addition doctors tend to locate where there is a sufficiently large market base from which to attract sufficient numbers of patients of the type and level of affluence that will enhance their practice. Naturally, specialists must be able to draw from a significantly larger market than generalists, to generate their higher income expectations. Doctors are also concerned that there be sufficient qualified back-up providers of the same professional skill-level as themselves, both so as to provide for coverage during off-duty time and incase of a procedure "going bad", or simply to allow discussions of a case with a peer.

A 15-bed hospital is not going to provide a sufficiently strong stimulus for any M.D. to consider relocating to St. Helens. While there is a charm about St. Helens it is no "destination point"; there are neither cultural nor economic "magnets" and only limited recreational use of the river. Therefore St. Helens is unlikely to be of any great incentive from the standpoint of the level of social life and professional support that many M.D.s would expect.

Unless the Hospital District first recruits a sufficient number of M.D.s who are willing to practice at the proposed SHH; who will contractually commit to say, a five-year stay; and who will do so without any financial subsidy to their incomes being paid by the hospital, the doctors will be provided from Legacy's medical staff on an on-call basis. They will not likely become residents of the area.

We must also consider the scholastic achievement levels of the schools in the area and their ability to provide the type of scholarship requirements that an M.D. would demand for his or her children. I do not personally know the level of our schools in respect to their success rates with University entrance criteria, but with the "report card" from the US. Department of Education in 2003, it appears that our schools are not high on the achievement scoreboard. The ability of SHH to recruit more M.D.s to reside in the area seems highly suspect.

PROPOSED HOSPITAL MARKET/SERVICE AREA

With respect to the market area, I am of the opinion that the proposed SHH is going to be drawing patients only from the immediate St. Helens area, i.e. the City and its immediate environs, perhaps also including Columbia City. Speed in the delivery of high-tech care techniques is often the difference between life and death. Residents of Warren and Scappoose would be ill-advised to drive 15 minutes West to a 15 bed facility in St. Helens, (probably not M.D. staffed 24/7) when in about the same length of time driving East, they would have the entire selection of hospitals and services that Portland provides, including some of the finest trauma, obstetrical, burn and children's specialty providers in the State. Similarly, anyone in Deer Island, Goble, Rainier, Clatskanie or further West would be foolhardy to drive to St. Helens, in doing so, ignoring the bridge that would take them to a considerably larger, better staffed and equipped hospital, St. John's in Longview. In my view, the market is established as St. Helens City and its immediate "metropolitan area" (zip code 97051)

The Study's use of historical "market-share" data from the old District Hospital, which was a full-service facility, is inappropriate to this proposal.

ON-SITE PATHOLIGICAL LABORATORY SERVICES NOT A LIKELY OUTCOME

The location of on-site laboratory services is of virtually no concern to most M.D.s since the results are quickly available on computers, so that testing may be done many miles away from the doctor who is reading the test results. Indeed, the white cars from Providence and Legacy hospital systems' laboratory services can be seen frequently on the road between the St. Helens service area and Portland, transporting specimens to their centralized Portland laboratories. Legacy, as Managers of the SHH will perform Pathological laboratory testing at their central laboratories and will not duplicate these services in St. Helens, at great cost, solely for use by SHH doctors.

A 15 bed facility is not likely to be able to support any "out-reach" services to any other area close by and certainly not to, for example, Vernonia; residents of which would be far better served by Tuality hospital in Hillsboro or St. Vincent, Beaverton, both situated conveniently near major arterial highways. Both of these hospitals are far better equipped and staffed than SHH could ever expect to be.

SERVICE AREA POPULATION OVERSTATED

Total population of the St. Helens Census County Division (zip code 97051) is given as 19,812 in the 2000 Census Data The comparable population in 1990 was