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HomeMy WebLinkAbout2.0 PC Staff Report 04.14.1993PC 4-14-93 PROJECT INFORMATION AND STAFF COMMENTS REQUEST: Sketch Plan and PUD Amendment - Westbank Ranch PUD Filing #4 APPLICANT: Westbank Ranch #1 LTD PLANNERS: Jerome Gamba & Associates ENGINEERS: Jerome Gamba & Associates LOCATION: A parcel of land located in portions of Sections 35 T6S, R89W, Section 1 and 2, T7S, R89W of the 6th P.M.; more practically described as a parcel of land located south of Westbank Ranch PUD Filing #1, #2 and #3, south of County Road 109, approximately 3.5 miles southeast of Glenwood Springs. SITE DATA: A 285.08 acre parcel to be split into tracts of land that would allow a maximum of 98 single-family dwelling units. WATER: Wells - Community System SEWER: ISDS ACCESS: County Road 109 EXISTING ZONING: PUD I. RELATIONSHIP TO THE COMPREHENSIVE PLAN The proposed PUD is located District 1C -Central Water and Sewer, Severe Environmental Constraints as indicated on the Comprehensive Plan Management Districts Map. II. DESCRIPTION OF THE PROPOSAL A. Site Description: The proposed PUD is located on a bench overlooking the Roaring Fork river valley floor, directly above the existing Westbank development. Topography on the site consists of three distinct geologic configurations: a moderately sloping lowland fully vegetated with native grasses, a steeply sloped zone sparsely vegetated with evergreen species, sagebrush, and native grasses, and an upland benched area well vegetated with significant sagebrush, rabbitbrush, and isolated stands of pinion and juniper. 1 B. • Several intermittent drainages are visible in the steeper portions of the property and extend into the upland bench. Elevations on the property range from 5,950 at the northern edge, to almost 6,880 feet at the southern reaches of the property. A vicinity map is attached on page Background: Westbank Filing #4 was approved and platted in September of 1982. At that time, Filing #4 included the following uses; 40 single-family dwellings, 20 duplex units, and 40 fourplex units for a total of 100 dwelling units on 60 lots on the 285 acre parcel. The original proposal included a central sewage treatment facility, which was included in the SIA. Table 1 summarizes the primary differences between the approved project and the modified proposal. A site plan will be presented at the public meeting. Since that time, the Subdivision Improvements Agreement (SIA) has been amended in respect to two dates: the deadline for improvements has been changed from November 1, 1984 to November 1, 1994; and the deadline for security for the improvements described in the SIA has been extended from July 1, 1983 to July 1, 1993. These amendments were made in response to a public meeting to consider the revocation of the approval of Filing #4 in March of 1992, due to the failure to complete any of the required improvements on the site. C. Development Proposal: The plan has been modified in several respects from the previously approved project. The current proposal contains 98 single-family lots for a total of 98 dwelling units. The modified plan contains lots ranging from 1.0 to 15.0 acres in size, with the majority of lots in the 1.0 to 2.0 acre range. The approved project contained lots ranging from 0.44 to 1.94 acres, with 36 of the 58 dwelling units being less than one acre. The modified plan calls for 91 dwelling units on the upper bench and 7 on the lower bench. The approved project calls for 81 dwelling units on the upper bench and 17 on the lower bench. The road alignment has also changed to reflect the modified lot configuration. The previous plan anticipated an expansion of the existing water system which currently serves Westbank Filings 1, 2 and 3. The modified plan includes a system separate system, with water to be provided from new well(s) to be augmented with Ruedi Reservoir water. A total of 64 feet of water is to be purchased from Ruedi for the needs of the development. Fire protection will be provided via hydrants and a storage system. Table 1 summarizes the primary differences between the previously approved project and the current proposal. III. REVIEW AGENCY/PLS BLIC COMMENTS A. Colorado Geological Survey: No comments have been received from the Geologic Survey. Staff does not typically refer projects of this type to the Geologic Survey until the Preliminary Plan Phase. B. Colorado Department of Health: Staff has had several conversations with Dwayne Watson concerning this project. Mr. Watson has serious concerns with the proposed ISDS systems, including slope and soil constraints. Furthermore, Mr. Watson questions if the slope constraints on the site physically prohibit ISDS on some lots within the PUD. 2 TABLE 1 COMPARISION BETWEEN APPROVED AND PROPOSED PROJECT DESIGN COMPONENT APPROVED PROJECT PROPOSED PROJECT Dwelling Type and Number 10 four-plex lots, 10 duplex lots and 38 single-family lots (98 Total DUs) 98 single-family dwelling units Lot Size 0.44 acres to 1.94 acres (36 of 58 less than 1 acre) 1.0 to 15.0 acres (0.344 DUs/acre) Site Plan 81 DUs on upper bench and 17 on lower bench 91 DUs on upper bench and 7 on lower bench Water Supply Expansion of existing system serving Westbank Filings I through III Separate sytem augmented with Ruedi water Sewage Disposal Central System ISDS Zone Districts Residential/Single Family, Residential/Cluster Housing, Residential/Multi Family, Open Space Residential/Single Family C. Colorado State Forest Service: The Colorado State Forest Service reviewed the project, and conducted fieldwork on April 1, 1993. The proposed subdivision is in an area that has been mapped as medium to high hazard for wildfire. The Forest Service was particularly concerned with areas in the subdivision that where grades exceed 30 percent and the densely vegetated drainages. In addition, Forest Service standards require dual ingress/egress points, which are not included in the proposal. Furthermore, the cul-de-sacs exceed the 750 foot maximum length as recommended by their standards. Turnouts are recommended at 750 intervals to provide adequate emergency vehicle access. A copy of Kelly Roger's April 7, 1993 letter is attached on page. ? D. U.S. Bureau of Lend Management: The BLM had the following comments on the proposal: 1. The BLM recommended fence standards that allow for easy passage by big game; 2. The parcel immediately adjacent to the site has been identified as a disposal parcel, and is not expected to remain in public ownership; 3. The density proposed by the applicant will render the critical mule deer habitat un suitable for deer habitat, and will increase deer impacts on adjacent property, particularly during the winter months; 4. The soils on the site are poorly suited for housing development due to shallow depth to bedrock, steep slopes, and very high hazard of water erosion. 3 A copy of Michael Mottice's April 2, 1993 letter is attached on page VI E. Public Service Company: No response has been received from Public Service. F. Colorado Division of Wildlife. The Division has noted that the area is considered to be elk winter range and critical deer habitat, meaning that the loss of critical winter habitat would adversely affect deer in the area. DOW further states that big game populations in the area will be threatened by domestic dogs, loss of native vegetation, increased erosion, increased vehicular traffic, increased human/wildlife interaction, and migration obstacles. The DOW suggests the following mitigation: 1. Reduce the density by cluster development; 2. Require underground utilities to protect raptors; 3. Require fencing restrictions; 4. Restrict or prohibit domestic dogs and horses within the subdivision; 5. Restrict building envelopes to preserve native vegetation. In addition, the DOW suggests that all homeowners are aware of the critical habitat designation, and realize that deer and elk will die on the property, and are responsible for disposing of carcasses. A copy of Larry Green's April 2, 1993 letter is attached on page /0 // G. Roaring Fork School District RE -1: No Response. H. Office of the State Engineer Division of Water Resources: No response. J. Public Service Company: No response. K. Holy Cross Electric Association: No Response. L. U.S. West Communications: No Response. M. Rocky Mountain Natural Gas: No Response. IV. STAFF COMMENTS This application is addressing two separate processes: A PUD zone amendment addressing the changes in the zone districts on the site; and the sketch plan for the revised subdivision design. These two processes require compliance with different standards, and each is addressed below separately. 1. PUD REZONING REQUEST: Westbank Filing #4 was processed as a PUD, with the existing portions of the project processed as a subdivision request. The standards for the current proposal (Zone District Amendment) are addressed in Section 4.0 of the Zoning Resolution. PUD Objectives: A PUD may be approved by the County Commissioners for the following purposes and to achieve the following objectives: 4 1. To provide necessary commercial, recreational, and educational facilities conveniently located to housing; 2. To provide well -located, clean, safe and pleasant industrial sites involving a minimum of strain on transportation facilities (NOT APPLICABLE); 3. To insure that the provisions of zoning laws which direct the uniform treatment of dwelling type, bulk, density, and open space within each zoning district will not be applied to the improvement of land by other than lot -by -lot development in a manner which would distort the objectives of the zoning laws; 4. To encourage innovations in residential, commercial and industrial development and renewal so that the growing demands of the population may be met by greater variety in type, design, and layout of buildings and by the conservation and more efficient use of open space ancillary to said buildings; 5. To encourage a more efficient use of land and of public services, or private services in lieu thereof, and to reflect changes in technology of land development so that resulting economies may inure to the benefit of those needing homes; 6. To lessen the burden of traffic on streets and highways; 7. To conserve the value of land; 8. To provide a procedure which can relate the type, design, and layout of residential, commercial, and industrial development to the particular site, thereby encouraging preservation of the site's natural characteristics; or 9. To encourage integrated planning in order to achieve the above purposes and objectives of development.' In the application, the applicant states that "The modifications are being proposed because it is felt that the multiple family concept is no longer in keeping with the development that has occurred in the general area".2 Staff contends that this assertion is not consistent with Objective #4 (above) for the following reasons: • The purpose of innovation, by both definition and the spirit and intent of the PUD objectives, is not to perpetuate adjacent development; • The growing demands of the population in the upper -valley region are more consistent with the cluster -multi -family concept previously approved, as opposed to the current proposal. Empirical evidence is available to support this contention, including the lack of affordable 'Section 4.02 Purposes and Objectives of Development, Garfield County Zoning Resolution, 1984 as amended. 2Westbank Ranch Planned Unit Development Modification and Westbank Ranch Filing #4 Subdivision, page 1. 5 housing in the upper -valley region, and the subsequent shift ofemployees to the down -valley communities were affordable is still available. The increased commuting pressure to up -valley employment sites is evidence of this shift. The applicant also states that "..the difficulty in permitting and constructing sewage treatment facilities which would discharge to the Roaring Fork River has caused the construction of a central sewage collection system to be impractical".3 Impractical can take several meanings, however the regional system proposed at Aspen Glen appears to address the traditional use of the term, and is certainly a superior, although costly alternative to the current proposal for individual ISDS systems. Staff recognizes that the Aspen Glen site, due to the distance and topography from Westbank #4, may prove to unfeasible, but the applicant has failed to address the issue. Consistency with the General Plan: Section 4.04 requires that "No PUD shall be approved unless it is found by the County Commissioners to be in general conformity with the County's General Plan. The following analysis attempts to identify potential conflicts consistent with the section of the PUD requirements. Mousing: The overall goal of the housing section of the Comprehensive Plan is as follows: Provide for affordable and diverse housing types capable ofaccommodating needs of County residents, in all income ranges, without putting a financial burden on existing public services 4 Objective #3 calls for the promotion of a variety of housing types and mix through the use of a flexible development review process. Policy #3 states that the PUD process is encouraged, so that the development community has greater flexibility in project design.' In staff's opinion, the cluster concept proposed in the original application is more in line with the housing goals described earlier than the current application. Recreation and Open Space: Policy 5 requires that areas such as floodplains and geological unstable soils which are restricted for the building of habitable structures will be used as common open space accessible to the public in new developments. No additional geologic data has been provided by the applicant because the engineering geology report prepared by Lincoln-Devore Laboratories in 1982 was incorporated by reference in this application. The geologic report and mapping provided with the original approval identifies a historic gravel pit near the center of the site. Considerable has been removed and relocated in this area, and is mapped as man-made fill (Qf1). This fill material is considered 3lbid, page 1. 4Garfield County Comprehensive Plan, page 2. 5Garfield County Comprehensive Plan, page 2. 6Garfield County Comprehensive Plan, page 7. 6 "unacceptable for foundations or other structures" without being removed and recompacted".' This area is currently proposed for platted lots, with no explanation regarding mitigation. This appears to be inconsistent with the Comprehensive Plan policies cited earlier. A small landslide is located along the southern portion of the site, were a slump has occurred in the Eagle Valley Evaporite and colluvial material overlying it. The engineering report suggests that these areas be avoided, or proceed only with detailed studies. This area is also indicated for residential development.' Transportation: Policy 5B requires that excessive road cuts that will create negative visual impacts will be discouraged. The proposed road alignment crosses numerous drainages, and no cut/fill estimates or visual analysis information has been submitted. Therefore, it is not possible for staff to determine compliance with this policy. Water and Sewer Services: Objective 3 encourages developers to carefully analyze the site's capability to accommodate individual sewage disposal when it is being considered as a part of a development proposal. Policy 3A states that the County will require developers proposing ISDS to provide information that demonstrates to the County that the land involved can physically accommodate the individual systems.1D The original proposal, and the Geologic Report prepared in 1976, did not address the feasibility of ISDS on the site due the proposed central sewage system. Therefore, no perc tests have been done on any of the proposed lots. The only source of data available to staff regarding the suitability of ISDS on each lot are from the Soil Conservation Service. Table 2 summarizes each soil type present on the lots and the suitability of each soil type for housing development and ISDS systems. Staff recognizes that SCS maps are for general planning purposes and that these constraints may be able to be addressed through engineering means. However, no information has been submitted by the applicant at this time addressing these constraints. 'Lincoln-Devore Laboratories, General Soils and Engineering Report, July 18, 1976, page 10. 8lbid., page 7. 9Garfield County Comprehensive Plan, page 8. '°Garfield County Comprehensive Plan, page 10. 7 TABLE 2 SOIL SUITABILITY SOIL NAME BUILDING DEVELOPMENT SUITABILITY (1) ISDS SYSTEM SUITABILITY (2) Gypsum Land - Gypsiorthids Slight Moderate (Slow percolation) Dahlquist - Soutbace Complex Severe (Slope and large stones) Severe (Poor filter, large stones) Earsman - Rock Outcrop Complex Severe (Slope and depth to bedrock) Severe (Depth to rock, slope) Empedrado Loam Moderate (Slope) Moderate (Slope) Gypsum Land - Gypsiorthids Complex Severe (Slope) Severe (depth to rock and slope) Soutbace Cobbly Sandy Loam Severe (Slope) Severe (Slope) Uracca, Moist - Merge] Complex Severe (Slope and large stones) Severe (Slope and large stones) 1) Assumes a single-family dwelling unit with no basements (2) Assumes a typical septic tank absorption Geld Source: Soil Survey of Aspen -Gypsum Area, Colorado, U.S. Department of Agriculture, Soil Conservation Service, May, 1992. Table 10 - Building Site Development (pages 191 - 200), and Table 11 - Sanitary Facilities (pages 201 - 210). Environment: Objective 1 discourages the development of land in areas of identified severe environmental constraints. Policy 1, designed to implement this objective, requires that the County shall discourage and reserve the right to disapprove (sic) development in areas with identified severe environmental constraints such as active landslides, debris slides, unstable slopes, bedrock slides, major mudflow, radioactive tailings, slopes over 25 percent and 100 year floodplain. Objective 5 requires projects ensure that development on land having moderate or minor environmental constraints consider the limitations of the land." Objective 6 requires that development proposals consider soil constraints as a part of the physical design, and policy 6 requires that the County discourage development in areas with severe soil constraints. Objective 9 encourages development in areas with the least environmental constraints prior to land with the greatest physical limitations.12 Garfield County has traditionally used the Lincoln-Devore Laboratories Natural Hazard Maps produced for the County in 1976 to determine areas of severe environmental constraints. These maps served as the basis for the "severe" classifications that appear on the Comprehensive Plan Management Districts Map, which identified the area including this project within the "severe" "Garfield County Comprehensive Plan, page 12. 12Garfield County Comprehensive Plan, page 13. 8 designation. Staff referenced the original working maps used for the management district maps, and these maps included the following findings: • The proposed subdivision is located in areas of Minor, Moderate and Major slope hazards, including areas platted as single-family dwelling units; • The proposed subdivision is located in areas of Moderate and Major soil hazards, including areas platted as single-family dwelling units; • The proposed subdivision is located in areas defined as Severe for septic systems. A graphic portrayal of the project's relationship to the hazard areas identified by Lincoln-Devore is shown on page taft. Staff is not suggesting that these constraints cannot be addressed from an engineering perspective, however no evidence of mitigation has been submitted by the applicant. Furthermore, staff questions if these constraints were considered in the subdivision design that is now proposed for this phase of the development. Objective 4 requires that the developer ensure that natural drainages are protected from soil erosion that would result from alteration. In the application, the project engineer points out that "..the road system serving the development will cross a number of major drainages. Drainage structures for these crossings will be designed on the basis of computer analysis of the drainage basins which they serve and on a 25 year frequency storm event."" No evidence has been submitted regarding possible alternatives to the geometry of the proposed roadway system, or evidence suggesting that the proposed alignment was designed to limit these impacts. Performance Standards: The Comprehensive Plan includes a series of perfornlance standards addressing specific environmental constraints, including areas having slopes greater than 25 percent. The Plan states that slopes exceeding 25 percent may be: 1. Maintained as open space; 2. Platted as a portion of an approved building envelope, with an open space easement; 3. Platted as a portion of a building lot which as adequate usable building space available other than steep slopes; 4. Platted as a portion of a subdivision and dedicated as permanent open space; 5. Developed with special design considerations and engineering.i4 The applicant has failed to provide staff with a slope analysis to assess compliance with these requirements. 13Application, page 5. t4Garfield County Comprehensive Plan, page 27. 9 Performance standards also address the impact of development on the natural terrain. Specifically, the Plan requires that the proposed development should be designed in a manner which demonstrates a "fit" with the existing topography of the land.15 Staff has no evidence of cut/fill estimates to assess compliance with this requirement, although the current road alignment appears to have significant topographical constraints due to the crossing of several major drainages on the site. Sewage Disposal facilities are also addressed by performance standards. Specifically, the Plan requires that central sewage disposal systems be included in proposals that have severe or moderate septic limitations. The State Department of Health and hazard maps reviewed by Staff indicate that the site poses significant constraints to traditional ISDS systems. Rather than proposing a system in compliance with the standard, the applicant has removed the central sewer from the proposal, and appears to violate this standard. Of particular note is the failure of the applicant to provide data that supports the suitability of the site for ISDS. Zoning Requirement$: Section 4.08 addresses the PUD processing requirements, and the following discussion addresses specific requirements that do not appear to have been met by the application:16 1. Under provisions of Section 4.08.05(2)(h), the applicant is required to identify sites suitable for construction, as well as sites suitable for sewage disposal based upon the severe limitations described in the soils report. As described earlier, this area has significant slope and soil constraints. These issues have not been addressed by the applicant, and staff questions if the physical design of the PUD considered these limitations; 2. Under provisions of Section 4.08.05(7)(E)(i), the applicant is required to identify the proposed water source adequate to serve the PUD. The proposed water source is a well augmented by Round II sales from Ruedi Reservoir. It is not clear that such water contracts are currently available, or whether the amount identified by the applicant is adequate to support a well servicing the PUD. Additionally, the calculations contained in Exhibit B of the application are not signed, nor explained in any manner; 3. Under provisions of Section 4.08.05(7)(E)(ii), the applicant must describe the proposed method of sewage treatment. In regards to sewage treatment, staff has previously noted the difficulties of the system proposed in any area with soils that may not be appropriate for ISDS, slopes that may not accept ISDS, and unknown percolation rates. This provision of the Code inherently requires that the system proposed is functional and responsive to unique conditions of the site. The evidence in this regard is inconclusive; 15Garfield County Comprehensive Plan, page 28. 16Garfield County Zoning Resolution, 1984 as amended, pages 39-41. 10 4. Under provisions of Section 4.08.05(7)(E)(iii), the applicant must describe the general manner in which storm drainage will be handled. There is little or no evidence as to the method in which storm drainage for the PUD will be addressed; 5. Under provisions of Section 4.08. 05(7)(F)(iv), the applicant must address legal access to the site. Garfield County Road Standards allow cul-de- sacs that do not exceed six hundred feet (600') in length. The Board of County Commissioners may approve longer cul-de-sacs for topographic reasons and it can be proved that fire protection and emergency access is provided." The longest cul-de-sac within the PUD extends from an intersection with the northeast cul-de-sac to a point at the northwest corner of the PUD. This cul-de-sac is approximately 4,486 feet in length, with no alternative access. No topographic explanation is included in the application. This is of particular concern to staff, particularly in regards to the wildfire potential on the site. 6. Under provisions of Section 4.08.05(7)(G), the applicant must provide evidence that the PUD has been designed with consideration of the natural environment of the site and the surrounding area and does not unreasonably destroy or displace wildlife, natural vegetation, or unique natural or historic features. The current plan, based on documentation from the Division of Wildlife cited earlier, will displace wildlife. There does not appear to be a statement regarding the manner in which consideration has been given to the affects this impact. Furthermore, staff contends that the overall design of the road geometry and lot configuration failed to consider the unique physical constraints on the site. V. STAFF RECOMMENDATION Based on staff review of the application, and an assessment of the consistency with Comprehensive Plan policies and the Zoning Resolution, staff recommends denial of the application. A number of issues may be able to be addressed through extensive conditions, although staff suggests that these conditions would require extensive discussions with the applicant beyond a public meeting. If the Commission feels that these issues can addressed at Preliminary Plan, the following conditions of approval are offered as a starting point: General 1. All representations, either within the application or at stated at the public hearings before the Planning Commission and the Board of County Commissioners shall be considered conditions of approval unless stated otherwise by the Planning Commission and the Board of County Commissioners. the public hearing, are considered conditions of approval. "Garfield County Subdivision Regulations, Section 9.33(A), page 9-2. 11 Geology 2. The Preliminary Plan shall have a building envelope designated for every lot within the PUD. All building envelopes will avoid active and older landslides, manmade fill, and unsuitable slopes. Construction upon debris fans and younger alluvial fans shall be avoided unless properly mitigated. No lot will be created that does not contain an acceptable building envelope. No lot shall be created that is smaller than the minimum lot size allowed in that particular zone district. 3. At the time of Preliminary Plan submittal, the applicant shall submit a detailed debris flow study for all lots on debris fans, with a proposed mitigation plan designed by a geotechnical engineer. 4. Additional soils investigation of Moderate and High Hazard areas, as defined by the Lincoln-Devore Hazards Maps and the previous geology report submitted with the previous filings of the Westbank project. Proof will be required at Preliminary Plan that the physical constraints on the site have been addressed in the physical design of the PUD. 5. An engineered foundation shall be required for all structures within the PUD and submitted with building permit applications. Furthermore, all final plats shall have the following plat notes: A. Prior the issuance of a building permit, the owner of each lot shall prepare and submit a soils and foundation report, and ISDS design, and a grading and drainage plan prepared and certified by a professional engineer. All improvements shall be constructed in accordance with such measures which shall be constructed in accordance with such measures which shall be a condition of the building permit. 6. At the time of Preliminary Plan submittal, the applicant will submit a detailed Drainage Plan addressing the existing and historic drainage basins on the site. Furthermore, proof will be required that the physical design of the lot configuration and road alignments respect these natural features, or can be mitigated if necessary. 7. Prior to Preliminary Plan submittal, the applicant will perform a slope analysis to ensure that all areas with slopes greater than 40 percent are not included in the minimum lot size determination. Following this analysis, each lot submitted at Preliminary Plan will have be least one (1) acre in size exclusive of areas in excess of 40 percent slope. ISDS 8. At the time of Preliminary Plan submittal, the applicant shall submit an ISDS feasibility study, prepared by a professional engineer, addressing the feasibility of ISDS systems on each lot. Percolation test results will be included in the study. Water Supply 9. At the time of Preliminary Plan, the applicant shall demonstrate evidence of adequate water quantity from the proposed well field for the project. 12 Wildlife Impacts 10. The applicant shall consider incorporating the Division of Wildlife comments within the Protective Covenants, including restrictions on dogs within the PUD as well as the recommended fencing restrictions. Road Alignment 11. At the time of Preliminary Plan, the applicant shall submit cut/fill estimates for the proposed road alignment, including an assessment of the relationship between the proposed road alignment and the visual impacts of the resulting cut slopes. Furthermore, the Preliminary Plan will include detailed design plans and the grade of each section of the roads to determine compliance with Garfield County Road Standards. 12. At the time of Preliminary Plan, the applicant will submit documentation that the lack of a secondary access is acceptable to the Carbondale/Rural Fire Protection District. SKETCH PLAN REQUEST: Section 3.23 of the Garfield County Subdivision Regulations states that "the Planning Commission shall review the application for consistency with the standards and policies set forth in the following: A. Garfield County Subdivision Regulations; B. Garfield County Zoning Resolution; C. Garfield County Comprehensive Plan; D. Garfield County Road Standards and Policies; E. Garfield County municipal comprehensive plans and municipal regulations, as applicable; and F. Other applicable local, state and federal regulations, resolutions, plans and policies, as applicable." The majority of these issues have been addressed in the previous discussion regarding the PUD rezoning approval. All of these issues are appropriate for discussion with the applicant. The sketch plan process is purely informational. Completion of the Sketch Plan process does not constitute approval of the proposed plan. The Sketch Plan comments shall be valid for a period not to exceed one (1) year from the date of the Planning Commission review. If a Preliminary Plan for the proposed subdivision is not presented to the Garfield County Planning Commission within this period, the applicant shall submit an updated Sketch Plan application to the Planning Department for review and comparison with the original application. 13 MEMORANDUM TO: PLANNING COMMISSION FROM: MARK BEAN Q 91:4— DATE: APRIL 9, 1993 RE: ADDITIONAL EASTSIDE COAL CONSIDERATIONS Subsequent to the staff report being completed, some additional concerns and issues were identified, that the Planning Commission should consider: -The Eastside coal discharge permit has limitations that are imposed on the applicant in terms of water quality discharged. The discharges will go into the Farmer's Irrigation Co. ditch. There are no guarantees that should there be an unexpected hydrologic event causing the settling ponds to overflow and damage down ditch agricultural lands, the recourse is litigation through the courts. It has been suggested that the applicant be required to post security with the County, to guarantee nondegradation due to hydrologic event not considered in the design of the mine, allowing property owners to have the Board make a determination without going to court. -The application does not say where the coal is being hauled. Will there be any other County roads impacted? Will trucks to through any municipality? PROJECT INFORMATION AND STAFF COMMENTS REQUEST: APPLICANT: LOCATION: SITE DATA: WATER: SEWER: ACCESS: EXISTING ZONING: ADJACENT ZONING: PC 4/14/93 Eastside Mine, Special Use Permit for a mineral extraction operation Eastside Coal Company, Inc. A tract of land located in portions of Sections 19, T5S, R91W and Sections 23 and 24, T5S, R92W, more practically described as a parcel located approximately 3.5 miles north of Silt off of County Road 237. An 830 acre tract for a coal mine and associated facilities. Individual wells and spring Individual sewage disposal system Via County Road 237 A/R/RD North: South: East: West: I. RELATIONSHIP TO THE COMPREHENSIVE PLAN O/S A/R/RD, O/S A/R/RD, O/S O/S The parcel is located in Districts D, Rural Areas with Moderate Environmental Constraints and District F, Rural Areas with Severe Environmental Constraints. II. DESCRIPTION OF THE PROPOSAL A. Site Description: The site is in the Harvey Gap area of the Grand Hogback and is a narrow valley floor with water running north to south, with the Grass Valley Reservoir on the north end. The terrain is generally fairly steep, with predominantly pinon-juniper trees with Indian rye-grass, cheatgrass, large sagebrush and other similar types of vegetation indigenous to this type of area. Mining activity has occurred in the area since 1913, with an existing mine on the east side of the gap and remnants from previous mining activity on the west side. 1 There is an office, bathhouse, shop and generator shed on the site presently, that are from previous mining activity approved in 1985. B. Project Descri tp ion: The applicant is requesting a special use permit for a coal mine and associated facilities. The request is for a maximum of 20,000 tons per year for the life of the mine. The mine will employ eight (8) people during that time. The disturbed area of the mine site will be a maximum of 13 acres, which will include all buildings, storage and waste disposal areas. The mine portal area is on the east side of the gap and will have the office, bathhouse, shop, generators, powder magazine, water tank, processing plant, coal and rock storage areas and equipment storage areas. The west side of the gap will have the waste disposal area, which is included in the previously noted 13 areas of disturbed area. The mine's water needs will be for dust suppression in the mine, domestic water for the bathhouse, office and sanitary facilities, and for cooling equipment and exhaust scrubbers. The estimated 75,000 gallons per year of domestic water would come from a spring, two wells and water pumped from the mine. Domestic drinking water will be provided from bottled water from a local purveyor. The water is stored in a 10,000 gallon storage tank. Sewage is dealt with by an existing individual sewage disposal system. Coal will be hauled off-site in end dump trailer trucks with a gross weight of 68,000 to 80,000 pounds. It is proposed that there will be an average of five round trips a day, Monday through Friday. The trucks will haul 18 to 25 tons of coal in each load, which will be covered. The trucks will use County roads 237 to 233 to 227, to access Highway 6 & 24 (See map page 3 ). HISTORY Up until 1985, coal mining activity on the subject lands has occurred since 1913, with a maximum annual production of 5,970 tons. In 1985, Garfield County by Resolution 85-42, approved a 200,000 ton/year maximum production. From 1985 to 1990, when the permit expired, the mine produced a maximum of 6,960 tons of coal. Since that time, Eastside Coal has continued to operate as a nonconforming use, with a maximum production level of 857 tons per year. III. MAJOR ISSUES AND CONCERNS A. Zoning: Mineral extraction, processing, storage and material handling are special uses in the A/R/RD zone district. As a special use, certain requirements must be met: 5.03 (1) Utilities adequate to provide water and sanitation service based on accepted engineering standards and approved by the Environmental Health officer shall either be in place or shall be constructed in conjunction with the proposed use; (2) Street improvements adequate to accommodate traffic volume generated by the proposed use and to provide safe, convenient access to the use shall either be in place or shall be constructed in conjunction with the proposed use; 2 (3) Design of the proposed use is organized to minimize impact on and from adjacent uses of land through installation of screen fences or landscape materials on the periphery of the lot and by location of intensively utilized areas, access points, lighting and signs in such a manner as to protect established neighborhood character. 5.03.07 (1) An impact statement demonstrating that the application shall be designed and operated in compliance with the applicable laws and regulations of the County, State and Federal governments, and will not have a significant adverse effect upon: (A) Existing lawful use of water through depletion or pollution of surface run- off, stream flow or ground water; (B) Use of adjacent land through generation of vapor, dust,smoke, noise, glare or vibration, or other emanations; (C) Wildlife and domestic animals through creation of hazardous attractions, alteration or existing native vegetation, blockade of migration routes, use patterns or other disruptions. (2) Truck and automobile traffic to and from such uses shall not create hazards or nuisances to areas elsewhere in the County; (3) Sufficient distances shall separate such use from abutting property which might otherwise be damaged by operations of the proposed uses; (4) Permits shall be granted for those uses only with the provisions that a satisfactory rehabilitation plan for the affected land be submitted prior to commencement of such use. 5.03.08 Industrial Performance Standards: All industrial operations in the County shall comply with applicable County, State and Federal regulations regulating water, air and noise pollution and shall not be conducted in a manner constituting a public nuisance or hazard. Operations shall be conducted in such a manner as to minimize heat, dust, smoke, vibration, glare and odor and all other undesirable environmental effects beyond the boundaries of the property in which such uses are located, in accord with the following standards: (1) Volume of the sound generated: every use shall be so operated that the volume of sound inherently and recurrently generated does not exceed ninety (90) decibels, with a maximum increase of five (5) decibels permitted for a maximum of fifteen (15) minutes in any one (1) hour, at any point of any boundary line of the property on which the use is located; (2) Vibration generated: every use shall be so operated that the ground vibration inherently and recurrently generated is not perceptible, without instruments, at any point of any boundary line of the property on which the use is located; 3 (3) Emissions of smoke and particulate matter: every use shall be operated so as to comply with all Federal, State and County air quality laws, regulations and standards; (4) Emission of heat, glare, radiation and fumes: every use shall be so operated that it does not emit heat, glare, radiation or fumes which substantially interfere with the existing use of adjoining property or which constitutes a public nuisance or hazard. Flaring of gases, aircraft warning signals, reflective painting of storage tanks, or other such operations which may be required by law as safety or air pollution control measures shall be exempted from this provision; (5) Storage area, salvage yard, sanitary landfill and mineral waste disposal areas: (A) Storage of flammable or explosive solids or gases shall be in accordance with accepted standards and laws and shall comply with the National Fire Code; (B) At the discretion of the County Commissioners, all outdoor storage facilities for fuel, raw materials and products shall be enclosed by a fence or wall adequate to conceal such facilities from adjacent property; (C) No materials or wastes shall be deposited upon a property in such form or manner that they may be transferred off the property by any reasonably foreseeable natural causes or forces; (D) All materials or wastes which might constitute a fire hazard or which may be edible by or otherwise be attractive to rodents or insects shall be stored outdoors in accordance with applicable State Board of Health Regulations; (6) Water pollution: in a case in which potential hazards exist, it shall be necessary to install safeguards designed to comply with the Regulations of the Environmental Protection Agency before operations of the facilities may begin. All percolation tests or ground water resource tests as may be required by local or State Health Officers must be met before operation of the facilities may begin. The following are the staff responses to the applicants proposal: 5.03 (1) The applicant has proposed to use water pumped from the mine, a spring and two wells as the source of domestic water. A plan of augmentation has been submitted to the water court, but there is no final ruling 011 the plan. Once the final decree is approved, the applicant will have adequate water for domestic purposes. Sewage is being treated by an existing individual sewage disposal system installed in the 1970's. There is no known capacity of the septic tank or leach field. Either the capacity will have to be determined and found to be capable of handling the proposed needs or a new approved system should be installed per a permit from Garfield County. 4 (2) The applicant has submitted an analysis of the road impacts, based on a road study done for the County by Chen -Northern that concludes that the proposed coal haul trucks will not cause any additional need for improvements to the impacted County roads (See letter pages i %s ). The applicant's analysis uses a different method of analyzing the data developed from the Chen -Northern study and comes to a different, but similar conclusion. The Chen -Northern study used a Falling Weight Deflectometer to test the various County roads strength to establish a level of improvements necessary, to meet the projected traffic impacts for a five (5) year design life. The applicant's analysis used the data from the Chen -Northern study to establish R -values for the pavement and sub -base of the impacted roads. Using these values and the projected traffic loading, the applicant established a one and one-half (1.5) year design life. Both studies conclude that additional overlay depths are necessary to deal with exist' g traffic, but they have different amounts of overlay needed (See rnaps pages 3 + ). A summary of the overlay depths recommended by each study is as follows: Road Chen -Northern (5 yr.) SGM (1.5 yr) CR 227 0.5" 3.5" CR 233 0.7" 3.0" CR 237 (South of Mine) 1.0" 3.5" CR 237 (at Mine) 0.5" NONE The applicant's (SGM) analysis states that the 1990 existing traffic load will require the equivalent overlay, to the 1990 traffic plus the projected coal trucks. In other words, the coal truck traffic will not increase the amount of overlay needed to meet existing traffic loads. The staff has difficulty reviewing the two analysis that utilize different techniques to evaluate the road impacts. Each has a different design life, five (5) years versus one and one-half (1.5) years. The applicant's position is that the trucks will not increase the amount of overlay needed, therefore there is no need for the applicant to make any improvements to the haul road. Section 5.03(2) states that there need to be "street improvements adequate to accommodate traffic volume generated by the proposed use and to provide, safe, convenient access to the use shall either be in place or shall be constructed in conjunction with the proposed use". Both studies conclude that the existing road is inadequate to deal with just existing traffic. The previously noted section of the zoning requires "improvements adequate to accommodate traffic generated", which the County does not have the capability of doing by itself. So, unless the applicant is willing to make improvements to the road, a finding that there are street improvements adequate to accommodate the traffic generated and provide safe, convenient access cannot be made. The applicant does note that they have participated in repair and maintenance activities previously, but there is not commitment to continue at least that type of agreement. (3) The applicant has reviewed the visual impacts of the mine and in summary noted that the primary visual impacts will be fairly minimal when driving by the mine site and from certain points on the Harvey Gap Reservoir dam embankment. Given the proposed small scale of the mine and associated facilities, the impacts to adjacent properties will be minimal in terms of visual impacts. Access points to the mine site and waste disposal areas are located in reasonable locations. The only signs proposed are those required by the State MLRB. 5 3.03.07 (1) (a) As noted previously, the applicant has filed a plan of augmentation for the necessary water rights. Enclosed in the application is a copy of an approved Colorado Wastewater Discharge Permit effective 7/1/92. (b) Eastside Coal has an approved Colorado Department of Health, Air Pollution Control Division, Emission Permits issued on 1/16/84 for coal processing; primary and secondary crushing and screening; underground coal mining operation; material handling, vehicle traffic emissions and other similar air emission sources. Also included in the application is a noise impact study done by Engineering Dynamics of Englewood that demonstrates that noise from the mine site and truck traffic from the mine will comply with state noise level limits. There are no identified sources of glare due to reflection from or lighting on the site. None of the mining activities will result in vibration off of the property. (c) The Colorado Division of Wildlife has reviewed the application and based on the proposal does not anticipate any additional impacts to wildlife in the area. (2) Truck traffic's physical impacts on County roads was reviewed previously. The average of five (5) round trips per say, Monday through Friday, are to be covered, minimizing the possibility of dust affecting properties along the haul route. The County Road and Bridge department has expressed some concerns about the traffic safety (See memo page 1, ). The Road and Bridge department's concerns are related to the physical narrowness of the road in one section and signage/stripping along the route. The traffic due to recreational use poses a potential safety concern. Silt officials have expressed concern about heavy truck traffic travelling through town, rather than going west on 6 & 24 to access the Interstate system. As noted previously, the trucks will not exceed any statutory noise limitations according to the applicant's consultant. The applicant has received an approval of the coal haul schedule date of June, 1991. Confirmation by the School District that this schedule is still valid, should be obtained prior to issuance of any permits. In general, hauling will be between 7:00 A.M. and 7:00 P.M., Monday through Friday. Emergency hauling may occur to three (3) times a quarter, with notification to the Planning Department in advance. If this is approved, notice should be given to the Road and Bridge department, not the Planning Department. (3) Automobile traffic due to employees and vendors, should not pose a problem, based on the relatively small scale of the mine. The mining operations nearest property line is 413 feet from the north property line. This is the property line that is contiguous with the Harvey Gap State Recreation area. The State Park Ranger has noted th t there will be visual impacts and potential traffic impacts (See letter page' , ). These issues have been addressed in previous comments. (4) Eastside Coal has a reclamation plan approved by the State Mined Land Reclamation Division, dated June 29, 1990, and with an expiration date of 6 January 13, 1995. This permit must remain valid for the life of any permit approved by the County. Included in the approval of the reclamation plan is a $49,000.00 bond for reclamation, that the State has determined is adequate. 5.03.08 (1) As noted previously, Engineering Dynamics of Englewood has concluded that Eastside Coal will comply with all County and State noise limits; (2) Eastside has indicated that there is no anticipated vibration that will be noticed on adjacent properties, due to any of their operations; (3) Eastside has air emission permits in place for all operations on the site requiring permits. No other operations are anticipated to cause smoke or particulate matter emissions; (4) No heat, glare, radiation or fumes are anticipated that will substantially interfere with the existing use of adjoining properties; (a) All explosives are stored in a concrete and steel storage' explosive magazine, with the appropriate permits in place from the Colorado Division of Mines. All other flammable liquids are stored in metal tanks; (5) (b) All outdoor storage oCfuel products is encircled by a concrete retaining wall or earthen berm two feet high to minimize any spill or leak. Given that the supply storage area is behind the bathhouse and office, there does not appear to be any purpose in requiring additional screening of these facilities; (c) Solid waste disposal from the mining operation will be disposed of in a waste disposal area approved as a part of the MLRB permit. The disposal area is located on the west side of the gap and will be visible for short periods of time from CR 237. MLRB requires drainage and dust control measures; (d) The coal storage area may constitute a fire hazard, but will be stored in compliance with the COH Emission permit and should not constitute a fire hazard; (e) The mining operation is required to comply with parameters established in the State Waste Water Discharge permit. There are monitoring requirements to ensure that water quality is maintained. There are additional sampling and monitoring requirements required by MLRB. 9.03.05 The application for the Special Use Permit is for the life of the mine and if deemed necessary, periodic reviews of compliance or noncompliance. At the last major special use permit for a coal mine (NCIG), the Board of County Commissioners imposed the following language as a part of a condition of approval: Once begun, any cessation of mining activity for a period of more than one (1) year shall be considered an invalidation of all land use permits and any resumption of mining activity shall require a new special use permit application. 7 For purposes of this Resolution, "mine activity" in terms of cessation of mine activity, means the mining of coal in excess of 10,000 tons per calendar year. "Mine activity" does not mean construction of surface facilities at the mine site nor does it mean the construction of the mine including, but not limited to, the completion of rock tunnels, the installation of mine ventilation equipment and other such mine development activities. It is suggested that a similar condition be imposed on any approval of this application. IV. SUGGESTED FINDINGS 1. That the public, meeting before the Planning Commission was extensive and complete, that all pertinent facts, matters and issues were submitted and that all parties were heard at the meeting. 2. That proposed special use conforms to the application requirements of Section 5.03.07 and 5.03.08 of the Garfield County Zoning Resolution of 1978, as amended. 3. That the proposed land use will be compatible with existing and permitted land uses in all directions if appropriate conditions are attached to the permit. 4. That for the above stated and other reasons, the proposed special use is consistent with the best interests of the health, safety, morals, convenience, order, prosperity and welfare of the citizens of Garfield County. V. RECOMMENDATION Unless the applicant can propose some method of mitigating the road impacts, the Planning Commission cannot make a determination that there are "street improvements adequate to accommodate traffic volume generated by the proposed use", therefore, the request should be denied. If improvements to the County road can be made, the following conditions should be included with an approval: (1) That all road improvements and safety improvements necessary to improve CR 227, CR 233, and CR 237 to provide a safe and convenient access to the mine be completed prior to issuance of a Special Use permit; (2) The applicant demonstrate that the existing individual sewage disposal system is properly sized to meet the needs of the mine or construct an ISDS that is approved by the County; (3) Prior to issuance of a Special Use permit, the applicant submit a letter from the RE -2 School District confirming the current school bus schedule; (4) That all proposals of the applicant shall be considered conditions of approval, unless specified otherwise by the Board of County Commissioners; 8 (5) Once begun, any cessation of mining activity for a period of more than one (1) year shall be considered an invalidation of all land use permits and any resumption of mining activity shall require a new special use permit application. For purposes of this Resolution, "mine activity" in terms of cessation of mine activity, means the mining of coal in excess of 10,000 tons per calendar year. "Mine activity" does not mean construction of surface facilities at the mine site nor does it mean the construction of the mine including, but not limited to, the completion of rock tunnels, the installation of mine ventilation equipment and other such mine development activities. 9 \ -1.=- c..S.---- \ ----- - „ ,P..- ___•.00 "--7;;..: • ••'Z'-',. r, ..1, • -'-- ... _1,- ;..... It 1,...o ,4!-- ,(..V Q 6863.• Z / y ‘7/ ..._-----'--- ///'''-•-______--------"V, i4eFra., 1., ttvrI'ji 1 ‘-------------L--77 -1".. li ,••• _ //, I - -Ni-/\-----:---::- - - ' — / e k-• • 1 )1.0) • • •\.• ,11? VICINITY MAP SCALE 1"= 2000' ••• ..... IU( ' ' • . , • x6860 60 k tj I. SKETCH PLAN LARSII SUBDIVISION 43- 0 M1i Si -ATE OF COLORADO Roy Romer, Governor DEPARTMENT OF NATURAL RESOURCES DIVISION OF WILDLIFE AN EQUAL OPPORTUNITY EMPLOYER Perry D. Olson, Director 6060 Broadway Denver, Colorado 80216 Telephone: (303) 297-1192 3-30-93 Garfield County Planning 109 8th St., Suite 303 Glenwood Springs, CO 81601 Dear Dave: -5'71 HC �: +f r,�,w` "'7„.„.i 1. it tNAR 3 f 1993 REFER TO OF For Wildlife - For People On 3-29-93 I inspected the Larsh Subdivision proposal. The property does not lie within any winter range designations for deer and elk but does lie adjacent to critical winter range and winter range across Highway 82 to the northeast and across the Roaring Fork River to the southwest. Wintering mule deer and elk will occasionally utilize the property as is evidenced by their droppings. The property contains valuable cottonwood riparian zone along the Roaring Fork River and lies north of a bald eagle nest site. These cottonwoods along the lower portion of the property are valuable wildlife habitat to a variety of species but are also very important as a screen between homesite development and the eagle nest and adjacent feeding and roost sites. It is important that this zone of cottonwoods be protected. The following will help minimize impacts to wildlife. Most of these recommendations emphasize measures which will minimize impacts to the bald eagles. 1. Maintain and preserve the cottonwood riparian zone (i.e.- no removal of cottonwoods, no livestock or horse grazing within this zone) 2. Homesites be constructed on the upper 1/2 of the lots with a 100 yard setback from the river bank and cottonwoods. This would also keep homes away from what appears to be some active sinkhole activity in the lower portions of the lot. 3. Limit dogs to 1 dog/home with dogs kenneled or chained. Kennel be constructed before C.O. is issued. 4. No construction activity from Feb. 15 - May 1 if eagles are present. This is less restrictive than Aspen/Glen due to this subdivision's distance and elevation from the eagle nest. 5. No public or private fishing on the Roaring Fork River, except float through traffic only, from Jan. 1 - May 15. Once eagles abandon or leave the area for the year fishing may continue. DEPARTMENT OF NATURAL RESOURCES, Kenneth Salazar, Executive Director WILDLIFE COMMISSION, William R. Hegberg, Member • Eldon W. Cooper, Member • Felix Chavez, Member • Rebecca L. Frank, Membf Louis F. Swift, Secretary • George VanDenBerg, Chairman • Arnold Salazar, Member • Thomas M. Eve, Vice Chairman In addition, if homeowners have livestock or horses, winter feeding will attract deer and elk causing game damage problems. In addition, it may also draw more animals across Highway 82 and increase animal/car collisions. To minimize this we recommend that homeowners be required to fence their stackyards with 8' game proof fencing. We can provide fence specifications upon request. Thank you for the opportunity to comment. If you have any questions, please feel free to give me a call. Kevin Wright District Wile Manager Carbondale ;j 1 1 0• 1 1 1 1 LOCATION MAP WESTBANK RANCH `,P.U.D.-FILING #4 SUBDIVISION:; SCALE: 1 inch = 2000 feel i JEROME GAMBA & ASSOCIATES, INC,` CONSULTING ENGINEERS & LAND SURVEYORS rTIPL.:1) .1.Nr-71 rAPh 0 8 1993 GARFIELD L OUN Y April 7, 1993 Dave Michaelson Garfield County Planning Dept. 109 8th Street, Suite 303 Glenwood Springs, Colorado 81601 Re: Westbank Ranch Wildfire Hazard Review FOREST SERVICE State Services Building 222 S. 6th Street, Room 416 Grand Junction, Colorado 81501 Telephone (303) 248-7325 Dear Mr. Michaelson, I have reviewed the Sketch Plan Report for the Westbank Ranch Filing IV Resubdivision, submitted by Jerome Gamba and Assoc., and visited the site on April 1st. When evaluating a site for wildfire hazard, I concentrate on vegetation, topography, water supply, and access. These points are addressed in the following comments. Vegetation in the proposed subdivision is primarily sagebrush and pinyon -juniper woodlands. The pinyon -juniper is generally located in and around drainages, with sage occurring in between. Topography consists of a series of gently sloping benches separated by steep hillsides; the area is cut by a series of drainages that create steep gullies flowing generally north. Slopes range from nearly level to 40%. The proposed subdivision is in an area that has been mapped as medium to high hazard for wildfire. The high rating is limited to the steeper ground of this parcel. Although fires in the pinyon - juniper type are common, they are usually confined to single trees or small groups of trees, and are generally easy to control. In sagebrush, fires are usually of low to moderate intensity and are likewise fairly easily controlled. Of primary concern in this proposed subdivision are the areas over 30% slope and the densely vegetated drainages. Under favorable burning conditions, a fire occurring in one of the steep gullies would intensify due to the "chimney" effect of the topography and slope. Structures located in or at the head of such drainages would be especially vulnerable to damage from wildfire. The applicant has stated that water supply for firefighting will be incorporated in the domestic water system. The CSFS standards for water supply recommend either hydrants every 1000 feet along roadways or cisterns with a 1000 gallon capacity for each dwelling unit. In regard to access, CSFS standards are for subdivisions to have dual ingress/egress points, which is not provided for in this proposal. Dual ingress/egress can be an important factor in providing safe evacuation in case of wildfire. In addition, it was noted that cul-de-sacs exceed the maximum 750 foot length as recommended in CSFS standards. Turnouts should be located every;' 750 feet along these cul-de-sacs to provide adequate emergency vehicle access. My specific recommendations to further mitigate wildfire hazard; for this proposed subdivision are: - Structures should not be located drainages. in or at the head of -Remove all vegetation within ten feet of all structures. This area should be maintained in the future as low groundcover such as mowed grass. - Brush or trees within 30 feet of homes should be thinned,' if necessary, so that remaining clumps are no more than 10 feet wide. This may be necessary on some lots, depending on exact locations of building envelopes. -Roof coverings should be of non-combustible materials. Shake -shingle roofs are a documented source of ignition in a wildland fire situation, and should be avoided. The above recommendations are covered in more detail in the CSFS publication "Wildfire Protection in the Wildland Urban Interface" which I have sent to Mr. Gamba with a copy of this letter. Thanks for the opportunity to review this proposal. Should you have any questions regarding the above comments, please call me at 248-7325. Sincerely, Kelly Rogers Asst. District Forester cc: Glenwood Springs FPD Jerome Gamba