Eugene Planning Commission <br />August 22, 2016 <br />Page 6 <br />pay System Development Charges based on the rates for filtration planters, but <br />will minimize the amount of stormwater being discharged to the public <br />system." (Emphasis supplied). <br />What the above passage says is that on-site planters will adequately treat the storm water quality <br />and, for storm water quality, the proposal complies with EC 9.6792(3)(d)(1). That statement is <br />supported by the revised application's Attachment L - Stormwater Report. Attachment L <br />consists of two documents. The first is a Stormwater Report with site plans and water quality <br />calculation sheets from pages L-1 through L-58. The Stormwater Report cover and table of <br />contents is attached hereto as Exhibit 7. The second is a Geotechnical Report from pages L-59 <br />through L-79 of the revised narrative's Attachment L. The cover, cover letter and table of <br />contents of the Geotechnical Report are attached hereto as Exhibit 8. <br />The application demonstrates compliance with the city's storm water quality standards through <br />on site water quality management that satisfies EC 9.6792(3)(d)(1). The Geotechnical Report <br />demonstrates that the conditions exist to warrant an on-site filtration system. The Stormwater <br />Report and the numerous filtration/infiltration data sheets demonstrate that the on-site filtration <br />system will result in storm water quality sufficient to meet City standards. <br />EC 9.6792(3)(d)(2), which applies only to off-site water quality management, does not apply <br />to this application because the proposal manages storm water quality through on site measures. <br />The Hearings Officer erred by applying EC 9.6792(3)(d)(2) after the applicant demonstrated <br />compliance with EC 9.6792(3)(d)(1). The Planning Commission should reverse that error. <br />Two other points are worth noting. First is the reference to systems development charges <br />(SDCs). The reference to SDCs in the above narrative is expressly in relation to stormwater <br />flood control, which is addressed under EC 9.6791. The Hearings Officer concluded that the <br />proposal complied with that standard and did not discuss it in his decision. The application <br />narrative makes clear that it is under that standard, and consistent with its requirements, for <br />which the SDCs will be paid. The Hearings Officer and opponents incorrectly associated the <br />storm water flood control SDC reference to the storm water quality standard. <br />The second point includes statements at page 31 of the revised narrative, under the discussion <br />for EC 9.6792(3)(a) that provide: <br />"Geotechnical work has not yet been completed[.] * * * These conditions will be <br />verified with the geotechnical report to be submitted with the building permit <br />application." <br />The inclusion of the above language in the revised application was an editing error on the <br />Applicant's part. It is language that was in the original application narrative, prior to <br />completeness review, that the Applicant failed to edit out for the revised application narrative. <br />That language should have been removed because, as indicated above and in excerpts attached <br />hereto as Exhibit 7, a geotechnical report had in fact been completed and provided as part of <br />