Microfiche records prior to 2006 have not been completely digitized and may not be available yet on PRO. If you cannot find what you are looking for please submit a records request.

Permit Review Detail

Permit Number: TD-DEV-1025-00259
Parcel: 11901046C

Address:
314 E BENSON HY

Review Status: Requires Resubmit

Review Details: DEVELOPMENT PACKAGE NEW v.2

Permit Number - TD-DEV-1025-00259
Review Name: DEVELOPMENT PACKAGE NEW v.2
Review Status: Requires Resubmit
Review Date Reviewer's Name Type of Review Description Status Comments
04/10/2026 NPPO Standard NOT REQUIRED
04/06/2026 Commercial Plumbing Standard REQUIRES RESUBMIT ACTIVITY NO. TD-DEV-1025-00259
ADDRESS/PARCEL: (314 E BENSON HY TUCSON, AZ 85713
Submit your revised drawings along with a detailed response letter, which states how all comments were addressed. Review will not proceed without the response letter. The submitted documents were incomplete and a thorough plan review could not be performed. Please be aware, new comments may arise with the next review.

If you have any questions about these review comments, I can be reached at Sean.Severson@tucsonaz.gov

1. Does wastewater flow exceed 3,000 GPD?
a. If flows exceed 3,000 GPD, the sewer system shall be reviewed and approved by PDEQ per Arizona Administrative Code, Title 18, Chapter 9.
2. Revise the site plan to include the existing utility information required by the City of Tucson Administrative Manual, Section 2-06.4.8D and Section 107.2.1, IBC 2024:
a. The size of both the existing water meter and the reduced pressure backflow preventer assembly.
b. The location and size of sanitary and storm sewers, including the pipe diameter and the invert and rim elevations of all manholes and cleanouts; along with the Pima County Wastewater Management Department (PCWMD) reference number.
c. The points of connection to existing public sewers.
3. Revise the utility notes section to identify the correct applicable codes. The project shall reference the 2024 I-Codes (IBC, IMC, IPC, etc.), as adopted and amended by the City of Tucson.
03/17/2026 External Reviewers - Pima County Addressing Standard REQUIRES RESUBMIT Review Report - Resubmittal Requested
Application Number: P26AD00221
Comment ID Comment Date Corrections
Needed
Page Ref Reviewer : Department Review Comments
DSD Addressing
1 03/17/262026 Yes 1 David Wilging : DSD Addressing Building 1
2 03/17/262026 Yes 1 David Wilging : DSD Addressing Building 2
3 03/17/262026 Yes 1 David Wilging : DSD Addressing Building 3
4 03/17/262026 Yes 1 David Wilging : DSD Addressing Building 4
5 03/17/262026 Yes 1 David Wilging : DSD Addressing Building 5
6 03/17/262026 Yes 1 David Wilging : DSD Addressing Building 6
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
7 03/17/262026 Yes 1 David Wilging : DSD Addressing Building 7
8 03/17/262026 Yes 1 David Wilging : DSD Addressing If you would like suites to be added to the map, please provide a floor plan
as apart of the review.
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
03/31/2026 External Reviewers - Tucson Electric Power (TEP) Standard REQUIRES RESUBMIT March 30, 2026
WO#T179332
City of Tucson
Planning and Development Services
Attn: CDRC Admin Team
Dear CDRC Admin Team
Subject: CONVERTING MOTEL ROOMS
TD-DEV-1025-00259
Tucson Electric Power Company (TEP) has reviewed and cannot approve the
development plan submitted 3/17/2026. There are existing facilities within the
development which are depicted upon the plan. COMMENTS ONLY PLEASE
INDICATE APPROVAL WITH THE BELOW CHECK BOX PLEASE DO NOT ADJUST
IF THERE ARE NO COMMENTS Further: TEP Facilities and easements not shown on
development plan. Bk 234 Pg 275, Bk 476 Pg 466, Bk 3865 Pg 510, Bk 8791 Pg 851.
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
03/31/2026 Site Engineering Standard REQUIRES RESUBMIT Permit Activity Number: TD-DEV-1025-00259 (1st Review)
Project: Convert existing motel rooms into multi. family apartments.
Location: 314 E BENSON HY
Review Date: 3/31/2026
Reviewer: Marco Contreras – Engineering Associate - Site Engineering
Related Cases:

*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. Provide the development package case number, TD-DEV-1025-00259, adjacent to the title block on all sheets
2. Revise the sheet index to reflect all development package pages/sheets.
a. This should be done for the bottom corner sheet xx of xx as well. This would mean the total page count should be XX of 8 based on what the current DP file shows.
3. Revise ADA parking sign & post details page 8 (Sheet A-7 Detail 1&2) ) to show the required minimum height to be 7 feet minimum. This is required when the ADA sign is placed within a pedestrian pathway. TSM 7-01.4.3.B No change is required if they are not placed within a pathway/sidewalk area.
4. Provide the general note: “A single property owner, property management company, or homeowners association (HOA), will be responsible for the management and maintenance of the solid waste collection services and storage area(s) for all development/business occupants. TSM 8-01.5.1.D.
5. Show that this project falls in compliance with 8-01.5.1.A by providing possible space for solid waste and recycle collection services.
6. It appears the trash enclosure is referenced using keynote #4 on page 2 (Sheet A-1) when it should be keynote #5, revise accordingly.
7. Provide a keynote/call-out for all structure(s) downspouts and sidewalk scupper locations on the site plan (Sheet A-1). Any downspout shown to discharge on a pedestrian pathway/sidewalk will be required to be scuppered in compliance with TSM 7-01.4.1.E
8. Demonstrate how the new bicycle parking falls in compliance with TSM 7-01.4.D. It will be required that a sidewalk/established pathway be established to connect to the bicycle parking or the parking be moved to a better suited location with pedestrian connectivity. This will also need to be demonstrate for the new trash enclosure.
9. Based on aerial imagery and plan page A-6, it appears the southeast corner of the site where parking area is shown is entirely unpaved/dirt. In compliance with UDC 7.4.6.I, all vehicular use areas must be surfaced with approved dust control materials. Revise he plan set to make this clear. Include a construction detail showing the proposed surfacing.
10. Provide a construction detail relating to the new 6-foot fence proposed along the property boundary(s).
11. In reference to page A-6, it shows the trash enclosure existing over dirt/untreated area. This will not be acceptable in compliance with TSM 8-01.5.2.G & H.
12. Revise trash enclosure detail (Sheet A-7) sheets to show all the trash enclosures ramps slopes being 2% away from enclosure as well as the enclosure slabs sloping 1% to the gate. TSM 8-1.0.0
13. Revise the enclosure detail to show/include the required bollards. TSM 8-01.5.2.B
14. As the dirt area on the southeast will need to be surfaced per comment #9, City of Tucson drainage requirements will be triggered which will require the submission of a drainage report to demonstrate compliance with First-Flush retention & Balanced basin detention requirements.

If you have any questions or concerns, please contact Marco Contreras at Marco.contreras@tucsonaz.gov
04/10/2026 Site Landscape Standard REQUIRES RESUBMIT PLANNING AND DEVELOPMENT SERVICES DEPARTMENT
REVIEWER: CHAD KELLER, PLA
SITE LANDSCAPE/NATIVE PLANT PRESERVATION SECTION

PROJECT: CONVERT EXISTING MOTEL ROOMS INTO MULTIFAMILY APARTMENTS
ACTIVITY NO: TD-DEV-1025-00259
ADDRESS: 314 E BENSON HY
ZONING: COMMERCIAL ZONE (C-2)
LAND USE: MULTIFAMILY/CHANGE OF USE FULL LANDSCAPE CODE COMPLIANCE REQUIRED
2026.04.10

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

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

1. PER UDC ARTICLE 3.3.3.G.2.C - A SITE PLAN (DEVELOPMENT PACKAGE) is required for the following types of development: existing development undergoing a CHANGE OF USE, building structure additions, and/or reconfiguration of an area outside a building. A Development Package (DP) meeting the requirements of Administrative Manual (AM) 2-06 must be submitted and approved prior to approval of this building plan.

2. This change of use requires full site landscape compliance. If it is determined that any of the following site landscape standards cannot be met due to the nature of the development, then a Design Development Option (DDO) may be an option to gain partial relief from some landscape requirements, see UDC 3.11.1.B.3 for landscape and screening modifications allowed. A BOARD OF ADJUSTMENT VARIANCE TO THE UDC SITE LANDSCAPE REQUIREMENTS WILL LIKELY BE THE BEST COURSE OF ACTION DUE TO THE CONSTRAINTS PRESENT ON THIS EXISTING SITE. Please reach out to Mark Castro or Georgia Pennington with PDSD for more information on the DDO and Variance process. Mark.Castro@tucsonaz.gov – Georgia.Pennington@tucsonaz.gov

3. UDC 7.6.2. APPLICABILITY: Preparation of the landscape plans shall adhere to UDC 7.6 and Administrative Manual 2-10.

4. Parking lot canopy trees are required at 1 tree for every 4 parking spaces provided, see UDC 7.6.4.B. Structurally covered parking spaces do not count toward the ratio, see UDC 7.6.4.B.1.c (8). Trees are to be distributed evenly throughout the parking area, see UDC 7.6.4.1.a.(1). See Technical Standards Manual 5-01.3.0 for additional landscaping in vehicular use area requirements.

5. Interior landscape borders per UDC 7.6.4.C.3 and Table 7.6.4-1 and proposed Multifamily Land Use:
A. Interior landscape borders is required on Multifamily land use sites adjacent to residential zones. Provide the landscape border trees along the south property line.

6. Street landscape borders per UDC 7.6.4.C.2 and Table 7.6.4-1 and proposed Multifamily land use along MS&R and non-MS&R:
A. E Benson Hy requires a 10’ landscape border located on the project side of the ROW/Future ROW.

7. A drip irrigation plan and details are required for all proposed landscape planting areas.

8. DTM review is required for all planting and irrigation in the ROW prior to the approval of the development package. Reach out to David Marhefka (david.marhefka@tucsonaz.gov) for review and approval if applicable for this project.

9. All landscape plans shall incorporate water conserving design as defined in UDC Section 7.6.6, Use of Water, and as described in the Technical Standards Manual 5.01-5.11.

10. A Commercial Rainwater Harvesting plan is required: See Technical Standards Manual 4-01.3.0 RAINWATER HARVESTING PLAN. A Rainwater Harvesting Plan shall be submitted with all applications for commercial developments at which landscaping is required. The Rainwater Harvesting Plan shall consist of two elements: a Site Water Budget and a Water Harvesting Implementation Plan. Preparation of the Rainwater Harvesting Plan elements requires coordination between project managers, site engineers and landscape architects from the inception of the project. The two elements of the Rainwater Harvesting Plan shall illustrate water harvesting how will meet 50% of annual landscape water demand, as required by the ordinance.

11. Coordinate the Landscape Plan, Commercial Rainwater Harvesting Plan and the Civil Grading Plans to have identical basin size, grades/percent slopes, spot elevations and curb cut inlet and outlet locations.

12. Maximize rainwater harvesting across the site into all landscape areas, including the street landscape borders and planting islands for the required trees in the parking area.

13. A separate irrigation water meter is required. Please label irrigation meter as “irrigation only”. See TSM 4-01.6.0. Or see City of Tucson Ordinance 10597 -- Sec. 6-182. Rainwater Harvesting Plan: Number 3 (a) A separate water meter connected to the main water supply; or (b) An irrigation sub-meter.

14. Label sight visibility triangles and ROW (existing and future) on all landscape plans.

15. Include a construction detail showing root barriers for plants located near sidewalks and parking lots. (see Detail 402 located here: https://www.tucsonaz.gov/tdot/landscape-architects)

16. This is an existing site and does not appear to have any protected native plants growing on site. The NPPO will not be required for this project.

17. Prior to site landscape approval, ensure that Site Zoning and Site Engineering comments are fully addressed.

18. Include the Activity Number TD-DEV-1025-00259 on all sheets in the plan set.

Thank you.
Chad Keller, PLA
Landscape Architect
chad.keller@tucsonaz.gov
520.837.4923
04/20/2026 Site Zoning Standard REQUIRES RESUBMIT CDRC TRANSMITTAL

FROM:
Fernando Garcia
Site Zoning Review Section

PROJECT:
Development Package
314 E Benson Hy, Tucson, AZ 85713
TD-DEV-1025-00259 (2nd Review)

TRANSMITTAL DATE: April 20, 2026
DUE DATE: April 8, 2026

COMMENTS: Please resubmit revised drawings and any redlined plans along with a detailed response letter, which states how all Zoning Review Section comments were addressed.

Section 3.3.3.G.5.c UDC, an applicant has one year from the date of application to obtain approval of a site plan that complies with zoning and other development requirements in effect at the time of application, unless an ordinance adopted by Mayor and Council during this period states otherwise. A site plan application that has been in review for a period of one year and has not yet been approved is considered denied. To continue the review of a site plan for the property, a new site plan must be submitted that complies with regulations in effect at the time of re-submittal. The new submittal initiates a new one-year review period. One year expiration date is October 13, 2026.

SECTION 2-06.0.0: DEVELOPMENT PACKAGE (TENTATIVE PLATS AND SITE PLANS)

0. COMMENT: Remove all clouds and revision notes. For City of Tucson submittals, clouds and revisions are only provided only previously-approved plans that are undergoing a change from the approved version. Changes to unapproved plans are considered corrections.


CONTENT REQUIREMENTS

2-06.4.1 - The name, mailing and email addresses, and phone number of the primary property owner of the site, the developer of the project, registrant(s), and other person(s), firm(s), or organization(s) that prepared the development package documents shall be provided on the right half of the cover sheet. The applicable registration or license number shall be provided if prepared by or with the assistance of a registered professional, such as a surveyor, architect, landscape architect, or engineer. All sealing shall be consistent with Arizona Board of Technical Registration guidelines.

1. COMMENT: 2-06.4.1 – Pima County indicates the owner of this property to be “314 E BENSON LLC” rather than “OCOTILLO LLC”.


2-06.4.2.B - A brief legal description and a statement as to whether the project is a re-subdivision are to be provided. On re-subdivisions, provide the recording information of the existing subdivision plat;

2. COMMENT: 2-06.4.2.B – Provide legal description of the property under the location map. The legal description is “W216.3'' SE4 NE4 S FREEWAY & N40' W441.92’ E1545' SE4 & PTN SOUTHGATE LOT 10 BLK 2 2.38 AC SEC 25-14-13” according to the Pima County Assessor’s Office.


2-06.4.3 - The administrative street address and relevant case numbers (development package document, subdivision, rezoning, board of adjustment, DDO, MDR, DSMR, overlay, etc.) shall be provided adjacent to the title block on each sheet.

3. COMMENT: 2-06.4.3 - Provide the development package case number, TD-DEV-1025-00259, adjacent to the title block on each sheet.


2-06.4.4.B - Identify major streets and regional watercourses within the square mile area and all streets that abut the subject property; and,

4. COMMENT: 2-06.4.4.B – Provide requested information.


2-06.4.4.C - Section, township, and range; section corners; north arrow; and the scale will be labeled.

5. COMMENT: 2-06.4.4.C – Provide requested information.


2-06.4.7 - General Notes
The following general notes are required. Additional notes specific to each plan are required where applicable.

Zoning and Land Use Notes

2-06.4.7.A.1 - List as a general note: "Existing zoning is ____."

6. COMMENT: 2-06.4.7.A.1 – The subject parcel has split zoning. Indicate that the “Existing zoning is C-2 and R-2”. Remove General Note #1 “Conditions of Rezoning/Original City Zoning”.


2-06.4.7.A.2 - List the gross area of the site/subdivision by square footage and acreage.

7. COMMENT: 2-06.4.7.A.2 – Provide requested information in a new General Note.


2-06.4.7.A.4 - Identify the existing and proposed use of the property as classified per the UDC. List all UDC sections applicable to the proposed uses.

8. COMMENT: 2-06.4.7.A.4 – Provide requested information in new General Note: “The existing use is Commercial Use Group – Traveler’s Accommodation (Lodging). The proposed use is Residential Use Group – Multifamily Development. The existing use on adjacent parcel 119-01-074A is “Commercial Use Group – Food Service, excluding soup kitchen”.


2-06.4.7.A.8 - For development package documents provide:

On the site plan, depict parcel 119-01-074A (310 E Benson Hy), including any structures, sidewalks, dumpsters, parking spaces, PAALs, landscaping, and accessory structures on the site. Include the square footage of the building. Although a separate parcel, because the adjacent parcel shares both access and parking within the proposed multifamily development, it is considered one site. As such, the development package calculations will also need to account for the restaurant use, to include indicating that enough parking is provided on site for both uses.

For reference, the City of Tucson Unified Development Code definition of “site” is as follows in UDC 11.4.20: “The land area consisting of a portion of a lot, an entire lot, or contiguous lots, not including dedicated public property, designated for development as a single entity.”

2-06.4.7.A.8.a - Floor area for each building;

9. COMMENT: 2-06.4.7.A.8.a – Depict and label square footage for adjacent restaurant building.


2-06.4.7.A.8.b - Percentage and area in square feet of building and accessory building coverage;

10. COMMENT: 2-06.4.7.A.8.b – Provide requested information (include restaurant building).


2-06.4.7.A.8.c - Percentage of building, lot area, or vehicular use area expansion. If the building(s) or lot area have been previously expanded, those calculations shall be included; and,

11. COMMENT: 2-06.4.7.A.8.c – Provide requested information. If none, indicate so.


2-06.4.8 - Existing Site Conditions
The following information shall be provided on the plan/plat drawing to indicate the existing conditions on site and within 50 feet of the site. On sites bounded by a street with a width of 50 feet or greater, the existing conditions across the street will be provided.

2-06.4.8.A - Provide site boundary/subdivision perimeter information, including bearing in degrees, minutes, and seconds, with basis for bearing noted, together with distances in feet, to hundredths of a foot, or other functional reference system.

12. COMMENT: 2-06.4.8.A – Dashed gray lines labeled “Property Line” with dimensions cut through the subject parcel. Remove these.


2-06.4.8.B - All easements shall be drawn on the plan. The recordation information, location, width, and purpose of all easements on site will be stated. Blanket easements should be listed in the notes, together with recordation data and their proposed status. Should an easement not be in use and be proposed for vacation or have been abandoned, so indicate. However, should the easement be in conflict with any proposed building location, vacation of the easement shall occur prior to approval of plan unless written permission from easement holder(s) is provided.

13. COMMENT: 2-06.4.8.B – Draw, dimensions, and label existing easements (with recordation numbers labeled) with the adjacent parcel that allow shared access and parking. Also draw, dimension, and label the parking areas dedicated to each of the restaurant and motel/apartment use per the “First Amendment to Declaration of Covenants, Conditions, Restrictions, and Easements” as recorded in sequence #20212020855.


2-06.4.9 - Information on Proposed Development
The following information on the proposed project shall be shown on the drawing or added as notes.


2-06.4.9.F - All existing zoning classifications on and adjacent to the project (including across any adjacent right-of-way) shall be indicated on the drawing with zoning boundaries clearly defined. If the property is being rezoned, use those boundaries and classifications. The basis for this requirement is that some zoning requirements on a project are based on the zoning classification of adjacent property. Also, in some instances, each zone has to be taken into consideration on property that is split by two or more zoning classifications, as each may have different requirements.

14. COMMENT: 2-06.4.9.F – Draw and label the zoning boundary change between C-2 and R-2 on the property. For reference see MapTucson at https://maps2.tucsonaz.gov/.


2-06.4.9.H.5 - If utilizing parking area access lanes (PAALs), they shall be designed in accordance with Section 7.4.6, Motor Vehicle Use Area Design Criteria, of the UDC.

15. COMMENT: 2-06.4.9.H.5 – Dimensions all parking area access lanes (PAAL). Ensure measurements meet the minimums indicated in UDC Figure 7.4.6-A and Table 7.4.6-1 for one-way and two-way lanes, to include PAALs located completely or partially on the restaurant parcel.

2-06.4.9.H.5.a - Show all motor vehicle off-street parking spaces provided, fully dimensioned. As a note, provide calculations on the number of spaces required (include the ratio used) and the number provided, including the number of spaces required and provided for the physically disabled. The drawing should indicate parking space locations for the physically disabled. A typical parking space detail shall be provided for both standard parking spaces and those for the physically disabled. For information on parking requirements for the physically disabled, refer to adopted building and accessibility codes of the City of Tucson. Design criteria for parking spaces and access are located in Section 7.4.6, Motor Vehicle Use Area Design Criteria, of the UDC.

16. COMMENT: 2-06.4.9.H.5.a – Provide at least one reference parking space dimension in every row or separate area of parking.

One sheet A-7, correct the typical accessible parking detail to show that the space between the middle of the wheel stop and the curb is 2.5’, not 2’.

Label parking areas per the CC&Rs recorded at #20212020855. Update the parking calculations table to

Move vehicle and bicycle parking calculations tables to same sheet.

Calculations for electric vehicle supply equipment (EVSE) are incorrect. Per UDC Table 7.4.11-1, for “Multifamily Development”, the required number of “EV Installed” is none. The required number of EV Ready is 10% of total parking spaces provided. The required number of EV Capable is 20% of total parking spaces provided.” Correct the EV calculations table to indicate what is required and what is provided with correct nomenclature.

Both the southern parking area and the semi-circular area next to the apartment office (formerly a landscaped lawn) appears to not meet minimum requirements for parking surface as indicated in UDC 7.4.6.I. These parking areas also appears to be an unpermitted addition to the last-approved site plan. As such, it would be required to meet current code requirements, including the requirement for a curb-separate sidewalk between the parking area and the face of any immediately adjacent buildings as described in UDC Technical Standards Manual 7-01.9.0, Figure 2 (https://codelibrary.amlegal.com/codes/tucson/latest/tucson_az_udc/0-0-0-11644). Otherwise, this area would need to revert to a landscape use as shown on the last-approved site plan.

The parking calculations table indicates that a total required count of 95 vehicular parking spaces is required. Provide parking calculations for both the subject parcel and the adjacent restaurant parcel. In the updated parking calculations table, clearly indicates how many of on-site parking spaces are limited to either the multifamily use or the restaurant use as indicated in the CC&R recorded at #20212020855. The approved plan for the lot split of this site in 2007 at https://pro.tucsonaz.gov/plandetails/S07-141/ shows an approved parking count for the restaurant of 51 spaces. Although this is a nonconforming amount, it may remain as such (absent a change of use on that parcel, or an expansion).


2-06.4.9.H.5.d - Show bicycle parking facilities fully dimensioned. For specifics, refer to Section 7.4.9, Bicycle Parking Design Criteria, of the UDC. Provide, as a note, calculations for short and long term bicycle spaces required and provided.

17. COMMENT: 2-06.4.9.H.5.d – Per UDC 7.4.9.C.2, “Short-term bicycle parking must be within 50 feet of each public entrance to a building as measured along the most direct pedestrian access route.” The templated location near the southern dumpster does not meet this criteria.

Long-term bicycle parking must meet the design requirements indicated in UDC 7.4.9.D. The provided bicycle parking area does not appear to meet these requirements, including security, weather protection, signage, and lighting. Alternatively, long-term bicycle parking may also be located within individual units. If so, provide a general note and indicate on the separate building plans, where inside each unit the long-term bicycle parking is located.


2-06.4.9.O - All applicable building setback lines, such as erosion hazard, floodplain detention/retention basins, and zoning, including sight visibility triangles, will be shown.

18. COMMENT: 2-06.4.9.O – Dimensions the setback of the proposed dumpster location along the southern property line to the property line. Indicate the height of the dumpster enclosure wall. At minimum, this dumpster enclosure must be at lest 10’ set back from the adjacent property line per UDC Table 6.3-2.A. Likewise provide the same information for the dumpster along the western property line that currently is on site.


2-06.4.9.R - Show on-site pedestrian circulation and refuge utilizing location and the design criteria in Section 7-01.0.0, Pedestrian Access, of the Technical Standards Manual.

19. COMMENT: 2-06.4.9.R – Draw, dimension, and label all pedestrian circulation. A pedestrian circulation path is required to connect all public areas of a development, including to the restaurant, dumpsters, and bicycle parking areas, and to any existing sidewalk along the right-of-way.

Per UDC Technical Standards Manual 7-01.4.0 requires sidewalks (rather than crosswalks) in the following circumstances:
B. A sidewalk is required adjacent and parallel to any access lane or PAAL on the side where buildings are located (See Figure 1);
C. A sidewalk is required adjacent to any parking space accessed by a PAAL where the space is located on the same side of the PAAL as any building and no other parking spaces or PAALs intervene (See Figure 2).


2-06.4.9.W - Indicate the locations and types of proposed signs (wall, free-standing, pedestal) to assure there are no conflicts with other requirements and that minimal locational requirements can be met. Indicate if there are any existing billboards on site. Compliance to the Sign Code, Chapter 3 of the Tucson Code, is required. Include a note stating all signage requires separate permits.

20. COMMENT: 2-06.4.9.W – Indicate location of signage, provide dimensions, and place a note that “Signage per separate permit”. If adjacent to a vehicular travel lane, indicate setback distance from the sign to the travel lane.

***For additional information on the any standard presented in this memo, please refer to the City of Tucson “Unified Development Code” – Administrative Manual Section 2-06 or Technical Standards noted in the comments. https://www.tucsonaz.gov/pdsd/all-codes-plans-determinations


If you have any questions about this transmittal, contact Site Zoning Reviewer Fernando Garcia at fernando.garcia2@tucsonaz.gov.

RESUBMITTAL OF THE FOLLOWING IS REQUIRED: Revised development package and comment response letter. To resubmit visit Tucson Development Center at https://tdc-online.tucsonaz.gov/#/home.
Instructions for resubmittal - https://www.tucsonaz.gov/files/pdsd/website/Resubmittals.pdf.
03/17/2026 CDRC Review Coordinator Express REVIEW COMPLETED CDRC added Addressing, TAA, ADOT, TEP, PAG, USPS, and SWG to the workflow. Review request email sent to Addressing, TAA, ADOT, and TEP. FYI email sent to PAG, USPS, SWG.
03/25/2026 External Reviewers - Arizona Department of Transportation (ADOT) Standard REVIEW COMPLETED ADOT has no comments.
03/17/2026 External Reviewers - Pima Association of Governments Standard REVIEW COMPLETED CDRC sent FYI email sent to PAG, USPS, SWG. No further action is required.
03/17/2026 External Reviewers - Southwest Gas Standard REVIEW COMPLETED CDRC sent FYI email sent to PAG, USPS, SWG. No further action is required.
03/31/2026 External Reviewers - Tucson Airport Authority Standard REVIEW COMPLETED March 29, 2026
Planning and Development Services
City of Tucson
201 North Stone Avenue
Tucson, AZ. 85701
RE: TD-DEV-1025-00259, 1st Submittal, Converting motel rooms / 314 E. Benson Highway,
Tucson, AZ. 85713, Received March 17, 2026
To whom this may concern,
Thank you for the opportunity to comment on TD-DEV-1025-00259, 1st Submittal, a
development plan for converting an existing motel and into a multifamily apartment at 314 E.
Benson Highway. This development is located in the S.E. quarter of the N.E. quarter of Section
25, Township 14S, Range 13E, of the Gila and Salt River Meridian. The development site
occupies parcel number 119-01-046C, covers approximately 2.38 ± acres, and is zoned as
Commercial 2 Zone (C-2). The nearest major roadway intersection is South 6th Avenue and
Interstate 10, approximately 1,200 feet to the northeast of the subject development.
This site does lie within the Tucson International Airport avigation easement requirements and
public disclosure area, FAA traffic pattern airspace, and FAA Part 77 airspace.
The Tucson Airport Authority does not object to the 1st submittal of this project and does not
require a resubmittal of this project.
Although this project does not propose a change in plan designation or zoning the Tucson
Airport Authority highly recommends the applicant add the following notes into the general notes
of the revised development plan. This project is located approximately 3.75 miles northwest of
Tucson International Airport and is within FAA traffic pattern airspace, an area which would be
subject to aircraft overflight and noise due to being in close proximity to Tucson International
Airport.
The proposed notes would provide a means of assuring that future owners and tenants of the
property are aware they are in proximity an airport and further assures the continued right of the
City of Tucson, Tucson Airport Authority, and all persons lawfully utilizing the Tucson
International Airport the right to utilize the airspace above or near the property. This would be
accomplished through the property owner recording the Avigation Easement and providing the
Airport Disclosure Statement to the new residents of all residential uses. The Tucson Airport
Authority believes the proposed note helps to support the City of Tucson Airport Environs
Overlay Zone and supports Plan Tucson – Land Use 26.
1. "That prior to the City's approval of the proposed development, the property owner must
record the Avigation Easement that discloses the existence and operational
characteristics of the Tucson International Airport to future owners or tenants of the
property and further conveys the right to the public to lawfully use the airspace above the
property. The Avigation Easement shall be recorded in a manner with the Pima County
recorder which shall document it as having title liability. The content of such documents
shall be according to the form and instructions provided.”
The current property owner or person authorized to sign on behalf of the current property
owner must complete, sign, and record the Avigation Easement. Please record the
Avigation Easement with the Pima County Recorder’s Office. Then send a complete
copy of the recorded easement document to Tucson Airport Authority by either email
(send to srobidoux@flytucson.com) or to the mailing address provided below.
Scott Robidoux
Manager of Planning
Tucson Airport Authority
7250 South Tucson Blvd, Suite 300
Tucson, AZ 85756”
2. Applicable to residential uses only
“The property owner/developer/applicant must provide the Airport Disclosure Statement
form, at time of sale, to the new property owners with all new unit purchases. In the
event the development of any residential uses does not involve the sale of new units but
is instead offering rental residential units to the public, the new tenant of the rental unit
must be provided a copy of the Airport Disclosure Statement form. The intent of the
Airport Disclosure Statement form is to educate and notify the new residents that they
are living near an airport. The content of such documents shall be according to the form
and instructions provided.”
The property owner (for itself or its tenants) shall forward a signed copy of the Airport
Disclosure Statement form to the Tucson Airport Authority within ten (10) days of
signature, using the Scott Robidoux mailing address provided above.
Please do not hesitate to contact me if you have any questions or concerns regarding this
comment letter. I can be reached by email at srobidoux@flytucson.com or by telephone at 520-
573-4811.
Respectfully,
Scott Robidoux, C.M.
Manager of Planning
cc file
03/17/2026 External Reviewers - United States Postal Service (USPS) Standard REVIEW COMPLETED CDRC sent FYI email sent to PAG, USPS, SWG. No further action is required.
04/08/2026 Fire New Construction Standard REVIEW COMPLETED
03/12/2026 OK to Submit - Engineering Fast REVIEW COMPLETED Add Environmental Services to the Review cycle as Trash Enclosure/trash service included within scope of work
03/16/2026 OK to Submit - Zoning Fast REVIEW COMPLETED
03/25/2026 ROW Engineering Review Standard REVIEW COMPLETED Outside COT public ROW. Coordinate with ADOT for offsite related permits