methodology in the Stormwater Management Manual, that peak rates of flow delivered to an <br />existing open waterway at a point above 500 feet in elevation will not increase during storms <br />larger than the water quality design storm and smaller than the flood control design storm as a <br />result of the development that is the subject of the application. <br />Our Concerns/Arguments <br />1) The engineering firm hired to assess the stormwater flow was given the figures to work with by <br />the applicant, rather than being hired to do a full hydrology study to gather their own figures. The <br />current figures therefore do not include the stormwater coming off the Suncrest area onto the <br />northern portion of the property and thus only address 62% of the water flowing across the <br />property, according to the engineer we hired to review the stormwater report, who prepared prior <br />hydrologic report on this property. <br />2) The plan requires individual lot owners to build and maintain water detention systems to <br />ensure that post-development peak flows do not exceed existing peak flows—applies to codes EC <br />9.6790(2) & EC 9.6793(3)(a) -- rather than one large facility built by the developer that serves the <br />entire property. <br />3) It requires the individual homeowners to maintain and inspect their detention systems after <br />major rain events to ensure that they haven’t clogged. <br />4) Otherwise, the entire property is served by only one swale and 2 rain gardens, which are <br />supposed to also be maintained by an “owner.” <br />5) 70% of the existing wetlands have been targeted for removal by the developer. Those wetlands <br />are a natural water filtration and detention system! Removing them and filling them in with dirt and <br />impervious surfaces, will increase the flood & erosion risk. <br />We feel leaving stormwater mitigation issues up to imaginary home builders/owners is the worst <br />possible way to handle this issue, as there is a history of lots in this area being left vacant after <br />natural vegetation and trees have been destroyed during infrastructure development. A large <br />number of undeveloped lots are available in a half-mile radius of this property. Many of these lots <br />have been available since 2006 and have either changed hands multiple times or simply been left <br />fallow (either way, still empty). The natural vegetation was removed when building the <br />infrastructure, and nothing but blackberries and weeds have taken their place. Aerie Park and <br />Timberline Hills are two examples. <br />Aerie Park: 2006, 29 lots. 12 homes now exist. <br />Timberline Hills: 2006, 255 lots approved. Phase 4—32 lots--only now being built (sort of), with <br />some lots still available in Phase 3. Phase 5—plat recorded with 96 additional lots. <br />Summary: 1) The stormwater analysis is faulty due to the engineering firm being required to use <br />the numbers given to them by the developer instead of being able to do a full hydrology study. <br />Prior studies in the area show the amount of stormwater would be far greater. <br />Summary: 1) The stormwater analysis is faulty due to the engineering firm being required to use <br />the numbers given to them by the developer instead of being able to do a full hydrology study. <br />Prior studies in the area show the amount of stormwater would be far greater. <br />2) Putting the onus of stormwater detention on the individual lot owners is a poor plan as it <br />assumes a certain responsive level in the owner correctly installing and maintaining the system. <br />3) Not requiring the developer to install a detention system that is sufficient to handle the entire <br />property, but instead allowing him to push the requirement onto individual lot owners, assumes <br />lots will be sold and developed within an immediate timeframe, which recent history shows is a <br />faulty assumption. Therefore, it is possible that detention systems may not be installed for years, <br />with the result being flooding and erosion issues for the Goal 5 Creek (Videra Creek) and its <br />headwaters, and additional erosion and flooding issues for neighboring homes. <br />TREES AND WETLANDS <br />EC 9.4900 The purpose of the /WR Water Resources Conservation overlay zone is to provide