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Permit Number: TD-DEV-0925-00238
Parcel: 132130490

Address:
1025 E BENSON HY

Review Status: Requires Resubmit

Review Details: DEVELOPMENT PACKAGE NEW v.5

Permit Number - TD-DEV-0925-00238
Review Name: DEVELOPMENT PACKAGE NEW v.5
Review Status: Requires Resubmit
Review Date Reviewer's Name Type of Review Description Status Comments
03/19/2026 External Reviewers - Pima County Addressing Standard REQUIRES RESUBMIT Review Report - Resubmittal Requested
Application Number: P25AD00866
Comment ID Comment Date Corrections
Needed
Page Ref Reviewer : Department Review Comments
DSD Addressing
9 03/19/262026 Yes 1025 East
Benson
Highway
Developmet
packet-SITE
PLAN
David Wilging : DSD Addressing The unit numbers would reflect the building and floor that they occupy, e.g.
1114, 2214, 3214
General Comments
Pima County Public Works
201 N. Stone Ave.
Tucson, AZ 85701
If you have any questions please call 520- 724-6490 for an appointment to discuss this notice. If following discussions with staff you still disagree with the below listed deficiencies,
you may appeal to the Building Official in accordance with Pima County Code 15.04.060 by submitting the form posted on our web site with payment of appeal fee prior to permit
application expiration. Disputes about the interpretation of the Zoning Code may be appealed to a Pima County Board of Adjustment under A.R.S. § 11 -816 and P.C.C. § 18.93.060.
Please submit all plans, calculations and specifications to us electronically via the Digital Projects page in the online portal.
Comment ID Comment Date Corrections
Needed
Page Ref Reviewer : Department Review Comments
10 03/19/262026 Yes 1025 East
Benson
Highway
Developmet
packet-SITE
PLAN
David Wilging : DSD Addressing Building One
11 03/19/262026 Yes 1025 East
Benson
Highway
Developmet
packet-SITE
PLAN
David Wilging : DSD Addressing Building Two
12 03/19/262026 Yes 1025 East
Benson
Highway
Developmet
packet-SITE
PLAN
David Wilging : DSD Addressing Building Three
13 03/19/262026 Yes 1025 East
Benson
Highway
Developmet
packet-SITE
PLAN
David Wilging : DSD Addressing Building Four
14 03/19/262026 Yes 1025 East
Benson
Highway
Developmet
packet-SITE
PLAN
David Wilging : DSD Addressing Building Five
15 03/19/262026 Yes 1025 East
Benson
Highway
Developmet
packet-SITE
PLAN
David Wilging : DSD Addressing 1015 E Benson HY
16 03/19/262026 Yes 1025 East
Benson
Highway
Developmet
packet-SITE
PLAN
David Wilging : DSD Addressing 1025 E Benson HY
17 03/19/262026 Yes 1025 East
Benson
Highway
Developmet
packet-SITE
PLAN
David Wilging : DSD Addressing 1013 E Benson HY will be retired upon plan approval
Re-Submittal Procedures
Please submit all documents using Citizen Access at permits.pima.gov (i.e. plans, drawings, calculations, quantities, exhibits, photographs, letters, etc.).
1. Please go to permits.pima.gov and login to your account to access review comments and resubmit.
2. If you have questions or need clarification regarding comments, please contact the reviewer.
3. Provide a response to each correction comment.
4. To resubmit, upload revised full plan set.
Should the resubmittal not completely address this request for corrections, the application maybe denied requiring a new application and payment all applicable
review fees in accordance withA.R.S. § 11-1605
03/20/2026 Site Engineering Standard REQUIRES RESUBMIT Permit Activity Number: TD-DEV-0925-00238 (5th Review)
Project: Building: North Building: convert (E) MOTEL into MULTI FAMILY APARTMENTS/ add new electric stove kitchen sink, fridge & counters.
Location: 1025 E BENSON HY
Review Date: 3/20/2026
Reviewers: Marco Contreras – Engineering Associate - Site Engineering & Joe Macaulay – Civil Engineer
Related Cases: TC-RES-0126-00379, TC-RES-0126-00378, TE-FPU-0126-00016
*This plan has been reviewed for compliance with applicable development criteria in the City of Tucson Unified Development Code (UDC) Administrative Manual (AM) Section 2-6 and Technical Standards Manual (TSM) Section for waste management, Pedestrian Access, Hydrology -Retention/Detention Requirements, and all site standard code. *
City of Tucson Code: https://www.tucsonaz.gov/Departments/Planning-Development-Services/Codes
Floodplain Code: https://codelibrary.amlegal.com/codes/tucson/latest/tucson_az/0-0-0-19333
Drainage Manual Link: https://www.tucsonaz.gov/files/sharedassets/public/v/1/pdsd/documents/engineering-code/cot-drainage-manual-searchable.pdf
Design standards for Stormwater Detention and Retention Link:
https://www.tucsonaz.gov/files/sharedassets/public/v/1/pdsd/documents/engineering-code/updated-retention-detention-manual.pdf
Site Engineering Review Comments:
1. Previous comments #2, 2a, & 3. have not been addressed in compliance with all referenced code. I will provide further details in regard to how these comments will need to be addressed for Site Engineering approval for TD-DEV-0925-00238.
a. As this is a proposed change of use from "Commercial Services Use Group - Traveler's Accommodation (Lodging)" to "Residential Land Use Group - Multifamily Development", the site will need to meet full compliance with all development standards as articulated in Article 7 of the UDC.
b. As such, demonstrate established pedestrian connectivity to all ADA parking spaces. The connectivity will be in compliance with TSM 7-01.3.3. The ADA space on the southeast corner of the site will be required to be moved to a properly established position where direct pedestrian connectivity can be achieved. Simply showing a “Pathway” will not be sufficient as it demonstrates a pedestrian potentially walking alongside an unprotected PAAL in direct conflict with TSM 7-01.4.2 & 7-01.4.1.B. This would simply be accomplished by shifting the ADA space up till is matches up with an area for a potentially established/delineated crosswalk so as to connect to the rest of the site.
c. In compliance with TSM 7-01.4.1.A. Demonstrate how connectivity is achieved for connecting to the established sidewalk that runs along Benson HWY ROW. This would need to be an established pathway which falls in compliance with TSM 7-01.4.3.
d. As the trash enclosure is newly proposed with this Development (Existing appears to simply be a single enclosure vs proposed), it is required that the trash enclosures be connected to the site with an established connection such as a striped cross walk. As the current position appears to carry some constraints, it’d be advisable to consider hatching the southern adjoining parking space and establishing a crosswalk that crosses the PAAL diagonal from the current ramp shown.

If you have any questions or concerns, please contact Marco Contreras at Marco.contreras@tucsonaz.gov or Joe Macaulay at Joe.Macaulay@tucsonaz.gov
04/13/2026 Site Landscape Standard REQUIRES RESUBMIT PLANNING AND DEVELOPMENT SERVICES DEPARTMENT
REVIEWER: CHAD KELLER, RLA
SITE LANDSCAPE/NATIVE PLANT PRESERVATION SECTION

PROJECT: CONVERT (E) MOTEL INTO MULTIFAMILY APARTMENTS; CHANGE OF USE
ACTIVITY NO: TD-DEV-0925-00238
ADDRESS: 1025 E BENSON HY
ZONING: C-2 COMMERCIAL ZONE
LAND USE: CHANGE OF USE/COMMERCIAL/UPDATE TO CURRENT SITE LANDSCAPE CODE REQUIREMENTS
REVIEW #3
2026.04.13

THE PROPOSED PLANS HAVE BEEN REVIEWED FOR COMPLIANCE WITH APPLICABLE DEVELOPMENT STANDARDS PER THE CITY OF TUCSON UNIFIED DEVELOPMENT CODE (UDC), TECHNICAL STANDARDS MANUAL (TSM), AND ADMINISTRATIVE MANUAL (AM) FOR SITE LANDSCAPE, NATIVE PLANTS, AND RAINWATER HARVESTING.

RESUBMIT REVISED DRAWINGS ALONG WITH A DETAILED RESPONSE LETTER, STATING HOW ALL OF THE SITE LANDSCAPE AND NPPO SECTION REVIEW COMMENTS HAVE BEEN ADDRESSED.

SITE LANDSCAPE/NPPO SECTION COMMENTS:

1. UDC 7.6.4.B Vehicular Use Areas
The standards in this Section 7.6.4.B apply to all developments that provide more than four motor vehicle parking spaces, except as provided in Section 7.6.4.B.1.c, Exemptions.
1. Canopy Trees in Vehicular Use Areas
a. General Standards
Within a vehicle use area, one canopy tree is required for each four motor vehicle parking spaces or fraction thereof.
(1) The canopy trees must be evenly distributed throughout the vehicular use area. Every parking space must be located within 40 feet of the trunk of a canopy tree (as measured from the center of the tree trunk).
(2) Fifty percent of the trees required for landscape borders located within ten feet of the paved portion(s) of a vehicular use area may be counted towards both the minimum parking lot canopy tree standard and the landscape border canopy tree standard.
(3) An unpaved planting area, which must be a minimum of 34 square feet in area and four feet in width, must be provided for each canopy tree.
**(4) IN DEVELOPMENT WHERE IT IS NECESSARY TO BRING THE EXISTING VEHICULAR USE AREAS INTO CONFORMANCE WITH THESE REGULATIONS, GAPS ARE ALLOWED IN THE TREE COVERAGE REQUIREMENT OF EVEN DISTRIBUTION, PROVIDED THAT AT LEAST THE MINIMUM REQUIRED NUMBER OF TREES IS PLACED WITHIN OR ADJACENT TO THE VEHICULAR USE AREA WITH COVERAGE WHICH IS AS UNIFORM AS POSSIBLE. CANOPY TREES ADJACENT TO THE VEHICULAR USE AREA MAY COUNT TOWARD MEETING THIS REQUIREMENT, PROVIDED THE TREES MEET THE CRITERIA LISTED IN SECTION 7.6.4.B.1.A (1).

2. Include calculations for parking lot trees required and provided. There are approximately 234 parking spaces provided/4 equals 58.5 or 59 trees required specifically for the parking area.

3. Overall, please coordinate the existing and proposed plants so that it is abundantly clear what will be newly planted on site.

4. Drafting standards: Existing plants should be shown as medium to light gray and should be a dashed symbols. Proposed should be a solid line type. The initials of the plant/tree at their center point help, but it is still a bit difficult to review.

5. At the east side of the main buildings, the mature width of the Mesquite trees will be too wide for the space. This will cause maintenance and tree health issues. Either add a few planter islands within the parking space area or choose a different smaller tree variety for the current space. Examples: Desert Willow, Fruitless Olive, Texas Ebony. There are many other native Sonoran Desert trees that will fit in this area. If more example tree varieties are needed to help compile the plans, please reach out and I will provide additional.

6. The west building has a symbol with the letters (OLE). OLE is not represented in the legends. Identify OLE on the plans.

7. On the tree planting standard detail, show a 4-to-6-inch depression around the tree at a 4-foot radius around the tree trunk.

8. Clearly define the location of the existing meter, point of connection, existing water line and valve locations. There are several locations where the point of connection is shown to existing buildings with no drip valve included. **AGAIN, IF AN EXAMPLE IRRIGATION PLAN IS NEEDED TO SHOW POINT OF CONNECTION TO AN EXISTING SYSTEM WITH BACKFLOW AND VALVES, PLEASE LET ME KNOW AND WE WILL PROVIDE A COPY.

9. If an example of an approved landscape plan set is needed to aid in the compilation of your plans would be helpful, please let me know and I will email a copy for your reference.

10. With the above comments in mind and the overall site requirement for parking lot shade trees meeting full code compliance of 1 tree per 4 parking spaces, a Board of Adjustment Variance may need to be pursued to gain relief from the parking lot shade tree requirement. Please reach out to Mark Castro or Georgia Pennington with PDSD for more information on the Variance process. Mark.Castro@tucsonaz.gov – Georgia.Pennington@tucsonaz.gov

11. **There are Saguaro cacti visibly present on site where new plant material and irrigation is proposed for implementation. Protected native plants will likely not be disturbed with these updates and improvements. A NPPO Waiver is required for all sites where work is being completed and protected native plants are present. A Sonoran Desert, native, arid plant professional is required to verify if native plants are present on site. Please consult a native plant professional for this proposed work. See UDC 7.7.4.D. Professional Expertise: Preparation of all elements of the Native Plant Preservation Plan and on-site monitoring as required under Section 7.7.5.C.5, On- Site Monitoring, must be performed by a plant professional, such as: 1. An arborist certified by the International Society of Arboriculture; 2. A landscape architect; or, 3. A horticulturist, biologist, or botanist with a minimum B.A. or B.S. in an appropriate arid environment natural resource field.

**This is for record keeping only. A link to the fillable NPPO Waiver is attached below.

https://www.tucsonaz.gov/files/sharedassets/public/v/1/pdsd/documents/applicationsforms/nppoapp-2025-v.2-fillable-1.pdf

PREVIOUS COMMENTS NOT COMPLETED:

12. Include container gallon size for the proposed plants. The requirement per the Administrative Manual is 15 gallons for trees, 5 gallons for shrubs and 1 gallon for groundcovers. **2” CALIPER IS OK, BUT THE CITY OF TUCSON REQUIRES A GALLON SIZE CALLOUT. REMOVE THE CALIPER AND INCLUDE THE 15 GALLON MINIMUM FOR TREES.

13. **THE TOTAL EXISTING PARKING AREA SF AND TOTAL LANDSCAPE AREA SF IS NOT HOW THE PARKING LOT TREES ARE CALCULATED. PROVIDE THE 1 TO 4 RATIO CALCULATION FOR PARKING LOT TREES. INCLUDE THE REQUIRED AND PROVIDED. -- PREVIOUS COMMENT: “There are plants existing on site. The existing plants can count toward the overall requirement for plant material on site. Provide the required and provided calculations for landscape borders and parking lot trees. Street landscape borders are 10 feet wide and require 1 tree per 33 linear feet of frontage excluding the entry and exit points. Of that 10-foot landscape border 50 percent must include 50 percent coverage with vegetative ground cover, IE: shrubs, accents, cacti, groundcovers, etc. Parking lot trees are required at a rate of 1 tree per 4 parking spaces to bring the site up to current code requirements. If an example of approved site landscape compliance plans is needed, please reach out and I will provide a copy for your reference.”

14. **Include a irrigation details sheet or show the details on the irrigation sheet. Example details for your use can be found at the following link: https://www.tucsonaz.gov/Departments/Transportation-Mobility/Landscape/Landscape-Architects

15. At the following link you will find approved site landscape planting and irrigation details that can be used on your plans as you work toward an approvable set of site landscape plans. https://www.tucsonaz.gov/Departments/Transportation-Mobility/Landscape/Landscape-Architects

Thank you.
Chad Keller, RLA
Landscape Architect
chad.keller@tucsonaz.gov
04/08/2026 Site Zoning Standard REQUIRES RESUBMIT None of the Site Zoning comments from the previous review appear to have been addressed. They are provided again below:

1. COMMENT: The parking calculations table is incorrect. Per UDC Table 7.4.4-1, parking for studios less than 400 sf is 1/DU and for more than 400 sf is 1.5/DU.

2. COMMENT: Confirm parking space dimensions. Parking spaces are shown in some areas to be less than the minimum required 8.5’ x 18’ dimension. If parking space dimensions are less than the requirement, a Parking Design Modification Request (PDMR) may be submitted to request modification of this standard. Email Site Engineering Section Lead, Stephen Blood, at stephen.blood@tucsonaz.gov for a copy of the application. The PDMR is an internal review process and would be conducted concurrently with the next review cycle(s).

3. COMMENT: Confirm width of parking area access lanes (PAAL). The minimum one-way PAAL width is 12’; the minimum two-way PAAL width is 24’. A PDMR may also be submitted to request modification of the minimum PAAL width requirement as stated in Comment 2.

4. COMMENT: No separate is shown between the parking spaces along the western property line and the landscaped area. Six-inch vertical separation is required; wheel stop curbing may be provided per UDC 7.4.6.H.

5. COMMENT: The minimum distance between a wheel stop and signage is incorrect on Sheet A-8. Per UDC 7.4.6.H.3, wheel stop curbing must be a minimum of 2.5' from the front of the parking space.

6. COMMENT: Dimension and label existing or proposed signage. Provide a note that all signage will be per separate permit.

7. COMMENT: Per aerial imagery, the location of the proposed short-term bicycle parking area appears to interrupt existing sidewalk paths. Confirm location and clearly indicate that the minimum required sidewalk width will not be obstructed by the bicycle parking.

8. COMMENT: The bicycle parking detail on Sheet A-8 is incorrect. Per UDC 7.4.9.B.2, "Each required short-term bicycle parking space must be at least two feet by six feet". Only 10" are shown.

9. COMMENT: Provide a note indicating where long-term bicycle parking will be provided. If they will be inside every unit, provide a note indicating so. These locations will be confirmed during review of the building permits.

10. COMMENT: Provide an electric vehicle supply equipment (evse) calculation per UDC Table 7.4.11-1 and show these spaces on the site plan.

For multifamily development, 10% of provided spaces must be EV Ready and 20% must be EV Capable. See section for definitions of each.

11. COMMENT: On sheet 1 provide a general note indicating the zoning use as shown in the redline.

12. COMMENT: Overhead imagery shows existing striping in parking areas that is not indicated on the plans. If it still exists, please show.

13. COMMENT: Show pedestrian connectivity from the ADA parking spaces to the building. None is currently shown. Also show pedestrian connectivity from the building to the street frontage. None is shown.

Contact Fernando Garcia, Lead Planner, Site Zoning at fernando.garcia2@tucsonaz.gov.
03/31/2026 External Reviewers - Tucson Electric Power (TEP) Standard REVIEW COMPLETED March 30, 2026
WO#T171504
City of Tucson
Planning and Development Services
Attn: CDRC Admin Team
Dear CDRC Admin Team
Subject: CONVERT (E) MOTEL INTO MULTI FAMILY APARTMENTS
TD-DEV-0925-00238
Tucson Electric Power Company (TEP) has reviewed and approved the development
plan submitted 3/19/2026. There are existing facilities within the development which are
depicted upon the plan. There are no apparent conflicts at this time.
Enclosed is a copy of a TEP facilities map showing the approximate location of the
existing facilities. Any relocation costs will be billable to the customer.
To apply for electric service, please call the New Construction department at (520) 918-
8300. Please submit a final set of plans including approved site, electric load, paving
off-site improvements and irrigation plans. If available, include a PDF version of the
plans.
If easements are required, they will be secured by separate instrument. Should you
have any easement questions, please contact our Land Resources Department,
LandReviews@tep.com.
Should you have any technical questions, please contact the area designer,
Fred Quintero
(520) 235-6329
fquintero@tep.com
Sincerely,
Design Admins
Design Admins
Tucson Electric Power