staff was fearful that if they asked for more information to support their Greenway permit findings, the <br />developer or the developer's attorney might make threats of “unreasonable cost or delay” under ORS <br />197.303(4). While it is appropriate for staff to be concerned about the requirements of ORS 197.303, <br />more information was, and still is clearly needed, before a determination of compliance with Greenway <br />Permit Approval Criteria can be made. <br />Removal of large, mature trees and wetland vegetation <br />Based on the information provided, none of the mature trees or other valuable vegetation on the project <br />is slated to be saved. According to my count, 28 trees will be removed, including a stand of productive <br />English Walnut trees, a beautiful Port Orford Cedar, and a large and beautiful maple that is close to and <br />clearly visible from the River Bank Trail. This site is also important because of the presence of several <br />areas of lush green sedges (Carex species), which are an indicator of wetland conditions. By making <br />preservation of scenic resources like these a design criterion, as called for by state and local regulations <br />and standards, as stated above, these beautiful trees and sedges could be saved. However, if the over- <br />riding design standard is maximizing the number of apartment units, parking spaces, and profit, then <br />these important and beautiful resources will be destroyed. <br />Regarding the presence of wetlands on this site, I take issue with the conclusion of the developer's <br />consultant. The report submitted by the developer apparently bases its conclusions on the results of <br />soil borings and perc tests at several points on the project site. I question this conclusion based on my <br />observations of several stands of lush, green sedges (Carex species), both on the eastern side of the site, <br />near the center of the site towards the north side, and elsewhere on the property. I observed these <br />stands of sedges both on June 26 and on July 6, 2018, a time well into the dry season, with very little <br />rain during the preceding 60 days. During my 22 years of work for the California Tahoe Conservancy, <br />stands of sedges like that always meant the presence of wetland conditions, and we went to great <br />lengths to protect such areas—often spending millions of dollars to remove fill and structures. When I <br />observe lush, green sedges well into the dry season, it is very hard for me to believe that wetlands are <br />not present. Therefore, I recommend that an independent evaluation be conducted to verify the <br />developer's finding regarding this issue. <br />Impervious coverage <br />According to project plans submitted by the developer and posted on the city's website, the project <br />includes 2.05 acres of coverage out of a total project area of 3.38 acres. Thus, 61% of the site is <br />proposed to be covered with asphalt, buildings, and other impervious surfaces. Sixty-one percent is a <br />very high number. For example, at Lake Tahoe, where I used to work, the highest coverage rate <br />allowed by law was 30%, which applied to very well-drained sites far from sensitive areas. On wetland <br />and meadow sites (called “stream environment zones,” which the Lombard Apartments site is, in my <br />opinion), 0% coverage would be allowed. <br />Impervious coverage is harmful to the environment because it causes rapid rates and large quantities of <br />stormwater runoff, rather than allowing rain to percolate into the ground. The vegetation on a meadow <br />site, such as this, naturally filters out sediment and other water pollutants before the water discharges <br />into rivers or enters the ground. While the developer has proposed using mitigation measures, such as <br />porous pavers in some places, I know from my 33 years of water quality planning experience, including <br />water quality monitoring of projects, that such mitigation measures are typically not highly effective, <br />and become less and less effective over time. It would be far better for water quality, and for the <br />-4- <br />141 <br /> <br />