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Reasons to Deny 3685 New Brighton Road Subdivision Wetland Protection Easement Vacation Suitability and Road Safety on Thom Drive Tree and Habitat destruction Developers Property Sizes Contrary to City Vision Wetland protection: The wetland protection plan in inadequate. It will put more water and sediment directly into the wetland and does not include a reasonable maintenance nor replacement plan. With the current owner moving soon, the applicant not being from the city and having a poor history of follow through in the area (not completing the grading plan on the Thom development, erosion issues, etc), as well as unknown future owners taking on the physical and administrative tasks of maintaining the basin system. Plus, the very significant financial burden of protecting our shared wetlands falling on a single household. There is reasonable concern that this won't be well done in the out years and the city will be stuck with a bill and/or the wetland will be damaged. Weak Maintenance Plan The homeowner of the newly proposed Lot 1 will be solely responsible for inspection, maintenance, and when the time comes, rebuilding the stormwater filtration basins... in perpetuity.. The tasks for inspections and maintenance read like municipality and large organization tasks - logs, reporting, inspections, etc. City council members inform me there are no other agreements like this within the city with single homeowners. During the planning commission meeting that this was passed, the developer incorrectly stated that the RCWD would be responsible for inspections. While the RCWD is able to come and perform inspections and make fixes - billing back to the homeowner and/or the county/city if the homeowner is unable to pay, the RCWD indicate these inspections are purely "complaint driven" and there is no regular inspection included int the agreement. Given the non-public location of these basins, complains are unlikely even when grossly deserved. In effect, the untrained and biased homeowner is judge, jury, and executioner as it relates to a basin system that is protecting a large city resource. The city is not even party to the maintenance agreement; though rebuild costs eventually be backstopped by the county/city if/when the homeowners fail in their significant duty to protect the city's shared natural resources. These are to be maintained in perpetuity - at some point, the homeowners will fail in their duties to protect the city's natural resources, or fail ensure their they are maintained, safe, don't stagnate and turn into mosquito nests, and remain effective? Again, with only self-inspection the conflict of interest is large and risk to our city unnecessary. There are no notes in the plans about ensuring the swales on both sides of the houses and driveway, upper-most catchment basin, and under-driveway piping is maintained as-is in perpetuity by this homeowner or subsequent homeowners. At the least, these should be included in the maintenance agreement. Ineffective Basin locations A hydrologist that specializes in groundwater-surface water interaction at a federal science agency reviewed the plans and he indicates that almost none of the water that hits the driveways would infiltrate and none of it would make it into the southerly basin and, instead, the water would flow south of the basin "creating erosion and potential water quality issues and additional sedimentation in the wetland" for lot 1 as well as added flow to the street (which is not supposed to be allowed). This scientist further notes that depending on the Lot 1 house design, water hitting that roof would flow unimpeded down the extreme slope[11] at it's edge and directly into wetland or onto the driveway (which we just noted, does not direct water to the basins). He notes the basins, particularly the southern one, are simply not located in the right places and appear to be crammed into the available location rather than an effective location (this statement further supported by the RCWD comments). The developer's submitted plans agree with this assessment based on their hydrological flow marks showing water that hits the lot 1 driveway running south down a steeply graded driveway (7.7 and 8.3 grade on driveway) away from the stormwater storage basin, then go down an even steeper dirt slope (steepened to allow for driveway) unfettered into wetland. I contacted RCWD directly about the poor locations of the basins and the clear erosion issues in the plan. I also asked if they took the 2012 steepening of the grade into account. The RCWD indicated they only review what is provided them by applicants and/or the consultant the developer did not make them aware of the 2012 changes. They further did not review this plan for erosion or sedimentation controls beyond the construction period - only max Page 1 of 12Reasons to Deny 3685 New Brighton Road Subdivision 3/9/2018http://joefederer.com/subdivision/Reasons.html