To Whom it may concern, <br />I am writing to express my opposition to SDR 25-02 with /WR Resources Overlay and PDF <br />25-01. There are several areas that are problematic with codes and requirements that have <br />not been met by the applicant. <br />EC 9.4920 (2) (b), which addresses the required setbacks for a Goal 5 wetland has not been <br />met. The wetland in question is AMA 5B, a Category B wetland which has also been <br />determined to be an official Waters of the United States. The code states that one method <br />of determining established boundaries is from the jurisdictional wetland boundary <br />accepted by the Oregon Department of State Lands, if provided by the property owner. A <br />map fulfllling that method along with an accompanying letter from the U.S. Army Corps of <br />Engineers, which identifles that wetland as Wetland 2B, is part of the application for SDR <br />25-02 and clearly determines that the wetland at the northern end of the Category C <br />stream extends beyond the Goal 5 stream’s established 40-foot setback, both to the east <br />and west. <br />The true conservation setback would add an additional 25-foot setback from the <br />jurisdictional boundary of the wetland, into Lots 33, 32, and 27. Additionally, there are <br />areas in Lot 35 where the wetland appears to be lacking the full 25-foot setback required. <br />The applicant will argue that additional setbacks will render some lots unbuildable. It was <br />the applicant’s choice to create the lot lines where they are, and they can be moved or lots <br />changed to accommodate the proper setbacks. <br />EC 9.4920 (3) Clearly states that if a Goal 5 stream and wetland exist together, “…the /WR <br />conservation area for each of the individual water features shall be calculated and mapped <br />separately, and the total footprint of all the individual /WR conservation areas <br />combined shall be the /WR conservation area for that site.” (emphasis mine) <br />This code has clearly not been met. While the conservation area for E35A, the Category C <br />stream, was established and mapped, no conservation area has been established for the <br />Category B Wetland, or as per the U.S. Army Corps of Engineers determination letter of 25 <br />July 2025 labels it, Wetland 2B, a jurisdictional Water of the U.S. <br />Not only was the 25-foot setback for the wetland was not established, nor was the total <br />footprint of both the wetland and stream setbacks combined, and therefore, the proper <br />/WR conservation of that site was not calculated or mapped. EC 9.4920 (2) (b) and (3) have <br />not been met. <br />Given the City’s insistence that the entire property is Goal 5, there needs to be an emphasis <br />on proper conservation area establishment and protection.