlands.  We swore to clog up his development engine with paper.  It’s worked so far, and the agencies were out there yesterday, too.  I escorted an inspector to the groundwater seep, and to the oily trickle that drains off of the lot of the creek. Here is the complaint letter.

Dear Commissioners:

I speak to you in your roles as Directors of Clean Water Services.

I am the organizer for Protect Bethany Lake Environmental, a group of over 200 local residents who oppose the magnitude of impacts from a proposed gas station on the very edge of a wetland, at 185th and West Union.

The developer withdrew his scheme, but now has re-applied.  During our project review, we noticed several errors and omissions, and ongoing violations to the “Service Provider Letter” that Clean Water Services’ consultant issued to “RJ Barman” in file # 17-002833.

I offer details of our concerns.

The developer has already commenced site preparation.  In and about 2017-2020, the developers have removing leaking gasoline tanks, but left tainted soil behind,  dug up in the front of the adjacent house, demolished the former asbestos-ridden Greek Deli, and left  large holes in part of the lot.

They have torn down part of an 3rd existing building at about 18300 NW West Union, and piled waste wood, roofing, and rubble on/near Tualatin Hills Park Lands that the District states were improperly filled.

Here are some existing violations of the current Provider Letter.

Condition 1 prohibits construction activities and dumping materials of any kind that may affect water quality.  

But storm water runoff from the discarded tarpaper, waste wood, exposed nails and rubble from the partly destroyed building will deplete oxygen in the receiving waters just a few feet from the rubble pile. I’m attaching a photo of this rubble that appears to be partly on Park Lands.

The Park lands are to the right of where the hot water heater lay,   

Condition #2 requires the developer to survey and fence the land prior to any site clearing. However, the owner has already commenced site clearance, as pictured, without meeting the listed conditions.  

Condition #5 also requires an erosion permit prior to earth disturbing activities.  This area has become a “slow motion” construction site, with demolition, backfilling, waste materials storage, and asbestos and toxic waste removal ongoing in fits and starts since 2017. But the site lacks such common construction site features as a current silt fence, collection ponds, or enclosing or covering waste materials.

Condition #8 limits removal of native woody vegetation to the greatest extent practicable.  However, the Developer proposes to eliminate every single one of the 20 trees in the property.

Three large mature trees next to the 80-year old house, some with 30-foot girths that exceed the size of some of Oregon’s heritage redwoods, will be cut down and replaced with inch-thick shrubs. One tree survived a clawing by a bear, but may not survive a mauling from Chevron. I’ve attached a picture of three of the mature trees.

The THPRD’s submitted maps and comments to Paul Schaffer on May 20, 2020 related to this proposal (attached).  Their marked-up aerial showed those mature trees, and several smaller trees slated for cutting, are partly on THPRD land.  The THPRD maps also pointed out illegal dumping, and filling of Park land.

All of these trees are important, because they provide valuable shade and habitat to the directly adjacent tributary of Rock Creek.  It will take decades, if ever, before the trees will be replaced.

Doug Fir on right.

The developer’s own maps show the entry way can skirt the trees.

Nonetheless, the developer’s consultant  claims there is 0% Canopy, and 0% native species on the site. We dispute that conclusion, and so does the mature Doug Fir and other trees on the site.

Condition #9 refers to a swale and water detention pond. But none of the Project’s site maps ever had a swale and detention pond.  Stacey Benjamin, the permit writer, was a consultant and no one at CWS can tell me where to find her and explain this conflict.

The plan drawings call for collecting the site’s wastewater underground, and discharging it into the Park’s wetlands.  We are attaching the Site plan that Benjamin initialed.  The current Service Letter referring to a pond are not accurate.


The developer has left an ugly mess at 18300 to 18450 West Union since July, with rubble piled on or next to the sensitive areas of our Parklands on the east end, and thorny blackberries blocking part of the sidewalks.  Poorly graded areas on the west end allow silty oily runoff to flow into the wetlands.   It’s an obnoxious and harmful eyesore right by our Greenway.  We ask that Clean Water Services rescind their Service Letter.  

We ask the opportunity to comment on any new or amended service letter or NPDES permit for this site.

If the County finds that the developer commenced site clearance affecting vegetated areas without complying with the Letter’s conditions, we urge prosecution.

Very Truly Yours,

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  • December 19, 2020