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<br />May 22, 2006 <br /> <br />Peggy Keppler, <br />The proposed stormwater ordinance and manual go a long way toward meeting the <br />NPDES permit requirements and implementing the outcomes of the completed basin <br />plans. This step toward increased water quality and flood control is appreciated citywide, <br />yet there are certain places where these proposed actions fall short of the best we can <br />achieve. Part of that is due to the fact that not all basins have completed basin plans to <br />inform the ordinance, and part ofthat is due to omissions or adjustments that could be <br />made to the proposed ordinance. Below I have outlined the concerns of the Santa Clara <br />Community Organization's Land Use Subcommittee on this issue and have <br />recommended changes where they seem feasible. <br /> <br />The River Rd/Santa Clara basin comprises approximately one fourth of the total area <br />for all seven basins covered by the proposed ordinance. The quality and quantity of <br />stormwater runofffrom this basin needs to be reflected in the ordinance and manual <br />being proposed for adoption. According to the process outlined by the city for <br />developing integrated strategies from the six basins, identifying, evaluating, and <br />developing proposed capital projects and development standards for each basin <br />precedes the development of an ordinace and BMP manual. (see 13 step process in <br />Volume I of the City's Stormwater Basin Master Plans) <br />The River Road/Santa Clara stormwater basin master plan is unfinished. Given that <br />this basin lacks piped stormwater infrastructure (the primary vehicle for stormwater <br />conveyance and treatment in the rest of the city) and instead relies on natural drainage <br />and open waterways, the challenges of meeting water quality and quantity goals there <br />require different solutions. <br /> <br />. PERVIOUS OR IMPERVIOUS? <br />The transition from undeveloped to densely developed correlates to a change from <br />pervious (vegetated land that allow water to infiltrate into the ground) to impervious <br />(roofs, roads, parking lots, driveways) surfaces. Impervious surfaces can not absorb or <br />infiltrate precipitation resulting in greatly increased runoff volumes, higher peak flows, <br />and higher concentrations of pollutants. According to the draft basin plan, our projected <br />percentage of impervious surface at buildout will be 51 %, the highest of all the basins. <br />Given that we have no piped system and thus no possible "mechanical fix" to adequately <br />filter out pollutants, or slow velocity of stormwater, we need to maintain a higher level of <br />impervious area to allow natural filtration and percolation of stormwater into the ground. <br />Preserving and enhancing the existing natural stormwater system is more cost effective, <br />efficient, requires less maintenance, and the system increases in value and efficacy over <br />its lifespan. The goals of the ordinance are best met through development standards, not <br />capital projects in this basin. We need to have language in the ordinance that reflects <br />these priorities for a functioning natural stormwater system. <br /> <br />. WATERQUALITY <br />Water quality data for this basin is missing. There has been no macro invertebrate <br />sampling (useful in evaluating water quality issues i.e.: cumulative effects of pollutants <br />