Item 9: Ordinance Concerning Stormwater Development Standards

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May 8, 2006 Esteemed mayor and city councilors, I am here as a concerned citizen of Santa Clara. I want to thank the public works department for its thorough outreach and education efforts with the stormwater ordinance. This exciting move forward for lower impact development has come at a time when our neighborhood land use subcommittee has been preoccupied. Upon close inspection of the ordinance and manual, we realize that the unique nature of our stormwater basin is not adequately protected by the proposed materials. We therefore ask for the hearing to be held open for two weeks to provide more cogent comments and suggested changes to the language used here. The River Road/Santa Clara stormwater basin is unique in that we · lack the stormwater pipe infrastructure found in other basins. · have an extensive system of open waterways that function as our stormwater conveyance . have a high water table with many residents actively relying on domestic and agricultural wells . are supported by soils and pervious surfaces that allow rates of percolation which recharge our groundwater . do not have a completed Stormwater Basin Plan The Stormwater Basin Master Plan for River Road and Santa Clara is unfinished (an initial study was published in August of 2002). The study states that the city does not have a comprehensive data set on the drainage system nor adequate data on aquatic habitat and species in the basin. Without clearly defined characteristics and a thorough understanding of how our system functions today, we do not see how this ordinance can effectively address the needs of our basin. An inspection ofthe initial study document reveals that conclusions about the effectiveness of the present system to control water quality were not based on data taken within the basin. Instead sampling done in basins with wholly different stormwater collection and conveyance systems was used to make assumptions about our water quality. The goals ofthe ordinance and manual are admirable but limited, and fail to take the logical first step in stormwater management. They are limited in that they do not address the protection of groundwater, natIve vegetation, and soils that" all playa dramatic part in stormwater filtration, percolation, and conveyance. The ordinance stumbles over its first step by promoting engineered and manufactured solutions without first recognizing and prioritizing the preservation and enhancement of existing natural features that already meet the goals ofthe ordinance. For instance, the ordinance definitions of flow control facilities, pollution reduction facilities, and stormwater management facilities should be amended to have two subsections, one that recognizes natural and existing facilities and another that defines engineered and manufactured facilities.