•The “pre-development” condition is represented by a single curve number and uniform <br />soil/cover assumption for the entire wooded hillside, without site-specific measurements of how <br />existing wetlands and streams currently store and release water over the wet season. <br />•The analysis focuses on 2-year and 10-year storm events, yet the most ecologically important <br />processes in small headwater wetlands and streams are often driven by frequent, lower-intensity <br />storms and seasonal groundwater conditions not captured by event-based peak-flow modeling. <br />•Four existing off-site lots discharge stormwater near the eastern boundary. These flows are still <br />characterized as “pass-through,” yet they are being routed through the new system and are <br />acknowledged to increase 2-year peak flows at one point in the system. In a Goal 5 wetland and <br />stream corridor, any increase in the frequency or magnitude of bankfull-type flows warrants <br />more careful evaluation of channel and habitat impacts than has been documented so far. <br />These concerns are not intended to impose new or discretionary criteria; they instead underscore the <br />need for the record to show that the existing code-based methods have been applied in a way that <br />actually addresses Goal 5 resource protection, not just peak-flow control at a few design storms. <br />5. Clarification regarding planting, O&M, and long-term /WR protection <br />Finally, I appreciate that the applicant has incorporated Operations and Maintenance language drawn <br />from the City’s 2014 Stormwater Management Manual for rain gardens, swales, and structural <br />detention facilities. However, this O&M text is general in nature and not specific to the particular /WR <br />conservation area present on this site. It does not substitute for a project-specific planting and long-term <br />management plan that demonstrates compliance with EC 9.4980’s requirements for vegetation, erosion <br />control, and long-term protection. <br />Given the extent of grading and construction proposed at the base of the slope and within or adjacent to <br />Goal 5 wetlands and streams, I believe that the City would benefit from: <br />•a detailed planting plan for the /WR conservation area showing species lists, densities, and <br />expected coverage, with an emphasis on appropriate native species; <br />•clear performance standards and timelines for achieving stable vegetated cover; and <br />•measures to address edge effects, human disturbance, and invasive species risk associated with <br />the extension of Randy Lane and multiple new lot access points. <br />Such information would provide stronger support for required findings under EC 9.4980 and Goal 5, <br />and would also give future homeowners and the City a clearer understanding of their responsibilities in <br />maintaining these important water resources over time. <br />6. Summary request <br />In light of these clarifications and the sensitivity of the mapped Goal 5 wetlands and streams on the <br />site, I continue to believe that the current record does not adequately demonstrate compliance <br />with EC 9.8365, EC 9.8470, and EC 9.4980. I respectfully renew my request that the City either: <br />•deny PDF 25-01 and SDR 25-02 as submitted; or <br />•at minimum, require additional, resource-specific analysis and plan revisions addressing <br />the issues identified above before reconsidering the applications .