Page | 6 <br />4) Critically Flawed Stormwater Control Plans <br />1. Error in Basin Size Estimate: As shown in Figure 3 [1], the applicant has drastically underestimated the <br />size of the contributing stormwater basin. They claim a basin area of only 12.39 acres, while the actual <br />area is 30.2 acres—a difference of over 140%. This is affirmed by the 2003 analysis and reinforced in <br />testimony by Goebel Engineering [7] concerning this application. This misrepresentation directly impacts <br />the accuracy of their flow calculations. <br />Figure 3 - Basin size estimate does not include all area contributing to stormwater flow <br /> <br /> <br />2. Ignoring the Role of Wetlands: Figure 4 [1] illustrates the extensive wetlands on the property, which <br />currently provide crucial natural stormwater detention and filtration. The applicant's plan to remove these <br />wetlands, as requested in their Joint Permit Application [3] ,will eliminate this vital natural function and <br />significantly increase peak runoff. There is no recognition of the existing wetlands as a stormwater <br />facility. This wetland “sponge” retains/detains a large volume of stormwater. The applicant’s plan is to <br />remove most of these wetlands and pay into the wetland mitigation “bank” (which is intended to fund <br />creation of new habitat somewhere else – like Fern Ridge). This does nothing to preserve this wetlands’ <br />vital role controlling stormwater flow control in this neighborhood. <br />Appeal Testimony (PDT 24-01 & ST 24-03) - Batch #1 Page 32 of 43