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<br />Finding:The erosion program will be adequately staffed and administered to ensure <br />it will not cause any delays in the issuance of building permits. Other non-building permit <br />construction activities, such as quick-start agreements and grading permits may be affected. <br />Quick permit turnaround is a high priority for the program. <br /> <br />Comment 11. There is no documentation of an erosion problem related to <br />construction activities. <br /> <br />Finding: During the time of development of the program (1995), surveys of <br />construction site for a variety of land use types, including single family residential, revealed <br />erosion, sedimentation, and other impacts related to construction activities (trash, improper <br />storage of toxic materials). <br /> <br />Comment 12: Some of the professions listed as qualified to prepare construction site <br />management plans are less qualified than contractors and builders. <br /> <br />Finding: The list generally represents those professions familiar with the building <br />and construction trades. This list has been reviewed and recommended by a Department <br />Advisory Committee that includes a cross-section of occupations including a home builder. <br />There is a provision that allows the City Manager to approve additional professions on a <br />case-by-case basis. Therefore, there is no need to adjust the rule at this time. <br /> <br />Comment 13: How can City justify this program in-light of Ballot Measure 47? <br /> <br />Findine: The erosion program is financed through erosion permit fees and, <br />therefore, is not dependent on property tax revenues. Protecting water quality is a federally <br />mandated program for the City of Eugene. Erosion prevention is a component of that <br />program. <br /> <br />Comment 14: The program places too much emphasis on regulations and permits; <br />should be on an honor-basis. <br /> <br />Finding: This issue was raised at the time of adoption of the erosion ordinance. The <br />ordinance was approved by the City Council containing the level of regulations and permit <br />requirements as reflected in this Administrative Rule. This issue was addressed by the <br />Department Advisory Committee which recommended the level of regulation and permit <br />requirements as contained in the ordinance and rule. The current level was determined <br />necessary to address negative water quality impacts due to both large and smaller sized <br />construction activities. In order to lessen the extent regulations and permit requirements the <br />recently approved ordinance would have to be amended. That action is out of the scope of <br />the Administrative Rule making process. Therefore, there is no need to adjust the rule. <br /> <br />Comment 15: General public should be required to meet erosion outcomes. <br /> <br />Erosion Prevention Administrative Rule R-6.645 - 4 <br />