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it is not clear why rain gardens in conjunction with drywell decommissioning ought to be such a major focus. As above, the data is not convincing that decommissioning drywells will lead to significant additional surface water pollution that needs to be addressed near the sites of those drywells. As in our comments on Section 3, we have many concerns about the proposed local street designs with sidewalks and rain gardens. In terms of water quality, narrower "shared space" designs that do not include a separate sidewalk, and that use pervious pavement to reduce effective impervious area of the roadway, would be better choices for protecting water quality. 4.3.2. Development standards to address water quality Water quality development standards in the City stormwater manual may be sufficient to address water quality issues for new development in our Basin, unless significant types or amounts of new development (smaller and single - family units ?) are exempted from the standards. Also, we are not aware of what particular changes are being proposed for the update underway, nor what particular ways to encourage LID might be proposed under separate LID initiatives. However, there are many other low impact development standards that protect water quality that the City could consider, including those we listed above in our comments on section 3.5.3. Some of these may be lower in cost, more effective, and serve other beneficial functions besides just protecting water quality. We think additional low impact development standards should be encouraged or required for the RR- SC basin, to protect water quality and other values. As for preventing stream bank erosion, the Eugene Water Quality Protected Waterways ordinance and WQ overlay zone requirements are a good first step for protecting waterway segments that run through certain identified properties that are within City jurisdiction. However, Lane County needs to adopt similar protections that apply to waterway segments running through unannexed properties within the UGB. These waterways- - including segments of Upper Flat Creek and tributaries of the Al channel - -need protection whether or not the properties annex to the City. Section 5: Stormwater Related Natural Resources 5.2.2 Development Standards Alternatives As above, Lane County needs to adopt protections similar to those in the City's Water Quality Waterways ordinance, to protect waterway segments that pass through properties that are in Lane County jurisdiction now, and whether or not they are ever annexed to the City. Also, more protections are needed to prevent fill of waterways, even small ones, and whether or not such fill is done in the context of "development ". And low impact development standards, as listed in our comments on section 3.5.3, are needed to help ensure groundwater recharge and to help retain more natural stream flow in waterways such as Flat Creek and Spring Creek. Perhaps it is not feasible to consider more stream corridor acquisition for segments of Flat Creek or other waterways in our neighborhood, but it does seem that more could be done to educate property owners and the community about the natural values of even small waterways, and to encourage their protection and restoration. Section 6: Summary Overall, it seems that the data in this document show that the rain garden projects proposed as part of the drywell decommissioning are not needed for flood control. Also, the data is not convincing that they are needed for pollution control. If they were constructed, of course, they'd perform some of these functions. But they will replace swales that already perform these same functions, seemingly well. Does decommissioning the drywells really need to be linked to proposals for new sidewalks and wider streets and replacing our existing drainage