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6 <br /> <br />are not distinguishable, the top of banks shall be as determined by the <br />Engineering and Construction Division based on the adjacent slopes and/or the <br />extent of riparian vegetation. <br /> <br />Through various submittals beginning in April 2014, the applicant had depicted the top <br />of bank in its original location as shown in the 2006 entitlement application (this location <br />was also utilized for the proposed project and alternatives analyzed within the certified <br />EIR). In June 2014, MacLeod and Associates (project civil engineer and land surveyor) <br />provided cross-sections of the Cordilleras Creek bank along Lots 1-4. A total of 16 <br />cross-sections were cut, utilizing the underlying topographic survey (also prepared by <br />MacLeod and Associates). The Applicant hired Berry & Associates, a local civil <br />engineering firm, to independently review MacLeod’s methodology, cross-sections and <br />top of bank location. Berry & Associates provided a letter outlining their concurrence <br />with McLeod’s top of bank location (original location). <br /> <br />On July 14, 2014, Kamman Hydrology & Engineering Inc., submitted a letter to the City <br />on behalf of the Friends of Cordilleras Creek (Friends), challenging the Applicant’s <br />topographic survey and top of bank location. MacLeod and Associates responded in a <br />letter dated August 5, 2014. <br /> <br />Upon review of all information provided by both the Applicant and Friends, as well as a <br />site visit to physically observe the creek and top of bank, the City issued a letter on <br />October 2, 2014, agreeing with the Friends’ top of bank location. To keep the project <br />moving forward, the Applicant has accepted this revised top of bank location and it is <br />depicted accordingly on the plan sets included in this application. <br /> <br />Stormwater Treatment (Article 32, Section 32.12) and Use Permits (Article 42) <br />In 2006, Redwood City adopted the Stormwater Treatment Ordinance to “minimize the <br />discharge of pollutants in stormwater runoff and to reduce erosion and sedimentation in <br />existing streams, lagoons, and wetlands.” Section 32.12.F specifically applies to <br />properties along protected watercourses and establishes required setbacks for creek <br />protection. Because the project site is along Cordilleras Creek, a protected watercourse, <br />all creek protection measures within Section 32.12 apply. <br /> <br />The current amended application removes all existing structures and impervious <br />surfaces on the project site (20,222 square feet in total), except for the existing retaining <br />walls along the top of bank and downslope from the top of bank. The project proposes <br />nine new homes (23,247 square feet of roof area) and a minimal amount of impervious <br />ground cover (900 square feet) for a total of 24,147 square feet of impervious coverage <br />(an increase of 3,925 square feet over existing site conditions). <br /> <br />Minor grading would occur within 25’ of the top of bank due to the removal of the <br />existing structures and impervious surfaces. This grading would not negatively affect <br />the stability of the creek bank or water quality. As the removal of all existing structures <br />within the 25’ creek protection setback area was anticipated as part of the original <br />project, it was analyzed and mitigated within the certified EIR. <br /> <br />The project would incorporate an on-site storm drainage system, including surface <br />swales, bioretention trenches and pervious surfaces (driveways, roadway and guest <br />8.B. - Page 99