Item 9: Ordinance Concerning Stormwater Development Standards

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Comments on Stormwater Development Ordinance and Stormwate Page 3 of 6 Unfortunately, the proposed stormwater development ordinance and Manual have no provisions that specifically address the unique characteristics of our area, nor any special development standards that aim to protect the natural drainage system in our neighborhood. Our neighborhood is slated for a high development density. The draft Basin Plan projects that at UGB buildout, impervious surface in our Basin is expected to "increase to 51 percent, which is the highest for all of the basins." Can our "country drainage" system continue to function at this percentage of impervious surface? Alas, our Basin Plan is not complete, and drainage modeling is unverified. None of the water quality testing that has been used to develop the plan has been done in our area at all. According to the draft text (Initial Study Towards the Development of a Stormwater Basin Master Plan), feasibility and cost analysis of proposed water quality standards and capital projects have not been completed. Staff have suggested that this stormwater development ordinance and Stormwater Management Manual can be adopted separately from the Basin Plans, but something is wrong with this picture. Each Basin Plan contains proposed development standards ostensibly based on characteristics and needs of the Basin, and aimed at controlling flooding and preserving water quality. Surely it is those proposed development standards that are, or should, be the basis for these city-wide development standards. A schematic and text at the start of the draft Basin Plan describes such a process--adoption of stormwater development standards and best management practices manual AFTER completion of Basin Master Plans and integrated stormwater management strategies. In any case, the public has not had the opportunity to comment on the proposed development standards in the draft River Road-Santa Clara Basin Plan. There needs to be a more thorough review of these standards in light of the unique characteristics of our Basin and natural drainage system, and the City's development code may need to be amended in the future with provisions protective of our Basin. " Comments on Specific Sections of Stormwater Ordinance and Stormwater Management Manual: These comments address various sections of the ordinance (and relevant sections of the Manual): Definitions, destination (flood control), pollution reduction (water quality), flow control (stream bed. protection), and drainage ways section of Manual. Definitions More work is needed to clarify the definitions of Runoff and Stormwater. Runoff is not defined in the ordinance, but is defined in the Stormwater Management Manual as "Stormwaterflows across the ground surface during and after a rainfall event." But shouldn't runoff also include water flows across ground caused by human activities, such as car washes? The Manual defines "stormwater" as "water runoff that originates as precipitation on a particular site, basin, or watershed. " In contrast, according to the Eugene Public Works web site, "stormwater" is water that flows across the land -- and it is not limited to what falls from the sky. It includes water that runs off any hard surface, from roads to roofs..." The ordinance itself does not have a definition of "stormwater". It probably should. Also, the source 5/23/2006