Laserfiche WebLink
<br />comments on ~tormwater Development Urdmance and lStormwate <br /> <br />Page 1 ot 0 <br /> <br />KEPPLER Peggy A <br /> <br />Becky Riley [briley@efn.org] <br />Monday, May 22, 20064:50 PM <br />KEPPLER Peggy A <br />WALCH Therese; COREY Kurt A; MUIR Susan L; CARLSON Jim R; TAYLOR DennisM; YEITER <br />Kurt M <br />Subject: Comments on Stormwater Development Ordinance and Stormwater Management Manual <br /> <br />From: <br /> <br />Sent: <br />To: <br />Cc: <br /> <br />May 22, 2006 <br /> <br />COMMENTS ON STORMW ATER DEVELOPMENT ORDINANCE and STORMW ATER <br />MANAGEMENT MANUAL <br /> <br />We, residents and neighborhood leaders from River Road and Santa Clara, appreciate the opportunity to <br />submit additional comments on the Stormwater Development Ordinance and accompanying Stormwater <br />Management Manual. <br /> <br />We are glad to see that Eugene is joining the many communities around the country that are adopting <br />development standards that require installation of stormwater flow control and pollution control <br />facilities that mimic natural systems and discharge stormwater close to the source. It is encouraging that <br />the City recognizes the importance of such controls, and the benefits of more naturalistic stormwater <br />systems. <br /> <br />This ordinance has enough beneficial aspects that we encourage its adoption as soon as possible. <br />However, there are a number of shortcomings of the ordinance that we hope can be addressed, either in <br />amendments now or later. Several aspects will require more detailed consideration. These <br />shortcomings are: <br />* Too much development is exempted from pollution control provisions--that which adds less than 3000 <br />sq. ft. impervious surface <br />* It fails to recognize and protect existing soils, vegetation, and trees--despite their superior capabilities <br />to store and filter stormwater <br />* It doesn't go far enough to protect existing drainage ways <br />* It fails to take into account the particular needs of the sensitive River Road-Santa Clara Basin and its <br />"natural" drainage system <br /> <br />We offer more detailed section-by-section comments below--but a few more general comments first. <br /> <br />Eugene Needs to do More to Preserve Natural Hydrology in the Urban Area <br /> <br />The Stormwater Management Manual (1.1 Purpose) says: "The purpose of this manual is to provide <br />stormwater management principles and techniques that help preserve or mimic the natural <br />hydrologic cycle and achieve water quality goals." However, the purpose of "preserving" the <br />natural hydrologic cycle is not carried over as policy guidance in the ordinance. It is also barely <br />addressed in the "text of the Manual, which is devoted to describing constructed stormwater "facilities" <br />that mimic natural stormwater systems. The only exceptions are the section offering credits for <br />preservation or planting of trees as an optional "pollution control facility" and the section listing <br />conditions that must be met when drainage ways are filled. Otherwise, protection of soils, trees, <br />vegetation, and drainage way--and their superior infiltration capacity--is ignored. This is a major and <br /> <br />5/23/2006 <br />