show a PUE over the entire width of the private roads and that this “satisfies this requirement,” but the <br />record does not clearly identify where this width equals or exceeds the required 14 feet in relation to <br />the specific wastewater alignment, nor does it plainly reconcile the new private easement structure with <br />the public easement condition. <br />Because EC 9.8365 requires the City to find that the final PUD “conforms with the approved tentative <br />PUD plan and all conditions attached thereto,” there should be a direct, traceable link between each <br />tentative condition and a corresponding element in the final plan set and easement documents. In my <br />view, the current record still leaves room for doubt on this point, which is significant given the <br />complexity of the joint access and utility arrangements and their importance for long-term access, <br />maintenance, and emergency response. <br />3. Clarification on “adequate information” and the level of analysis expected in <br />/WR and Goal 5 areas <br />The City’s Standards Review guidance for the /WR Water Resources Overlay specifies that it is the <br />applicant’s responsibility to provide “adequate information” demonstrating how the project satisfies the <br />approval standards, and explicitly warns that failure to do so “may result in a denial.” The guidance <br />also states that site plans and supporting materials should show the adopted Goal 5 resource <br />boundaries, the /WR conservation area, top of bank/ordinary high water, and wetlands listed on the <br />Local Wetlands Inventory, along with detailed information about vegetation, soils, slopes, hydrology, <br />and stormwater disposition. <br />I understand that the applicant has provided SLOPES V-based hydrologic modeling and a stormwater <br />facility layout designed to meet the City’s 2014 Stormwater Management Manual and EC 9.6796. <br />However, the project would place new roads, tiered detention ponds, and vegetated swales within and <br />adjacent to mapped Goal 5 wetlands and streams that are protected by EC 9.4900–9.4980 and the City’s <br />Water Resource Conservation maps. In that context, “adequate information” reasonably includes <br />resource-specific analysis of: <br />•how the Randy Lane extension and associated grading will affect wetland hydroperiod, <br />inundation depth and duration, and baseflow conditions; <br />•how changes in flow routing and peak timing will influence channel stability and erosion <br />potential in the small streams at the toe of the slope; and <br />•how vegetation removal, replanting, and long-term maintenance will preserve or enhance <br />habitat functions within the /WR conservation area. <br />Absent that level of resource-specific detail, there is a genuine question whether the City has enough <br />information to make affirmative findings under EC 9.8470 and EC 9.4980 that the proposal avoids, <br />minimizes, and fully mitigates adverse impacts to the protected Goal 5 resource. This is particularly <br />important because Statewide Planning Goal 5 requires local governments to apply adopted protection <br />measures to ensure that identified resources and their functions are maintained. <br />4. Clarification regarding stormwater methods, assumptions, and Goal 5 <br />implementation <br />I also wish to clarify that my comments are not a critique of SLOPES V or the use of event-based <br />hydrologic modeling per se; these are tools that the City has adopted and incorporated into its <br />stormwater standards. The issue, in my view, is that the way these tools have been applied in this <br />particular case leaves several key questions unanswered in a sensitive Goal 5 setting: