HomeMy WebLinkAbout1.20 Completeness Response Letter 12.22.2023
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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
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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:
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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.
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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
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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.
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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
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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.
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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