Amended complaint - PennFuture

42. The additional volume of stormwater runoff increases the likelihood ofdowngradient flooding, channel erosion and water quality impacts.Impacts43. The drainage channel on the SRA Property has experienced severe erosion sinceconstruction of Tripp Park began.44. Since construction of Tripp Park began, a gorge approximately eight feet deep hasformed at the outlet of the pipe coming from Tripp Park at the head of thedrainage channel on the SRA Property.45. The SRA Property contains debris, including but not limited to tires andappliances.46. The eroded material and debris gather in the culvert at the end of the drainagechannel just above the Medallis Property, clogging the existing storm sewersystem.47. During storm events, the drainage facilities located on the 1200 Block of PierceStreet overflow, back up, and otherwise malfunction, resulting in inundation ofthe Medallis Property with stormwater, and causing substantial, severe, andongoing damage as described below.48. Mr. Medallis or a member of his family has lived at the Medallis Property sinceapproximately 1955.49. Prior to the time that construction of Tripp Park began, the Medallises did notexperience any flooding problems on the Medallis Property during storm events.