Item 9: Ordinance Concerning Stormwater Development Standards

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Page 1 ot '2 KEPPLER Peggy A From: Anita Van Asperdt [anita@modemmedium.com] Sent: Monday, May 22,200612:20 PM To: *Eugene Mayor and City Council Cc: KEPPLER Peggy A Subject: Stormwater Ordinance Comments To the Mayor and the City Council of Eugene. As one of few rainwater harvesting experts in Eugene and a registered landscape architect, I have a few comments to make before you approve and implement the new stormwater development standards ordinance. I have one small point to make about he new ordinance under point 9.6794. It states that source control is needed when the site stores "High and Low-risk hazardous materials". This is confusing, it almost reads as if medium risk materials are not included, why not just state "hazardous materials". My bigger issue has to do with Rainwater Harvesting. Upon reading the ordinance I understand that Rainwater Harvesting can be used as a "Flow Control" and "Pollution Reduction" Facility. City Staff member Peggy Keppler mentioned that the manual on Rainwater Harvesting should be treated as a guideline not as code or regulation. However, the new code says under point 9.6791 Standards: "Locate, design and construct pollution reduction facilities in accordance with adopted plans and policies, Chapters 6 and 7, and the Stormwater Management Manual." and under 9.6792 Standards is says: "Locate,design and construct flow control facilities in accordance with adopted plans and policies, Chapter 6 and 7, and the Stormwater Management Manual." I can only conclude from this that the flow and pollution reduction facilities have to be designed, located and constructed according to the Stormwater Manual. I find two stipulations in the Manual regarding Rainwater Harvesting objectionable. 1. The Stormwater Manual mentions that Harvested Rainwater "may be collected for non-potalbe water uses". I advice you to strike that from the manual and replace that with "may be collected for water uses to be determined upon further city staff study." 2. The Manual furthermore stipulates that hydrologic calculations need to be included on the permit package. Since water collected in a cistern does not infiltrate I am wondering what these hydrologic calculations entail. I advice you to direct city staff to replace this requirement with "hydrologic or holding capacity calculations to be determined upon further study by city staff'. There will be a meeting on June 8 on Harvesting Rainwater. I understand that on this meeting a discussion will take place on how Rainwater Harvesting should occur in the city of Eugene. Accepting the stormwater ordinance with its strong reference to the Stormwater Manual as it is drafted now seems to pre-empt this meeting. I urge you to direct staff to rewrite the text in the Stormwater Management Manual so that it is clear that further study on Rainwater Harvesting still needs to occur or to rewrite the text so that it is clear that the stipulations in the Manual shall be treated as guidelines only. 5/22/2006