Because EC 9.8365 approval must be based on an evidentiary showing that the final plan conforms to the <br />tentative plan and “all conditions attached thereto,” the City cannot rely on unverified assertions in the <br />supplemental materials in place of complete, consistent final plans and clearly referenced easements that match <br />each condition of approval. [1][5] <br />2. EC 9.8470 – Standards Review: inadequate demonstration of protection and mitigation <br />for Goal 5 resources <br />EC 9.8470 and the associated Standards Review guidance require the applicant to provide a narrative prepared <br />by qualified professionals demonstrating compliance with all applicable standards, including the /WR overlay <br />provisions beginning at EC 9.4900 and the conservation area requirements in EC 9.4980. [2][3][4] <br />The City’s own Standards Review application instructions emphasize that: <br />It is the applicant’s responsibility to provide “adequate information” demonstrating how the project <br />satisfies the applicable approval standards, and failure to do so may result in denial.[2] <br />Site plans must show the adopted Goal 5 resource site boundaries, required /WR conservation area, top <br />of bank/ordinary high water, wetlands on the Local Wetlands Inventory, and detailed information about <br />vegetation, soils, slopes, hydrology, and stormwater disposition.[2] <br />In light of this, the current SDR 25-02 record appears deficient in several key respects: <br />Reliance on generalized SLOPES V assumptions: The stormwater report applies SLOPES V <br />“pre-European development” flow standards and assumes a generalized pre-development curve number <br />of 76 for the entire “wooded hillside,” but it does not provide site-specific hydrologic measurements <br />within the Goal 5 waterways and wetlands that will be affected by the Randy Lane extension and <br />associated grading, nor does it analyze how localized changes in flow paths and velocities within the <br />/WR conservation area will affect channel stability and habitat functions. [6] <br />“Pass-through” treatment of off-site flow: Four existing lots east of the site currently discharge <br />stormwater via a private system that outfalls near the project’s eastern boundary; the report explicitly <br />treats these flows as “pass through,” stating that this runoff is not required to be detained and that the <br />project “does not impact the quantity or destination of that water.” Yet the applicant also proposes to <br />route this flow through the new detention system and downstream conveyance, and acknowledges that it <br />increases the 2-year peak in the system from 2.43 cfs to 2.78 cfs. This is a significant change in <br />hydrologic routing through Goal 5 wetland and stream corridors, and the applicant has not provided an <br />impact analysis that demonstrates no adverse effect on the protected resource as required by the /WR <br />overlay. [4][6] <br />Lack of resource-specific impact analysis for Randy Lane extension: The extension of Randy Lane and <br />associated swales, pipes, and detention tiers will directly encroach on and fragment Goal 5 wetlands and <br />streams that are mapped in the City’s Water Resource Conservation maps and regulated under EC <br />9.4900–9.4980. However, the supplemental materials focus almost entirely on peak-flow hydrology and <br />do not provide quantitative analysis of changes in wetland hydroperiod, inundation depth and duration, <br />or baseflow conditions that are critical to Goal 5 resource functions.[3][6] <br />Incomplete vegetation and habitat analysis: The report notes that much of the site will remain “wooded <br />and vegetated,” but it does not provide a detailed inventory of native versus invasive species within <br />the /WR conservation area, the extent of tree removal associated with the street extension and grading, <br />or how revegetation/planting will meet EC 9.4980’s standards for replanting bare soil with appropriate <br />native species. Without this information, there is no basis to conclude that the Randy Lane extension and <br />associated utilities will “avoid and minimize” impacts to Goal 5 resources to the maximum extent <br />practicable, or that required mitigation will fully replace lost functions. [2][3][4]