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<br />May 8, 2006 <br /> <br />I' <br />" / <br /> <br />Mayor and City Council <br />777 Pearl Street <br />Eugene, Oregon 97401 <br /> <br />SUBJECT: Proposed Stormwater Manual Adoption <br /> <br />As you know, the proposed Stormwater ordinance and the related Stormwater Manual have significant <br />implications for development and the related urbanization that resul~ from development. Although these draft <br />documents are expected to address a variety of circumstances and specific basin area assumptions, the River <br />Road/Santa Clara area, with it's own specific circumstances, does not appear to have been considered. <br /> <br />While stafIhas done a great job of reaching out to neighborhood organizations and others in an effort to inform <br />, 'and educate citizens about the proposed polices, we would like to request an additional 2 or 3 weeks to prepare <br />written comments. The review and preparation of comments has proven to be complex and time consuming. <br />In an attempt to be proactive rather than reactive, citizens from the RR/SC area would like to offer useful and <br />reasonable suggestions for improvements specific to the RR/SC Basin. However, we have found it challenging <br />to prepare suggestions for improvements as the issues ARE so complicated, and the learning curve is steep. <br /> <br />, For now, I have two examples of issues of concern : <br />. Section 1.4.2, Destination Design Methodology, states "The City of Eugene has developed a flood <br />control strategy for each of the drainage basins within the Urban Growth Boundary and published its <br />findings in the 2002 Stormwater Basin Master Plans." However, no such strategy has been adopted for <br />the RR/SC Basin. As a result, the Flood Control Design. Storm information does not include the data <br />necessary to evaluate the capacity of storm drainage facilities for the desired level of protection for the <br />RR/SC neighborhoods. <br /> <br />. Section 2.2.1, Simplified Design Methodology Approach, states, in part, that "the simplified approach <br />is a relatively easy process for selecting and designing combined pollution reduction and flow control <br />facilities, intended to save the project developer and the City time and expense." This is a <br />shortsighted justification for the simplified methodology. We suggest including language that addresses <br />the intent of the simplified design methodology to encourage implementation of natural systems' <br />functions' where appropriate, and that articulates the value of protecting and preserving open waterways, <br />groundwater, native vegetation, and soils that contribute to stormwater filtration, percolation, and <br />conveyance. After all, the simplified approach might be most appropriate for specific sensitive areas, <br />such as the RR/SC Basin. This methodology shouldn't be promoted as just a fast/cheap tool for <br />developers but rather as an efficient tool for maximizing the benefits and functions of natural stormwater <br />maintenance. <br /> <br />From these two examples, I hope you all can understand how important it is for the RR/SC Basin to receive <br />more attention from this proposal than is currently proposed. Tharik you for your time, and for considering our <br />request for a 2 - 3 week extension of the written comment period. <br /> <br />R dy <br />455 ~ River Road <br />RUQ'ene OR 97404 <br /> <br />