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Development standards to address pollution from private development would be more <br />effective than treatment and infiltration of flows associated with drywell <br />decommissioning and therefore should be a higher priority. [RR -121 <br />Both are important and necessary aspects of the stormwater management strategy for RR -SC and <br />are not mutually exclusive actions. Stormwater Development Standards are necessary for <br />meeting the Clean Water Act and associated municipal stormwater permits issued to the City of <br />Eugene (National Pollution Discharge Elimination System, or "NPDES" Phase I permit) and <br />Lane County (NPDES Phase II permit). As described above, the City's stormwater development <br />standards apply to properties inside city limits as well as any properties annexed to the city from <br />the urban growth boundary. These standards address the water quality impacts from new <br />development and re- development sites within city limits. Addressing existing UICs that must be <br />decommissioned for lack of separation to high groundwater levels is also necessary to meet Safe <br />Drinking Water Act regulations (see Department of Environmental Quality, or DEQ, web site for <br />more information about UIC regulations and pending permits for municipalities utilizing UICs: <br />ham: / /www.deq. state .or.us /wq /uic /permits.htm Providing treatment and conveyance for <br />stormwater currently directed to certain UICs is necessary to address the potential water quality <br />impacts to surface water (of surfacing water currently directed to sub - surface — for UICs <br />decommissioned utilizing a piped system) and groundwater (to provide treatment of water <br />directed to sub - surface, prior to reaching groundwater — for UICs decommissioned utilizing rain <br />gardens). <br />Reduce projected impervious surface area via development standards, and as a result <br />CPs would be smaller in size. Requiring low impact development standards, pervious <br />pavement for all roads, parking lots and driveways, and on -site storage and infiltration <br />of all stormwater would reduce the size of capital projects. [SC -91 <br />[RR -101 <br />As described in responses above, the City provides incentives for certain best management <br />practices (e.g. pervious pavement, eco- roofs, contained planters, and tree credits) through lower <br />systems development charges and user fees, and through impervious surface area reduction in <br />sizing stormwater facilities. The City encourages, but does not require, green infrastructure/LID <br />facilities over structural engineered facilities. The majority of residential developments, and <br />slightly more than half of the commercial developments over the past year have chosen to use <br />green infrastructure /LID facilities. Follow through on Eugene City Council direction to further <br />increase implementation of LID is underway. It is anticipated that all of these efforts will reduce <br />the total impervious surface area in the RR -SC basin and throughout the City, as compared to <br />traditional development. However, development standards and incentives affect only the areas <br />undergoing development and re- development, and must be considered in the context of the large <br />amount of existing impervious area not affected by the development standards. <br />RR -SC Stormwater Basin Plan Comments Pg.9 of 17 <br />