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Additional comments received from the Santa Clara Community Organization. Therese Walch and Dan Hurley March 10, 2010 City of Eugene and Lane County Re: Comments to accompany RR/SC basin plan Therese and Dan, We thank you for meeting with us to review your comments to our criticisms regarding the RR/SC storm water basin master plan. Your offer to include a last set of comments generated by that meeting to accompany the proposal to the various elected officials is appreciated. We reiterate that the uniqueness of our basin is not adequately reflected in the proposed plan strategies and refer you to the SCCO comments of Oct 23, 2009 that highlight some of our challenges and our need for development standards to help address these problems. No other basin is categorized by our blend of high water table, lack of storm water infrastructure, fertile well- draining soils, and reliance on open waterways for the vast majority of storm water conveyance. Our proximity to the Willamette River makes us particularly flood -prone and heightens our focus on the importance of all open waterways within our neighborhood. As stressed in our comments, the protection and enhancement of these watercourses is pivotal in averting widespread flooding. Staff comments point to the myriad of overlays and protective measures applied to date. We appreciate these measures, but reiterate that they leave out vital watercourses that are part of our naturally occurring system. Our storm water system is akin to the human circulatory system, and the existing protections apply only to the arteries leaving the veins and capillaries unprotected. The system can not function effectively for the entire body of Santa Clara without adequate mapping and protection of our "lesser" waterways. The protection and enhancement of these create an existing storm water infrastructure that can accommodate development without capital projects. (See Santa Clara Community Organization comments dated Oct. 23, 2009) Staff uses the terms green infrastructure and low impact development throughout the basin plan, but doesn't differentiate between man-made engineered infrastructure (even "green" infrastructure) and naturally occurring infrastructure. Our neighborhood is riddled with swales, sloughs, channels and waterways that are naturally occurring infrastructure. These serve the long time residents as flood control measures. When they are obliterated by infill development, they are replaced on the development site by something that only serves the storm water needs of the infill, not the rest of the residents along what used to be a continuous storm water system. This places the existing residents at much greater risk of inundation. We would like the basin plan to prioritize the protection and enhancement of naturally occurring infrastructure which can continue to serve the existing residents as well as accommodate infill development. Finally, we urge the adoption of low impact development standards coupled with post development runoff not exceeding pre - development levels for this basin as a primary means to achieve both storm water quantity and quality goals. These measures make long -term economic and ecological sense. Let these neighborhoods be the trial ground for these principles and create a model which can inform development throughout the watershed. Sincerely, Jerry Finigan and executive board of the Santa Clara Community Organization