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removal of significant trees and subsequent actions impacting trees on property subject to an approved <br />conditional use permit, planned unit development, site review, or subdivision that includes a tree <br />removal/preservation plan or conditions related to tree removal or preservation. Exemptions from standards <br />include development activity not subject to land use conditions on certain residential lots under 20,000 square <br />feet. For lots of 20,000 or more square feet and not subject to land use conditions, removal of up to 5 significant <br />trees within a period of 12 consecutive months is exempt. <br /> Low Potential: Develop more restrictive standards or reduce exemptions to provide for additional tree <br />preservation. Existing standards already attempt to balance various objectives. <br /> Barriers: Complexities of developing and implementing land use regulations. Additional preservation <br />requirements could adversely affect utilization of area for site design, and impact density/lot sizes. <br />Standards for Driveways and Internal Circulation <br />Driveways and access isles typically represent a small percentage of impervious areas on developed sites. There <br />may be some potential to review for consistency between LID practices and private driveway and internal <br />circulation standards; e.g. reduce driveway widths or allow adjustments to encourage use of pervious surfaces <br />and ribbon wheel paths. <br /> Low Potential: Encourage, allow or require reductions in impervious area within driveway standards. <br /> Barriers: Complexities of developing and implementing land use regulations; potentially competing <br />objectives between LID practices and elements of the standards. <br />B. Local Policy and Regulatory Compliance <br />Both local policy (Eugene’s CSWMP and Stormwater Basin Plans) and compliance with State and Federal <br />regulations (Clean Water Act and Eugene’s NPDES municipal stormwater permit) provide the framework for the <br />city’s adopted stormwater management approach and stormwater development standards, and thus guide <br />implementation of LID practices. <br /> Comprehensive Stormwater Management Plan (CSWMP) <br />CSWMP forms the local policy framework to respond to stormwater quality mandates of the Clean Water <br />Act as well as other stormwater-related community values such as the protection/enhancement of <br />wetlands and other natural resources that provide stormwater functions. CSWMP incorporates a multiple- <br />objective stormwater management approach which is wholly consistent with the implementation of LID <br />practices in the community. No changes to CSWMP are necessary to remove barriers or increase use of <br />LID practices in the community. <br /> Low Potential: CSWMP is already consistent with the implementation of LID practices. <br /> Barriers: Complexities of modifying land use plans/policies (CSWMP was adopted as a refinement to the <br />Metro Plan). <br /> National Pollutant Discharge Elimination System (NPDES) Permit <br />Eugene’s NPDES permit, a municipal stormwater (MS4) permit administered by Oregon Department of <br />Environmental Quality (DEQ) for direct discharge into the Willamette River and related indirectly draining <br />waterways, is currently undergoing a periodic renewal application process. As part of the renewal <br />requirements Eugene is required to review its programs and activities to make sure that they collectively <br />reduce pollutants to the maximum extent practicable, contain certain program elements, and address <br />certain problem pollutants. <br />While the current NPDES permit provisions generally support and complement LID practices, the permit <br />itself does not mandate or implement use of LID practices. It is anticipated for renewal of the City’s <br />NPDES MS4 permit that DEQ will incorporate additional permit conditions related to LID practices <br />including requirements to: <br /> Review codes and development standards and, where possible, remove barriers to LID practices. <br />September, 2008 City of Eugene LID Report, Page 10 of <br />26 <br />