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Permit Number: TD-DEV-1224-00324
Parcel: 13216012Q

Address:
1767 E BENSON HY

Review Status: Requires Resubmit

Review Details: DEVELOPMENT PACKAGE NEW v.5

Permit Number - TD-DEV-1224-00324
Review Name: DEVELOPMENT PACKAGE NEW v.5
Review Status: Requires Resubmit
Review Date Reviewer's Name Type of Review Description Status Comments
05/06/2026 Site Engineering APPROVED
05/07/2026 Site Zoning APPROVED Proof of Pima County Lot Combo Approval Provided
05/19/2026 External Reviewers - Arizona Department of Transportation (ADOT) REQUIRES RESUBMIT May 15, 2026
Mr. Sean Messner, PE
CivTech, Inc.
10605 North Hayden Road, Suite 140
Scottsdale, AZ 85260
Re: Northwest Corner (NWC) of Kino Pkwy. and Benson Hwy. (South of the I-10 TI)
Traffic Impact Analysis (TIA) for Parkside Reserve – April 2026
Dear Mr. Messner:
This letter is being sent to provide comments on the Traffic Impact Analysis (TIA) dated April 27, 2026,
and received May 8, 2026, for the proposed Parkside Reserve development located in the northwest
corner (NWC) of Kino Pkwy. and Benson Hwy. (south of the I-10 TI) in Tucson, AZ. The proposed
development is requesting three (3) driveway access points: one (1) full access onto Kino Pkwy. and two
(2) right-in/right-out accesses onto Benson Hwy.
The proposed development would consist of 210 multi-family units. According to the ITE Trip Generation
Manual, 12
th Edition, LUC 221, the proposed development is estimated to generate 938 weekday daily
trips, with 80 trips occurring during the AM peak hour and 79 trips occurring during the PM peak hour.
Below you will find comments on the traffic study that need to be addressed prior to acceptance.
● General: “Arizona Department of Transportation (ADOT)” should be added to the “Submittal to”
line of the cover pages.
● Page 1 - Executive Summary: Please correct the typos stating that the opening year will be 2025
or 2026. The opening year should be 2027.
● Page 1 - Executive Summary: ADOT TGP 240 should be discussed. This TIA is also a Category I TIA
per TGP 240 guidelines. However, ADOT guidelines require a horizon year to be analyzed 3 years
after the opening year.
● Page 3 - Executive Summary - 4th bullet point on the page: The westbound off-ramps are also
being reconfigured. Please revise the first two sentences of the bullet point to read: “ADOT is
reconfiguring the interchange of Kino Parkway and Interstate 10 as a diverging diamond
interchange (DDI).”
● Page 5 - Study Area:
o The same intersection is provided in two separate bullet points. Please combine “Kino
Parkway and Benson Highway” and “Campbell and Benson Highway”.
o The Study Area will need to include the I-10 and Kino Pkwy. TI, which is currently being
redesigned as a Diverging Diamond Interchange (DDI) as part of a Design Build project.
The relevant plans can be obtained via a public records request:
https://azdot.gov/adot-news/public-information-and-records-request
o Please revise “Ajo Way and I-10 WB Ramps” to “Ajo Way and Ajo Way Connector”.
o Please revise “Kino Parkway and Ajo Way” to “Kino Parkway and Ajo Way Connector”.
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● Page 5 - Study Horizon Year: As stated above, an additional horizon year (2030) will need to be
analyzed.
● Page 6 - Surrounding Land Use: Please include that the proposed development would surround
the existing Anytime Storage.
● Page 8 - Intersection Configuration:
o Please revise “Kino Parkway and Ajo Way” to “Kino Parkway and Ajo Way Connector”.
The WB left operates with protected phasing as there is no opposing thru movement.
o Please revise “Ajo Way and I-10 WB Ramps” to “Ajo Way and Ajo Way Connector”. This
will now be a three-legged intersection with protected-permitted phasing on the EB &
WB approaches (the existing WB left turn lane will be converted to a U-Turn Only lane)
and protected phasing on the SB approach. The SB approach will consist of two
dedicated left turn lanes and one dedicated right turn lane. The WB approach will
consist of one dedicated right turn lane, two dedicated through lanes, and one
dedicated U-turn lane. The EB approach will consist of one dedicated left turn lane and
two dedicated through lanes.
● Page 15 - Trip Generation: Land Use Code 220 (Low-Rise) should be used rather than Land Use
Code 221 (Mid-Rise), as the multi-family housing will consist of 3-story buildings.
● Page 16 - Table 5 - Site Trip Distribution:
o Please revise the first two rows to read “Southeast on I-10” and “Northwest on I-10”.
o Please revise the third and fourth rows to read “North on Kino Parkway” and “South on
Campbell Avenue”.
o Please revise the sixth row to read “Northwest on E Benson Highway”.
● Page 20 - Figure 7 - 2027 Background Traffic Volumes: The EB volumes at Driveway A do not
match what is shown in the Maverik TIS.
● General: Please update the Executive Summary and Conclusions sections of the report after
addressing the above comments.
The ultimate success of the Development will require coordinated efforts with ADOT and the City of
Tucson.
The developer/owner will need to complete an ADOT Encroachment Permit Application and have a
signed Permit before commencing work within State Right-of-Way. The On-Site Plans and Off-Site
Improvement Plans, including the civil plans, traffic plans, and other requirements of the Encroachment
Permit will need to be submitted to the Southcentral District Permits Office in Tucson for review and
approval by the appropriate disciplines. Additional information can be found on ADOT’s website at
https://azdot.gov/business/permits/encroachment-permits.
Questions regarding the permit requirements, application, or process should be directed to the ADOT
Southcentral District Permits email address: southcentralpermit@azdot.gov.
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If you have any questions, comments, or concerns regarding the mitigation measures or requirements
necessary for approval of the TIA, please call me at (520) 388-4203, or email me at rfreije@azdot.gov.
Sincerely,
Richard S. Freije, P.E.
Southern Regional Traffic Engineer, ADOT
1221 S. 2nd Ave.
Tucson, AZ 85713
Office: 520-388-4203
rfreije@azdot.gov
CC: Jeremy Moore, PE, Southcentral District Administrator, ADOT
Priscilla Thompson, PE, Assistant Southcentral District Engineer, ADOT
Michelle Garza, Southcentral District Permits Supervisor, ADOT
Allen Wallace, Southern Region TE Specialist, ADOT
Blake Olofson, PE, PTOE, Traffic Engineering Administrator, City of Tucson
Greg Orsini, PE, PTOE, Department of Transportation and Mobility, City of Tucson
05/06/2026 Floodplain Administration Review REQUIRES RESUBMIT For clarification the following 2 comments are provided:
1. PC approval documentation must be submitted before issuance of this permit
2. Wall detail can be provided to PDSD by wall designer at the time of separate structural wall permit review to clarify sufficient cover.
For questions please contact:
Elizabeth Eberbach
520-429-4905
Elizabeth.Eberbach@tucsonaz.gov