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25 Michael Harvey From: James Bryan Sent: Wednesday, April 15, 2015 3:09 PM To: Michael Harvey Cc: Anne Marie Tosco Subject: RE: Internal Peer Review - Proposed IMpervious surface amendments We can talk tomorrow after our meeting, but below are our initial comments on the amendment. Clarify language in Table 4.2.5.1 Footnote 2 and Table 4.2.6 Footnote 2. The footnote reads that a BMP shall be required. I think it may be intended that requirement is that the BMP complies with state and local standards. But if not, then it should be clarified as to when or why the BMP is required. Question on scope. The amendment outline says this is to incorporate the use of permeable pavement as a means of modifying the allowable impervious surface. Footnote 5 regarding table 4.2.6 states that staff would like to discuss modifying the provisions. I'm uncertain on the impact of these changes and their implications. Redundancy in Table 4.2.5.1 re: state standards. Several districts have a statement added that requires 2 -acre parcel with a notation that this is in order to be consistent with current State allowances. Footnote 2 requires the BMP to be in accordance with State standards. Recommend keeping only the footnote (by keeping the reference it automatically updates if the State changes their standards, whereas the other would need to be amended). 4.2.8 C 1 Remove second sentence. This explains, but does not regulate. 4.2.8 C 5 What are the departments reviewing for? Additional review creates delays and openings for liability if there aren't standards to go by. If the agreement is in accordance with state regs, then there shouldn't be review necessary beyond that. From: Michael Harvey Sent: Friday, March 27, 2015 9:00 AM To: Craig Benedict; Tom Altieri; Perdita Holtz; Ashley E. Moncado; Howard W. Fleming; Wesley Poole; Steve J Kaltenbach; Patrick R. Mallett; Sam M. Schultz; John Roberts; James Bryan; Anne Marie Tosco Subject: Internal Peer Review - Proposed IMpervious surface amendments The Planning Department has completed an initial draft of a LIDO text amendment related to allowing for additional opportunities for property owners to modify impervious surface area. The BOCC authorized staff to initiate this process at their March 17, 2015 regular meeting. I am attaching the approved Amendment Outline form for additional context. Put simply the amendment would allow property owners to increase impervious surface area beyond established limits if they install a stormwater feature, recognized by the State, promoting the capture /infiltration of runoff from the property. Staff is slated to present the item at the May 26, 2014 Quarterly Public Hearing. We are asking for your comments on the proposed amendment(s) to be submitted by 5:00 p.m. April 17, 2015.