Portland’s Forest Park is one of the city’s most treasured natural features, and among the largest urban forests in the United States. Stretching across more than 5,000 acres in Northwest Portland, from outer West Burnside Road well past the St. Johns Bridge, the park is visible from miles away as a mass of giant Douglas firs, grand firs, big leaf maples, and more. Beneath the tree canopy, the park is home to hundreds of species of birds, mammals, and invertebrates.
Despite its status as a public park, Portland General Electric (PGE) wants to use a swath of the forest for a new utility project.
PGE’s proposal represents the third phase of its Harborton Reliability Project. The project would involve removing nearly 400 trees from a roughly five-acre area of the park to make changes to an existing power pole in the area, and add two additional poles to support 1,400 feet of new transmission lines.
In order to begin work on the project, PGE needs several permits from the city, including an approved environmental review. At a January 29 land use hearing, there was unanimous agreement about the park’s ecological significance and community value. But PGE faced significant pushback for its assertion that the project would be a net gain for climate action in Portland, creating minimal—and mitigable—impacts on the park.
According to a report from Portland Permitting & Development (PP&D) staff, the project would also result in the permanent fill of two wetlands, and impact two streams. The trees, wetlands and streams all support animal and plant life, including native shrubs and plants, fish, frogs, and birds.

These frogs are the ones volunteers shuttle across nearby Highway 30 during breeding season.
oregon department of fish and wildlife
The proposal has garnered substantial controversy since PGE first proposed it, receiving strong pushback from environmental advocates and conservation groups who wanted to see the utility company look into alternatives. Many project critics say they appreciate the need for increased electricity capacity needs, but don’t believe those resources need to come at the expense of so much treasured flora and fauna. They also worry this project could set a precedent for further exploitation of Portland’s natural resources for corporate gain.
The critics’ argument was bolstered by the PP&D report, which recommended the hearings officer deny PGE an environmental review for the project and prevent it from moving forward. The report cites other local agencies, including Portland Parks & Recreation, the West Multnomah Soil & Water Conservation District, and the Oregon Department of Fish and Wildlife, which disapprove of the proposal due to its impacts on the natural environment.
PGE disputes their claims, and says the project is necessary in order to “resolve a critical bottleneck in the grid” and meet future energy demand, which will increase along with climate change-induced extreme weather events.
Portland versus PGE
At the January 29 land use hearing, city staff reiterated PP&D’s determination that PGE failed to demonstrate a lack of better alternatives for the project location. The PP&D report also claims PGE didn’t prove it can mitigate for the “long-term impacts of the removal of 4.7 acres of healthy and viable mature forest,” and says overall, the proposed project is out of compliance with the Forest Park Natural Resources Management Plan, which dictates plans for the area.
The staff report also mentions concerns including increased wildfire risk from introducing new transmission lines into a heavily vegetated area. Importantly, staff also contended PGE’s required alternatives analysis—which must show “alternative locations and design modifications were considered” to create a proposal “with the least significant detrimental impacts”—was insufficient.
According to the city’s report, the utility company disqualified one of the alternatives it studied due to an obstructing power line—that PGE itself owns. The company said it would take at least six years to “design, permit, purchase properties, demolish/relocate the existing line, and construct this alternative.”
City staff don’t buy this excuse, stating “the ability to mitigate this impediment lies solely within the purview of PGE.” Since the applicant has stated it began planning the Harborton Reliability Project nearly a decade ago at this point, it would’ve “had plenty of time to explore and implement these options outside of Forest Park.”
“The applicant cannot create their own timing problem and then use it as a parameter to rule out other viable options,” the report states.
"The applicant cannot create their own timing problem and then use it as a parameter to rule out other viable options."
According to PGE, however, this is one of many issues the city got wrong.
“We have studied over 20 possible alternative projects, extensively and exhaustively,” Randy Franks, senior project manager at PGE, said at the hearing. “The proposed project is not only the best solution, but the only available one.”
PGE planners say they eliminated every other option because of environmental and community impacts, failure to meet the goals of the electricity project, or additional costs that would be placed on customers.
“When these proved infeasible, PGE worked to reduce the project area and the number of trees that needed to be removed,” the project website states.
David Peterson, a lawyer representing PGE, also refuted the city’s claims and called the staff report “very unusual,” insinuating a bias against the utility company. At the end of the hearing, Peterson said PGE found it “disturbing” two city employees testified against the project during the public comment period, calling it a “clear conflict of interest.”
The utility company and city staff are at odds when it comes to interpreting Forest Park’s management plan.
Peterson said city policy “allows for utility uses in the park,” and the Forest Park Natural Resources Management Plan “offers guidance for the city and utilities to collaborate on conservation laws, not to prohibit any future development.” But city staff think PGE’s proposal is incompatible with the management plan’s conservation goals, and don’t agree with the utility’s interpretation of the rules.
Missing the forest for the trees?
PGE says bolstering the power grid is a key part of meeting Portland’s climate goals, as more households start using electric appliances and vehicles. The company has presented its Harborton Reliability Project as both a strategy for climate action—it will “deliver reliable power…as we move to a cleaner energy future”—and a way to prevent blackouts during extreme weather events.
But it will come at the cost of significant ecosystem impacts and the loss of hundreds of trees. Project critics pointed out the forest is a crucial tool in combatting and mitigating the effects of climate change, too.
“PGE states this project will enhance climate resiliency. There is no evidence this project will reduce greenhouse gas emissions,” Carole Hardy, a forest ecologist and member of the Forest Park Conservancy board of directors, said at the January 29 hearing. “There is substantial worldwide scientific evidence that old forested ecosystems and wetlands sequester carbon and help mitigate the worst of climate change.”
Similar sentiments were repeated by dozens of speakers at the hearing, and addressed in the city staff report.
“Dense stands of mature trees offer beneficial carbon sinks which off-set carbon emissions created by urban environments of which Forest Park is mainly surrounded,” the report states. Staff wrote removing trees is harmful even “in the light of asserted long-term benefits of the proposed utility upgrades and expansions which the applicant argues would off-set the impact.”
PGE disagrees. At the hearing, Peterson said advocates have overstated the problem, as saving the impacted trees would not “absorb enough carbon to significantly affect worldwide climate change.” He said people concerned with the climate crisis should “balance [the project’s impacts on Forest Park] against the scope of carbon reduction this project will unlock by increasing the ability to use carbon-free electrical sources.”
Peterson disputed the notion that “Forest Park is a hands-off time capsule that must be protected from impacts at all costs,” which he said the staff report and climate advocates perpetuated.
Frank Mungeam, who identified as a supporter of the Forest Park Conservancy and media professional focused on improving news coverage of the climate crisis, said “adding electrical transmission capacity and reliability is essential for the quality of life for all Portland and regional residents.”
“Meeting our growing energy demand in a warming world requires us to electrify everything possible…there are no zero-impact options to meet this need for sufficient reliable power,” Mungean said. “NIMBY is not a policy and NIMBY is not a strategy.”
“Meeting our growing energy demand in a warming world requires us to electrify everything possible…there are no zero-impact options to meet this need for sufficient reliable power."
NIMBY, which stands for “not in my backyard,” is an acronym with a fraught history in the environmental movement. As the climate crisis has worsened, certain groups of conservationists across the country have been met with backlash for opposing clean energy projects, like solar farm developments, due to their supposed land use impacts.
Damon Motz-Storey, director of the Sierra Club Oregon Chapter, clarified their organization “supports building infrastructure to address electricity reliability in the face of climate change and a just transition to renewable power.”
“But we have important choices in where and how we build and upgrade transmission lines,” Motz-Storey said. “It’s clear to us that there are ways in which PGE can build this project without causing incredible damage and setting a dangerous precedent that it's okay to build wires all over Portland's crown jewel park.”
“It’s clear to us that there are ways in which PGE can build this project without causing incredible damage and setting a dangerous precedent that it's okay to build wires all over Portland's crown jewel park."
PGE officials have also stated their mitigation plan will fully restore or even improve upon the current conditions in the project area. The project’s proposed habitat mitigation plan includes planting oak woodland habitat throughout the transmission corridor area, as well as riparian plants adjacent to the streams and native wildflower and grass seed to support pollinator species. PGE also proposed paying a roughly $2.46 million in-lieu fee to Portland Parks & Recreation to further assist with ecological restoration outside the immediate project area.
“This is where staff are literally ignoring the forest for the trees,” Peterson said at the hearing. “The evidence shows in the long run, implementation of the mitigation performed by PGE and through the in-lieu fee…biodiversity is improved, habitat is restored, migration opportunities enhanced, valuable oak woodland habitat is created and the forest is better.”

But some of the trees proposed for removal are hundreds of years old, and cannot be easily replaced. The city staff report called the natural resources in the project area “arguably unmitigable” and said PGE’s proposal “lacks demonstrable plans to achieve what mitigation is proposed.”
The report cites a comment from the Coalition to Protect Forest Park, which called PGE’s claims that its project and mitigation plan will actually increase biodiversity “mind-boggling.”
“This may not be the first time a utility has said something [like that],” the Coalition said in a statement. “But it certainly must be the first time such a claim has been made about Forest Park.”
Future impacts
For many project opponents, the most concerning part of PGE’s proposal is the precedent it could set for future development in Forest Park and other protected natural areas. PGE officials say this phase of the Harborton Reliability Project is the only one on the table, and that if built, it will not make any future phase “any more or less likely to come about.” Others aren’t so sure.
According to the city staff report, PGE has shared “topical details” about the Harborton Reliability Project’s potential fourth and fifth phases. (The first and second have already been built or are currently in construction, and the third phase is what’s on the table now.) But city staff don’t feel the company has made it clear how interconnected these potential future phases are with the current proposed project.
Staff do believe, however, that the future phases would also be located within Forest Park, and could lead to nearly 15 acres of impacted mature, closed-canopy forest and waterbodies in Forest Park. They also emphasized the lack of transparency and communication by PGE about the future phases, a concern many people echoed during the hearing.
Others raised doubts about the true reason PGE feels compelled to build the project with such urgency. The company maintains the increased electrical capacity is meant to serve residential and commercial customers in North and Northwest Portland, but some people think it’s more likely the project is planned to accommodate manufacturing and data centers west of the city.
Franks, the PGE senior project manager, said claims that “the benefit of this project only goes to big data or major manufacturing” are incorrect, and emphasized the benefits the project would have for all Portlanders.
Skeptics point out that while residential energy demand has grown in recent years, the demand increase is much larger in the industrial sector. According to PGE’s data, electricity demand from the utility’s industrial customers has grown by more than 30 percent in the last five years. Residential demand has only increased by about five percent.
PGE has previously faced backlash from Portland residents—and even Oregon’s US Senator Ron Wyden—for its residential rate hikes. The company’s own data show a significant reason for these increased costs is demand from the semiconductor manufacturer and data industries.
Critics say starting work on the project in Forest Park may make the park appear viable for future development aimed at the tech sector. Motz-Storey said they think moving forward with phase three would clear a path for the utility to argue it “should be allowed to build over priceless trees in Forest Park” to serve Washington County’s tech center.
Portland’s Hearings Office is expected to make a decision on the case in early March. If the city denies an environmental review, PGE is expected to appeal the decision with Portland City Council, and potentially take legal action.