In addition, setbacks from the Goal 5/Category C stream must be calculated <br />from "the top of the high bank" on each side of the stream, not from the <br />stream center (EC 9.4920(1)(c) and 9.4720), and it appears from the <br />application materials that the stream center may have been used instead. <br /> The "high bank" is defined as "the highest point at which the bank meets <br />the grade of the surrounding topography, characterized by an abrupt or <br />noticeable change from a steeper grade to a less steep grade, and, where <br />natural conditions prevail, by a noticeable change from topography or <br />vegetation primarily shaped by the presence and/or movement of the water <br />to topography not primarily shaped by the presence of water. Where there is <br />more than one such break in the grade, the uppermost shall be considered <br />the top of the high bank." (EC 9.4920(1)(c).) Based upon our visual <br />inspections, it does not appear that the applicant's measurements accurately <br />reflect the "high bank." At a minimum, it is not apparent that a consistent, <br />objective standard was used in identifying the top of the bank. The Planning <br />Department should view the site to ensure compliance with this <br />requirement. <br />Critical root zones for trees to be preserved within the /WR conservation <br />area must also be shown on site maps, together with tree species and size. <br /> (See EC 9.6240.) Since the conservation areas for the wetlands and <br />Category C stream were either not mapped at all or were not correctly <br />mapped, the applicant has not complied with this requirement. <br />The application also does not show the access points for many of the lots. <br />Although in most cases it can be assumed that access will be made from a <br />street or driveway adjacent to the lot, in the case of Lot 34, for example, the <br />access point is not clear. A substantial portion of that lot will be occupied by <br />the 40-foot setback from the top of the creek bank, thereby greatly reducing <br />the size of the lot, leaving not much buildable area remaining. EC 9.8055 <br />requires that access points must be shown on site maps and development <br />maps, and many of the lots on these maps do not show how access points <br />will be sited after setbacks and conservation areas have been created. <br />Thank you for the opportunity to comment on this application and please do <br />not hesitate to contact me if there is any additional information I can <br />provide. <br />Sincerely,