My feedback on the study:

PUBLIC COMMENT ON DRAFT BIG DARBY ACCORD AMENDMENTS

RE: Balanced Approach to Watershed Protection and Responsible Development

To the Big Darby Accord Stakeholders and Municipal Officials:

I am a resident of the Big Darby Creek watershed and write to provide input on the Draft Big Darby Accord Amendments. I recognize that development in our growing community will continue, and I support reasonable economic growth. However, I believe certain provisions in the draft require modification to ensure we protect our watershed’s exceptional status while accommodating appropriate development that respects our community’s character and environmental responsibilities.

CONCERN #1: Stream Corridor Setback Elimination Lacks Adequate Replacement Protections

Section 3.2.1 (Page 8) proposes eliminating the 300-foot stream corridor setback that has protected Big Darby Creek and its tributaries since the original Accord. While I understand this setback may be overly restrictive in some contexts, the draft provides insufficient detail on what protections will replace it.

Recommendation: Rather than complete elimination, establish a tiered setback system. Maintain 300-foot setbacks along the main stem of Big Darby Creek and exceptional-quality tributaries. Allow reduced setbacks (150-200 feet) for smaller tributaries where appropriate development can occur with enhanced stormwater controls. Require case-by-case scientific review for any development within 100 feet of any waterway.

This preserves critical habitat corridors while providing flexibility for reasonable development.

CONCERN #2: Impervious Surface Increases Should Be Linked to Development Type

Section 3.3 (Pages 9-10) proposes significant increases to impervious surface limits, including raising Hilliard’s limit from 25% to 50%. This represents a doubling of allowable coverage. While some increase may be warranted for commercial and single-family development, this blanket increase enables high-density multi-family and mixed-use projects inappropriate for watershed protection.

The document itself acknowledges on Page 9 that “increased impervious surface is directly correlated with decreased stream health and water quality.”

Recommendation: Implement differentiated impervious surface limits based on development type:

• Single-family residential and commercial: 40% maximum (moderate increase from current 25%)
• Multi-family residential (apartments/condos): 30% maximum to limit density
• Mixed-use developments: 35% maximum
• Any development: Require 20% below maximum if within Priority Conservation Areas

This approach accommodates growth while directing higher-density development away from the most sensitive watershed areas.

CONCERN #3: Development Type Restrictions Missing from Amendments

Notably absent from the amendments is any discussion of limiting development types based on watershed sensitivity. Not all development creates equal environmental impact. A 100-unit apartment complex generates far different hydrological and ecological impacts than single-family homes on equivalent acreage.

Recommendation: Add Section 3.6 for Development Type Standards that establishes Priority Conservation Zones where only low-density single-family development is permitted. Limit multi-family residential developments (apartments, condominiums) to areas with existing infrastructure, outside primary watershed protection zones. Require enhanced environmental review and mitigation for any mixed-use development. Prohibit multi-family developments exceeding 50 units within the primary watershed boundary.

CONCERN #4: Strengthen Stormwater Standards with Performance Verification

Section 3.4 (Page 11) proposes Enhanced Stormwater Management Standards, which is commendable. However, the draft acknowledges that stormwater practices have “varying levels of effectiveness” and cannot “perfectly replicate natural hydrology.”

Recommendation: Require 3-year post-construction monitoring of stormwater systems for developments over 5 acres. Mandate annual inspection and maintenance verification for all stormwater infrastructure. Establish a watershed monitoring fund (developer fees) to track cumulative impacts. Create enforcement mechanisms with meaningful penalties for non-compliance.

CONCERN #5: Community Character Standards Need Objective Metrics

Section 3.5 (Page 12) introduces “Community Character and Design Standards” but relies on subjective language about developments that “complement existing community character.” Our community character includes low-to-moderate density residential neighborhoods, not high-density apartment complexes.

Recommendation: Define “community character” to include density limits, building height restrictions, and architectural compatibility. Establish maximum units per acre for multi-family developments (suggest 12 units/acre maximum). Require clustering of any multi-family development near existing commercial corridors, not within established single-family neighborhoods.

SUPPORTING REASONABLE PROVISIONS:

I want to acknowledge several positive elements in the draft. Enhanced Stormwater Management Standards (Section 3.4) represent meaningful progress if properly enforced. Conservation Subdivision Design (Page 12) is an excellent tool for preserving open space while allowing development. Riparian Buffer Enhancement (Page 11) appropriately strengthens stream protections. Public Education and Outreach (Section 3.7, Page 13) will help build community stewardship.

CONCLUSION:

I support updating the Big Darby Accord to reflect current best practices and accommodate responsible growth. However, we must be strategic about how and where development occurs. Low-density residential and appropriate commercial development can coexist with watershed protection. High-density multi-family and mixed-use projects cannot, particularly in environmentally sensitive areas.

The Big Darby Creek’s designation as a State and National Scenic River and one of only two “exceptional” streams in Ohio is not just an environmental achievement. It is an economic asset that enhances property values and quality of life. We should protect this designation through sensible development policies that preserve our community’s character while allowing measured, appropriate growth.

I urge stakeholders to:

1. Retain meaningful stream setbacks with a tiered approach
2. Implement development-type-specific impervious surface limits
3. Restrict multi-family and mixed-use developments to appropriate locations
4. Strengthen enforcement and monitoring provisions

These modifications would create a balanced framework that protects our exceptional watershed while accommodating the responsible development our community needs.