I piped stormwater system located within the public streets to meet EC 9.6793. The planning <br />2 commission concluded that the onsite detention of all stormwater runoff from the <br />3 development in pipes "will not increase peak flows or velocity in such a manner as to cause <br />4 damage to the open drainage system." Record 32. The planning commission concluded that <br />5 with the conditions of approval that require onsite detention stormwater management systems <br />6 on the subject property, the proposal demonstrated compliance with EC 9.8325(13): <br />7 "The [planning commission] rejects [Southeast Neighbors'] arguments and <br />8 finds that the [hearings officer] did make an independent evaluation of the <br />9 criteria at EC 9.8325(7)0) and EC 9.8325(13), which both relate to stormwater <br />10 runoff from the proposed development. Although EC 9.8325(7)0) does not <br />11 require the development to meet EC 9.6793 Stormwater Flow Control <br />12 (Headwaters), the [planning commission] endorses the hearings officer's <br />13 imposition of this standard to ensure that the development provides onsite <br />14 storm-water management facilities that detain post-development peak flows to <br />15 pre--development levels, which is necessary to ensure compliance with EC <br />16 9.8325(13). The flow control standards * * * provide this detention and are <br />17 the standards that city staff can readily implement during the building permit <br />18 process. The [planning commission] finds that the [hearings officer] did not <br />19 [err] by correlating the detention requirements of EC 9.8325(7)0) to address <br />20 the * * * `increased peak flow or velocity' test of criterion EC 9.8325(13)." <br />21 Record 33 (underlining in original). <br />22 In its second assignment of error, we understand Southeast Neighbors to argue that <br />23 the planning commission misconstrued the applicable law when it determined that EC <br />24 9.8325(13) is satisfied because the planning commission imposed conditions that require EC <br />25 9.6793 to be satisfied for each lot and for the public stormwater system within streets and <br />26 utility easements.10 We understand Southeast Neighbors to argue that EC 9.8325(13) is <br />27 concerned with ensuring that the proposed PUD will not "erod[e] or scour the natural <br />28 drainage courses [either on-site or downstream] * * * or caus[e] turbidity, or the transport <br />29 of sediment due to increased flows or velocity" and that EC 9.6793 does not address those <br />30 issues. According to Southeast Neighbors, the city's stormwater standard at EC 9.6793 does <br />10 Apparently EC 9.6793 does not apply to development of the western portion of the property because the <br />open portion of the Amazon Canal is not above 500 feet in elevation. EC 9.6793(3). <br />Page 18 <br />