Letter to North Roylaton from NoRoFF about New Report from us.

From: NoRo Flood Fight, LLC.
8954 Albion Road
North Royalton, OH 44133

June 3, 2025

To: North Royalton Storm Water Committee, Planning Commission and Mayor, Larry Antoskiewicz
North Royalton City Hall
14600 State Road
North Royalton, OH 44133

Subject: Urgent Request to Pause Subdivision Approvals and Update Stormwater Management Standards

Dear Members of the Storm Water Committee, Planning Commission and Mayor Antoskiewicz,

NoRo Flood Fight, LLC (NoRoFF) is a community organization representing North Royalton residents concerned about increased flooding risks due to new developments, particularly the proposed 29-lot cluster housing project at 9360 Albion Road (Ordinance 25-00).

We submit the attached report, Why North Royalton Must Pause Major Subdivision Approvals Until It Modernizes Stormwater Management Standards, urging the city to halt approvals until it replaces 1980s-era models (e.g., TR-55, Bulletin 71) with climate-adjusted standards. The report demonstrates that:

  • Legal Duty: Chapter 1481 mandates that developments do not increase flooding on other lands (§ 1481.01(a)), requiring peak runoff control for 100-year storms (§ 1481.01(c)).
  • Outdated Models: The city’s use of TR-55 with 1992 rainfall data underestimates flood risks compared to NOAA Atlas 14, violating § 1481.01 (NOAA, https://hdsc.nws.noaa.gov).
  • Modern Standards: NOAA Atlas 14, Ohio Rainwater and Land Development Manual, and NEORSD rules are best practices ignored by the city (Ohio EPA, https://epa.ohio.gov).
  • Legal Risks: Approvals based on deficient models risk appeals (R.C. § 2506.01), tort claims (R.C. § 2744.02(B)(2)), and takings actions (State ex rel. Doner v. Zody, 2011).
  • Recommended Actions: Impose a moratorium, adopt modern standards, require developer resubmissions, collaborate with NEORSD, and engage residents via hearings.

Failure to act constitutes a dereliction of the city’s duty under § 1481.01(a), exposing North Royalton to liability and endangering residents. We request:

  • A moratorium on all subdivision approvals, including Ordinance 25-00, pending updated standards.
  • An emergency ordinance amending Chapter 1481 to adopt NOAA Atlas 14 and climate-adjusted models.
  • A public hearing within 30 days to review these concerns, as per Article III(f).

NoRoFF stands ready to collaborate with the city, NEORSD, and residents to develop a resilient stormwater strategy.  We’re already speaking with Council Person Gorjanc on ways our organization can help with educating homeowners about riparian plantings and other natural solutions to prevent flood erosion. Please respond by June 11, 2025, the next planning commission meeting to discuss next steps. Contact us at info@norofloodfight.org.

Sincerely,
Edward Jacak
Community Leader, NoRo Flood Fight, LLC

On behalf of North Royalton residents

Edward.jacak@NoRoFloodFight.org

(m) 440.941.5150

www.NoRoFloodFight.org

Attachment: Comprehensive Report