required, the volume of the cistern, rain garden or impoundment becomes 4,737 cubic feet. Where is <br />this structure in the plans? <br />The project plans to dispose of the remaining stormwater (total stormwater less whatever amount can <br />be held for on-site detention) on the public parklands.-Has a geotechnical and/or feasibility study been <br />done to determine if this amount can be safely absorbed by the public parklands? Further testing of the <br />areas to the East of the project must be required. The area to the East of the project where the <br />proposed dumping is to occur is of lower elevation than the project'and this area frequently fills with <br />runoff during severe storms. Drainage will be especially problematic as large stormwater flows add to <br />rising river levels concurrently raising groundwater levels. <br />Further, this water will not be tested prior to discharge, not be treated nor will contaminants (oil, <br />gasoline, etc.) be removed violating the Clean Water Act which is codified in Eugene City Code for areas <br />within the Urban Growth Boundary. Given these facts, will a discharge permit be required as a <br />condition? <br />In summary, the project cannot safely dispose of stormwater flows on-site and requires a serious leap- <br />of-faith to believe the City parklands can accommodate such flows. In addition, why should the <br />neighboring property (City parkland.) and potentially neighboring private property bear the burden of an <br />inadequate stormwater plan? Further, this establishes a 'dangerous precedent in which a private party <br />becomes the beneficiary of public resources without remuneration. <br />Further testing and evaluation is needed before this project can move forward. <br />919 <br />