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Fi din~:The erosion program will be adequately staffed and administered to ensure <br /> it will not cause any delays in the issuance of building permits. Other non-building permit <br /> construction activities, such asquick-start agreements and grading permits may be affected. <br /> Quick permit turnaround is a high priority for the program. <br /> Comment 11. There is no documentation of an erosion problem related to <br /> construction activities. <br /> Findin :During the time of development of the program (1995), surveys of <br /> construction site for a variety of land use types, including single family residential, revealed <br /> erosion, sedimentation, and other impacts related to construction activities (trash, improper <br /> storage of toxic materials). <br /> Comment 12: Some of the professions listed as qualified to prepare construction site <br /> management plans are less qualified than contractors and builders. <br /> Findin :The list generally represents those professions familiar with the building <br /> and construction trades. This list has been reviewed and recommended by a Department <br /> Advisory Committee that includes across-section of occupations including a home builder. <br /> There is a provision that allows the City Manager to approve additional professions on a <br /> case-by-case basis. Therefore, there is no need to adjust the rule at this time. <br /> Comment 13: How can City justify this program in-light of Ballot Measure 47? <br /> indin The erosion program is financed through erosion permit fees and, <br /> therefore, is not dependent on property tax revenues. Protecting water quality is a federally <br /> mandated program for the City of Eugene. Erosion prevention is a component of that <br /> program. <br /> Comment 14: The program places too much emphasis on regulations and permits; <br /> should be on anhonor-basis. <br /> indin :This issue was raised at the time of adoption of the erosion ordinance. The <br /> ordinance was approved by the City Council containing the level of regulations and permit <br /> requirements as reflected ~ tbis Administrative Rule. This issue was addressed by the <br /> Department Advisory Committee which recommended the level of regulation and permit <br /> requirements as contained in the ordinance and rule. The current level was determined <br /> necessary to address negative water quality impacts due to both large and smaller sized <br /> construction activities. In order to lessen the extent regulations and permit requirements the <br /> recently approved ordinance would have to be amended. That action is out of the scope of <br /> the Administrative Rule making process. Therefore, there is no need to adjust the rule. <br /> Comment 15: General public should be required to meet erosion outcomes. <br /> <br /> Erosion Prevention Administrative Rule R-6.645 - 4 <br /> <br />