Ordinance -- Page 3 of 9 <br />1. For the c Construction of less than 1,000 square feet of new or replaced impervious <br />surface within a 12-month period; <br /> <br />2. For interior alterations of an existing structure Replacement of impervious surface <br />area that does not expose more than 1,000 square feet of soil; <br />RESPONSE: What does this language mean? Does this mean that more than 1,000 square feet <br />of soil cannot be exposed at any given time, even during construction? If so, then the replacement <br />or installation of 1,000 square feet of concrete would most certainly expose more than 1,000 <br />square feet of soil during construction to allow for the setting of concrete forms, installation of roof <br />drains, etc. This language is not clear and appears to potentially be in conflict with EC <br />9.6792(2)(b)(1). What sort of scenario is this intended to apply to that EC 9.6792 (2)(b)(1) does <br />not? <br /> <br />3. For the construction of more than 1,000 square feet of impervious surface that <br />replaces existing impervious surface for purposes of maintenance or repair for the <br />continuance of the current function, providing that as part of such m Maintenance and/or <br />repair the applicant is replacing less than 50% of the length of the stormwater drainage <br />system (including pipes, drainageway catch basins and drywells) on the development <br />site activities on structures or facilities to prevent decline, lapse or cessation in <br />the use of the existing structures, facilities, or impervious surface, as long as no <br />additional hydrologic impacts result from the repair or maintenance activity; <br />RESPONSE: This language is extremely subjective and ambiguous. If impervious surface is <br />proposed to be replaced, then there most certainly will be additional hydrologic impacts. For <br />example, the peak flow runoff rate of brand new asphalt will be higher than that of asphalt that is in <br />poor condition, and therefore will have a hydrologic impact. This is likely true for all replacement of <br />impervious surfaces, even if they are for repair or maintenance purposes. This language <br />completely contradicts the purpose of the exception, and can very easily be misinterpreted by plan <br />reviewers. <br /> <br />4. For the construction of new or replaced impervious surface where all of the <br />stormwater runoff from the impervious surface will discharge into an on-site, privately <br />maintained underground injection control system that is registered and approved by the <br />Oregon Department of Environmental Quality; <br />RESPONSE: Why is this language proposed to be removed? What if an existing, approved, on- <br />site, privately maintained UIC exists that has been sized to accommodate additional runoff from a <br />particular site? There are many instances where this language could prove to be beneficial to <br />home owners, builders, and developers. Is the City intending to remove the ability for private <br />UICs to be utilized? <br /> <br />5. For the construction of a single-unit dwelling or duplex on a lot or parcel that was <br />created by a land division application submitted and approved by the City prior to March <br />1, 2014, that is consistent with the approved land use application and the City’s <br />stormwater quality (pollution reduction) standards in place at the time of the land division <br />application; or <br />RESPONSE: There are many parcels within the City of Eugene that were legally created prior to <br />March 1, 2014 that would fall victim to the removal of this language. The removal of this language <br />has the potential to add significant additional costs to individual lots that previously met this <br />exemption. Additionally, this appears to create a situation where these lots would qualify for <br />compensation under Ballot Measure 49, since their fair market value has decreased. <br />