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improvements, and the relative costs of various design options. The potential costs and impacts on <br />neighborhood character are significant. <br />Residents should have the opportunity to evaluate and compare some "shared street" options without sidewalks, <br />and some narrower driving lane and on- street parking options. Some communities and guidelines are now <br />suggesting and installing roadways as narrow as 14 feet wide for two -way traffic (18 feet of "drive- able" surface <br />counting edge treatments). Also, permeable pavement options need to be considered. The use of permeable <br />paving could reduce roadway runoff and help filter out pollutants, reducing or eliminating the need for <br />additional stormwater facilities. Residents are also interested in "context sensitive" designs that preserve <br />existing large trees, something that also has value for stormwater management. <br />3.5.3 Development standards <br />This section states that flood control development standards were not selected for implementation in other Basin <br />plans completed in 2002, for various reasons. The text also notes that detailed cost comparisons were done in <br />conjunction with the other Basin Plans, showing that it was more cost effective to use public capital <br />improvements, not a combination of public improvements and requirements on developers to address on -site <br />storage. <br />It is not explained why the same conclusions from other Basin Plans, or the rather dated cost analyses, are <br />assumed to apply to our RR -SC Basin today. It is also not clear how total costs of public capital projects can <br />(or should) be compared with costs to private developers. At the least, more explanation is needed to justify <br />why these earlier data and conclusions are relevant to the RR -SC Basin and this Basin Plan. <br />The text notes that many flooding problems in other basins are caused by "existing developed conditions ", and <br />concludes that these problems need to be addressed by new (public) capital projects (instead of new <br />development standards). It seems that other conclusions are equally reasonable. If existing (private) <br />development causes flooding, then doesn't this suggest that development standards DO need to change to <br />prevent similar flooding problems in the future? Also, shouldn't private property owners be required to address <br />existing problems on their property, rather than new public projects having to be sized to handle their runoff? <br />Portland's Stormwater code encourages, and in some cases, requires stormwater retrofit projects for private <br />property. Eugene's could do the same. <br />In any case, at least parts of the RR -SC Basin are significantly different than other Basins. Many areas in our <br />neighborhood rely more on on -site stormwater infiltration and (non - structural) natural infiltration. We also <br />have a relatively high groundwater table, and many people have and use irrigation wells. Current City -wide <br />stormwater standards allow, but do not encourage or prioritize dispersed, on -site stormwater management. City <br />stormwater codes also do not require protection of natural hydrology, nor offer enough non - structural choices <br />for accomplishing on -site infiltration. We do not believe that existing City -wide stormwater standards or <br />programs to encourage LID practices are sufficient to protect natural drainage, groundwater recharge, or surface <br />water flows needed to maintain stream ecology in our area. Surface water flows (Flat Creek, Spring Creek) <br />have already been altered by existing development. <br />Also, if projected total impervious surface in the Basin could be reduced via new development standards, it <br />seems that would reduce the few modelled and observed flooding problems throughout the system and allow <br />some of the proposed public (flood control) capital projects to be smaller in size. <br />Here are some of the low impact development standards or methods that we think need to be required or <br />promoted in our Basin, and that need to be evaluated in this Basin Plan: <br />* prioritization of on -site infiltration (as in Portland) <br />* prioritization of non - structural Best Management Practices, including <br />