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HomeMy WebLinkAbout1.20 Completeness Response Letter 12.22.2023 345 COLORADO AVE. SUITE 106 | CARBONDALE, COLORADO 81623 | 970.379.4155 Page 1 of 8 December 22, 2023 Glenn Hartmann, Community Development Director Garfield County 108 8th Street, Suite 401 Glenwood Springs, Colorado 81601 Via email: ghartmann@garfield-county.com RE: Spring Valley Ranch: Responses to Completeness Review Comments for PUD Amendment Application (File No. SPFA-02-22-8881) Dear Glenn, Thank you for your letter dated October 25, 2023, which provided the County’s completeness review comments for the above-referenced application. We appreciate your valued time in the review of this project. The County’s comments are copied below, followed by the Applicant’s responses in blue. County Comments & Responses: 1. Please ensure the Authorization Letters and Statement of Authorities are properly documented. In particular the Attorney’s Office noted concerns with the Parcels (missing or incorrect references) included in the 12/7/22 Martin Van Ardenne letter. In addition, the Attorney’s Office requested clarification on Mark Enderle’s authorization to sign the Application. Response: The letter of consent signed by Martin Van Ardenne, representing Spring Valley Holdings, LLC, has been updated as to the parcel numbers and to provide authorization to Mark Enderle of Storied Development, LLC. The updated letter dated November 7, 2023, is included in the Application Forms & Consent Letters in Appendix A. 2. Phasing including for off-site improvements needs to include more specific timing and dates. Delaying traffic improvements to later phases while generating immediate traffic impacts is an issue that needs to be addressed in the submittals. Response: The phasing for off-site improvements has been revised, partly based on prior conversations with Staff. The revised Phasing Plan is included as Exhibit 2 of the Development Agreement in Appendix G. The Phasing Plan now prioritizes improvements to the intersection of State Highway 82 and County Road 114, while also re-segmenting the road improvements for 345 COLORADO AVE. SUITE 106 | CARBONDALE, COLORADO 81623 | 970.379.4155 Page 2 of 8 County Roads 114 and 115 such that each road segment may be completed in one construction season. 3. Traffic Study needs to clarify and summarize specific impacts and improvements required, including intersection improvements – per Chris Hales comments. Clarification on queuing lengths and coordination/timing of improvement with other projects needs to be addressed. Response: The recommendations for intersection improvements were provided in Section 5.1, Auxiliary Turn Lanes, in the Transportation Impact Study in Appendix H. The need for auxiliary turn lanes was assessed per State of Colorado State Highway Access Code standards. Section 5.1 provides a detailed analysis of each subject intersection, including whether specific intersection improvements are warranted based on either existing conditions, or by the addition of the project- generated traffic. The intersection of State Highway 82 and County Road 114 has many improvements that are warranted by existing conditions. Figure 10 of The Transportation Impact Study provides a graphic illustration of the warranted intersection improvements based on both current conditions and project-generated traffic. Additionally, signal timing recommendations are also detailed in this section. A detailed lane configuration plan for the SH 82/ CR 114 intersection is provided as Sheet 8 of the Schematic Engineering Plans in Appendix L. Any required improvements to this intersection will ultimately be determined upon CDOT’s review and will be conditioned upon the issuance of a CDOT Access Permit. The Applicant intends to apply for a CDOT Access Permit concurrently with the application for Preliminary Plan for subdivision. Please also see the response to comment #2 above, which addresses the phasing of off-site improvements. 4. Traffic Study needs to provide assessment of traffic impacts if County Road 115 is closed – per Dan Cokely comments. Response: This analysis regarding the potential closure of County Road 115 has been provided in a supplemental letter from McDowell Engineering dated December 20, 2023, and included in Appendix H (Transportation Impact Study). 5. Chris Hale, Consulting Engineer commented on the following topics. The Application needs to respond to his issues or identify how they will be addressed in the future: a. Winter Recreation Facilities and other permits and approvals required. Response: Section 6.2 of the PUD Guide in Appendix K includes land use allowances for Winter Recreation, Passenger Tramways, and Snowmaking in certain Zone Districts. These uses are defined in Section 9 of the PUD Guide as follows: 345 COLORADO AVE. SUITE 106 | CARBONDALE, COLORADO 81623 | 970.379.4155 Page 3 of 8 Winter Recreation: Winter season and over the snow recreational activities, including but not limited to cross-country skiing, snow biking, ice skating, tubing, downhill skiing, and the operation of Snowmaking, Passenger Tramways and associated facilities and structures. Passenger Tramway: An aerial tramway, surface lift, tow, or conveyor used to transport passengers. Snowmaking: The installation and operation of equipment and utility extensions for making and storing snow. Of the above-defined uses, only Passenger Tramways require approvals from an entity other than Garfield County. Any Passenger Tramway is required to be designed, operated, and maintained according to Colorado Passenger Tramway Safety Board (CPTSB) standards. The CPTSB will require that any Passenger Tramway located on Spring Valley Ranch be approved and licensed. b. Drainage report information on post development conditions. Response: The Garfield County Land Use & Development Code (the “LUDC”) identifies the submittal requirements for a Substantial Modification to a PUD in Table 6-301. Among the required submittal items is a Floodplain Analysis. The Spring Valley Ranch property does not have any FEMA-mapped floodplains, therefore, based on discussions with Planning Staff, we alternatively provided an Existing Drainage & Flood Hazard Report in Appendix I of the application. This report provides a thorough analysis of existing drainage basins, 100-year runoff volumes, and potential flood events along Landis Creek. Post-development drainage plans and reports are not required for a PUD Amendment, but rather are more appropriately required during Preliminary Plan when engineering design occurs. In accordance with Table 5-401 of the LUDC, the Applicant will provide the required Grading and Drainage Plans at the time of Preliminary Plan review for subdivision. c. Drainage report on preliminary/conceptual plans and location for future detention. Response: Please see the response to comment 5.b above. d. Will serve letter on gas service. Response: A commitment to serve letter for gas service has been provided by Black Hills Energy and is located in the District & Utility Service Letters in Appendix M. 345 COLORADO AVE. SUITE 106 | CARBONDALE, COLORADO 81623 | 970.379.4155 Page 4 of 8 e. Addition of details on slope analysis and identification of steep slopes. (slope analysis included in the Tab Q, Wildfire Mitigation Report needs to be enhanced and currently shows a significant number of lots in areas with 30% or greater slopes) Response: A Slope Analysis Exhibit has been prepared and provided as Sheet 7 of the Schematic Engineering Plans in Appendix L. Slopes have been categorized from 0-19.99%, 20-29.99%, and 30%+. These categories are consistent with the Slope Development thresholds of 20% and 30% as identified in Article 7-207.F of the LUDC. While the vast majority of lots in the conceptual layout are shown to contain suitable building areas that are less than 20% slope, it is acknowledged that the conceptual plan and lot layout may contain some lots and road alignments that may be reconsidered due to the presence of steep slopes. With that understanding, it is important to recognize that this lot plan is conceptual in nature, and any such slope issues will be revisited prior to the submission of Preliminary Plan for subdivision. f. Additional geo-hazard analysis on avalanche hazard. Response: A supplemental letter dated 12/14/23 from CTL Thompson has been added to the Geologic Evaluation (Appendix N) and includes a discussion on potential avalanche hazards. g. Additional details on water system to address technical issues including tank storage locations and volumes. Response: In the Water Supply & Distribution Plan (Appendix P) Section 1.1, the background for how the distribution pipe sizing is explained in detail. Further detail regarding the parameters under which the model was run are included in Section 1.5. To reiterate as stated in Section 1.1, the distribution pipe is sized to ensure a minimum of 50 psi is provided to each lot under peak hourly demand conditions, and that fire-flow (1500 GPM @ 20 psi) can be achieved at each hydrant. Infowater Pro is a GIS based hydraulic modeling software which iteratively solves for a host of parameters, most notably in this case pressure and flow. The model was used to simulate the entire water system and includes all hydrants and service lines. The modeling software provides the ability to check the project required fire-flow at each hydrant, and domestic pressure at each home to ensure compliance with CDPHE design criteria, and the International Fire Code as described in Sections 1.5, and 1.6 of the repor t in Appendix P. In Sections 1.5 and 1.6, it is stated that the defined flow and pressure constraints include 1500 gpm at 20 psi at each hydrant to meet Fire Flow, and 50 psi during peak hourly demand at each domestic tap. The 50 psi model constraints exceed the 35 psi CDPHE minimum required working pressure during peak hourly demand. In Table 4 of Section 1.5 of the Water Supply & Distribution Plan, the two limiting hydrants for each pressure zone are summarized. The lower area of the subdivision has a hydrant located in 345 COLORADO AVE. SUITE 106 | CARBONDALE, COLORADO 81623 | 970.379.4155 Page 5 of 8 Phase 5 which at 1,500 GPM will result in 35 psi of pressure. This is the lowest residual pressure hydrant in all of the lower zone and would be considered the limiting hydrant. This hydrant exceeds the minimum required pressure by 15 psi. In the upper zone the limiting hydrant is in Phase 4, with a pressure of 30 psi. This exceeds the minimum required fire-flow pressure by 10 psi. As these are the two lowest residual pressure hydrants, all others far exceed the minimum 20 psi at 1500 gpm requirement. These hydrants are labeled in Appendix L, Schematic Engineering Plans on the water system Sheet 2. A table for each of the 260 hydrants was not included since all residual pressures exceed the two limiting hydrants listed in Table 4. Using Infowater Pro, all line sizes and fire-flows are verified. Detailed tank volume calculations are described in Section 1.4 of the Water Supply & Distribution Plan in Appendix P, which outlines the required domestic storage, fire storage, and often overlooked dead storage within a tank. The upper tank location is located near a proposed ski lift and will be buried among other major infrastructure. Due to the location next to other major infrastructure, access is available for both construction and maintenance. The tank locations were chosen to ensure proper pressurization of the system, while weighing constructability and access. Both tanks were sited in the Infowater Pro model and provide adequate flow to meet fire-flow and domestic demands. Given the required pressure within the upper zone, the ability to construct two tanks or utilize an alternative location is extremely limited. As such, the design engineers on this project are strongly considering a dual compartment tank, which allows for the tank to remain online as one half is repaired and vice versa. Additionally, if a dual compartment is not pursued the community can utilize a temporary pressurized tank to provide water to the residents during a tank maintenance event. Given that the proposed tanks are concrete, major maintenance which will require the tank to be offline will occur roughly every 15 years. At this infrequent interval, temporary tanks or dual compartment tanks will meet every need of the community. Therefore, no additional tanks or sites are being evaluated. 6. Dan Cokely, consulting engineer technical comments on Traffic Study including adjustments to trip reduction assumptions needs to be addressed. Response: McDowell Engineering conducted a conference call with Dan Cokley to review this comment. During that call, the methodology and trip reductions were discussed and explained to Dan. McDowell Engineering also discussed that we had sent this methodology to CDOT (per the Transportation Impact Study Appendix) that identified the trip reduction and that CDOT was agreeable to the method. Therefore, Dan felt comfortable with the methods utilized in the Transportation Impact Study. 7. Additional information on the Metro District status, mergers, and potential 1041 issues. This should include status of any updates to the Service Plans. 345 COLORADO AVE. SUITE 106 | CARBONDALE, COLORADO 81623 | 970.379.4155 Page 6 of 8 Response: The proposed project is not subject to a separate 1041 review (Activity of State Interest) per LUDC Article 14-105.B.3, in which the following activities are exempted: Municipal and Industrial Water/ Wastewater Projects or Domestic Water and Wastewater systems that were or will be reviewed and approved by the County as part of a Land Use Change Permit, subdivision, or PUD application that addresses the impacts of the project. The Landis Creek Metropolitan District Nos. 1 & 2 Service Plan was executed in 2001 and needs updating. The Applicant intends to submit an Amended & Restated Consolidated Service Plan for the Landis Creek Metropolitan District No. 1 and District No. 2 to the BOCC. Changes to the Service Plan are needed to account for the changes being proposed to the Spring Valley Ranch PUD plan and the increase in construction costs since the original Service Plan was approved. Topics to be addressed in the Amended & Restated Service Plan include raising the maximum indebtedness of the Districts, removing mill levy limits for debt service to give the Districts more flexibility in how they allocate the existing maximum mill levy of 50 mills, updating the financial and engineering plans for the Districts, updating services provided and service fees charged by the Districts, and adjusting District boundaries to align with the planning areas of the amended PUD plan. 8. Copies of the existing Master Covenants that are referenced in the Application need to be provided. Response: The Master Declaration of Covenants, Conditions and Restrictions, recorded on 10/21/2020 at Reception No. 793245, are provided in Appendix S. 9. CTL Thompson – Geo-Tech report needs to more clearly delineate areas with high hazards including an overlay with PUD Plan Map to demonstrate how the amended PUD Plan addresses identified hazards. Response: A supplemental letter dated 12/14/23 from CTL Thompson has been added to the Geologic Evaluation (Appendix N) and includes two new figures (Fig. 1 and Fig. 2) that depict the potential geologic hazard types overlain on the PUD Plan Map, as requested. 10. Fire Station improvements need more details including special district capabilities to implement the operations and address the Fire Protection District comments. Response: Additional discussion regarding the fire protection plan has been included in Section 7.11.2 (page 49) of the Narrative Report, including the intent of the Applicant to engage in a contract between the Landis Creek Metropolitan District and either the Glenwood Springs Fire Department or Carbondale & Rural Fire Protection District for the provision of fire protection and EMS services within Spring Valley Ranch. 11. A summary assessment/compilation of wildfire hazards or combined hazard mapping needs to be provided. Please correct the reference to Figure 27 for lots needing special treatment. References 345 COLORADO AVE. SUITE 106 | CARBONDALE, COLORADO 81623 | 970.379.4155 Page 7 of 8 to the International Wildland Urban Interface Code (IWUIC) should be clarified or include copies of the Code. Evacuation planning needs to be further addressed including the potential for modelling and additional details on sheltering on site. Response: The Wildfire Mitigation Report in Appendix Q has been updated, and all references to Figures have been addressed. A discussion on Post-Treatment Hazard Conditions has been added starting on page 44. The proposed mitigation in this plan was designed with a wholistic approach with life safety being the first consideration, property conservation second and incident stabilization the third goal. It would not be appropriate to state a quantifiable reduction in hazard, post plan implementation, as many elements of the plan do not have, as of yet, a scientifically supported and quantifiable definition of the mitigating effects post treatment. For instance, there are no accepted and clear definitions of the reduction in hazard (low, moderate, high, very high) if a home has conducted home hardening techniques and defensible space. Each mitigation technique proposed in this plan are known and accepted techniques for reducing structure loss and enhancing life safety, they are complementary to each other, having a synergistic effect. However, it is not possible to quantify an objective reduction in overall hazard and risk. Garfield County has not adopted the International Wildland-Urban Interface Code (IWUIC); however, the Wildfire Mitigation Report relies upon certain prescriptions from that Code. If compliance with the Wildfire Mitigation Report is included as a condition of approval of the PUD Amendment, then compliance with that Report and its associated components of the IWUIC would be enforceable by the County. The Wildfire Mitigation Report has been updated to include a discussion on evacuation planning, starting on page 34. The Report recommends implementing the International Association of Fire Chiefs “Ready, Set, Go!” program, which supports developing and improving dialogue between the fire service and the residents they serve. The program helps departments teach individuals who live in high-risk wildland fire areas and the WUI how to best prepare themselves, their families, and their properties against outdoor fire threats. 12. PUD Guide Section 7.7 Slope Development needs to be clarified to address County Standard for slopes greater than 20% requiring engineering and slopes 30% or greater permitted only where they cannot be avoided. Studies or further documentation to support deviation from Code Standards is needed. Response: Section 7.7 (Slope Development Standards) of the PUD Guide (Appendix K) has been revised to be consistent with the LUDC in establishing criteria for the development of slopes at thresholds of 20% or greater and 30% or greater. The Applicant has chosen to memorialize these slope development standards in the PUD Guide to maintain consistency for development within the PUD in the event that the LUDC standards change in the future. 345 COLORADO AVE. SUITE 106 | CARBONDALE, COLORADO 81623 | 970.379.4155 Page 8 of 8 We appreciate the opportunity to respond and provide this information to the County, and we look forward to advancing the Spring Valley Ranch PUD Amendment in the referral review process. Thank you for your valued time and commitment to this application review. Sincerely, LANDWEST Jon Fredericks Principal cc: Jeff Butterworth, Storied Development Mark Enderle, Storied Development Lisa Reynolds, Storied Development Mark Yarborough, Storied Development Martin Van Ardenne, Spring Valley Holdings Bart Johnson, Waas Campbell Rivera Johnson & Velasquez LLP Jody Edwards, Klein Coté Edwards Citron LLC