additional information and argument supports a conclusion consistent with the recommendations <br />from Public Works staff that the system can feasibly be engineered in compliance with the <br />applicable stormwater standards. More specifically, that the system is scalable to accommodate <br />on -site detention on individual lots if middle housing is developed (see Kloos letter dated August <br />141 2025, including Exhibit I titled Storm Water Memo — KPFF Engineering), as well as from from <br />shared driveways and streets in the event that Randy Lane is required to be public. <br />Planning Commission's Determination <br />In the Staff Memorandum dated July 31, 2024, Public Works referral comments were revised with <br />findings regarding the application's compliance with EC 9.6815(2)(a) and (b) Street Connectivity <br />Standards, recommending that the proposed extension of Randy Lane, initially proposed as a <br />private street, should be a public street instead. This change also triggers necessary changes in <br />stormwater facilities, as discussed in the referral comments regarding the application's <br />compliance with EC 9.6791 through 9.6797, because portions of the proposed private conveyance <br />system will need to be constructed as a public conveyance system. In order to accommodate these <br />changes, Public Works recommended the following condition, believing it is conceptually feasible <br />to design a public conveyance system that will meet the City's stormwater standards: <br />Prior to final PUD approval, the applicant shall submit an updated Storm Drainage <br />Memorandum that addresses the conditions of approval under EC 9.6815 requiring Randy <br />Lane to be constructed as a public street and demonstrate compliance with EC 9.6791-EC <br />9.6797 based on this change. <br />The applicant does not appear to object or challenge this condition on appeal, except for the fact <br />that it requires the stormwater analysis to address Randy Lane being constructed as a public street <br />rather than a private street as initially proposed. Planning Commission agrees that the <br />requirement to construct Randy Lane as a public street may impact the calculations provided in <br />the applicant's Storm Drainage Memorandum dated March 5, 2024, and that the Hearings Official <br />erred in not relying on the applicant's evidence and argument provided in their second open <br />record materials dated August 14, 2025 (see Kloos letter dated August 14, 2025, including Exhibit <br />I, Stormwater Memo from KPFF Consulting Engineers). That argument and evidence, including the <br />engineer's memo should have been considered as responsive to the recommended conditions of <br />approval from Public Works staff related to compliance with applicable stormwater standards. <br />Planning Commission also takes note of the applicant's more recent suggested modifications to <br />the following condition about analysis demonstrating the feasibility of accommodating (and <br />detention for) stormwater runoff in the event that the proposed lots could be developed with <br />middle housing rather than single -unit dwellings, as described in their written appeal testimony <br />dated January 10, 2025 (see Applicant's Outline from Argument to the Planning Commission). <br />The additional condition recommended by Public Works staff to address the stormwater <br />requirement for middle housing to be developed on individual lots, which the applicant now seeks <br />to modify on appeal, was included in a Staff Memorandum submitted during the second open <br />record period (see Staff Memorandum dated August 14, 2025) which stated the following: <br />The applicant shall submit an updated stormwater memo, demonstrating the feasibility of <br />a proposed stormwater detention system where the proposed lots are developed with <br />Final Order: Braewood Hills 3rd Addition (PDT 24-1 and ST 24-3) Page 26 <br />