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Permit Number: T06CM05565
Parcel: 130010050

Review Status: Completed

Review Details: RESUBMITTAL - SITE

Permit Number - T06CM05565
Review Name: RESUBMITTAL - SITE
Review Status: Completed
Review Date Reviewer's Name Type of Review Description Status Comments
01/08/2007 ELIZABETH EBERBACH ENGINEERING REVIEW Denied TO: Patricia Gehlen; CDRC Manager
SUBJECT: Railroad W.A.S.H., Grading/Site, Floodplain Use Permit Re-submittal Engineering Review
REVIEWER: Elizabeth Eberbach
ACTIVITY NUMBER: T06SA00260, T06OT02735, T06CM05565, T06BU02535

SUMMARY: Development Services Department Engineering Division has done a review of the received items including the revised W.A.SH. Report package. This resubmittal represents proposed mitigation to resolve the disturbance and proposed development at the site. Engineering does not recommend approval of the overlay package at this time. The comments from Landscaping, Zoning and Engineering will need to be addressed and returned to determine whether sufficient information is provided addressing comments, so that SAC can be scheduled. This would assume there are no substantial issues remaining after addressing the above reviews by the Landscaping and Engineering reviewers. The Drainage Report was reviewed for overlay purposes only.

PROJECT SAC SUMMARY: The Railroad project proposes mitigation and proposed development encroachment into the Railroad W.A.S.H. Ordinance wash over a length of approximately 4,000 feet. The existing Railroad Wash is within a FEMA Special Flood Hazard Zone AE and consists of a constructed channel, approximately 6 feet deep and top width 40 feet, with earthen bottom and 1.5:1(H:V) side slopes, and has an existing 3-ft deep concrete toedown plates running along the toe of the slopes. Proposed encroachment includes proposed gantry railroad structure, a relocation/new access entrance that crosses the W.A.S.H. A mitigation plan is expected to address disturbance activities which occurred in June 2006, where approximately 4,000 feet of the wash was bladed and trees were removed in the channel and slopes of the wash. From aerials, there was minimal previous vegetation within the north Study Area prior to disturbance. Engineering does not recommend SAC scheduling until the following W.A.S.H. and associated grading comments are addressed.

GRADING/SITE PLAN, FLOODPLAIN, AND W.A.S.H. OVERLAY COMMENTS:
1) Tucson Code Sec. 29-15(b)(1): The W.A.S.H. Report submitted does not completely address all of the items listed in this section of the Tucson Code. Revise the W.A.S.H. Ordinance Report to address the following remaining comments:
a) Include in the discussion and acknowledgement of the W.A.S.H. disturbance in section 1.1 that this report represents part of the mitigation efforts. Clarify/remove the word "potential" from pages 1 and 16, regarding discussion of revegetation.
b) Tucson Code Sec.23A-50.(2): As stated previously:
i) After adequately addressing the comments for this submittal and acceptance of the review package is provided by DSD, the W.A.S.H. submittal package will need to proceed to City of Tucson stormwater committee(s) for review including Stormwater Advisory Committee. SAC is required since there are proposed placement of structures, paths of any type, and other grading disturbance proposed within the Study Area.
ii) Tucson Code Chapter 23A.Article II.Division 3.Sec.23A-50: Full notice procedure may be required for proposed disturbance within the study area. Contact CDRC Manager for further information.
iii) Tucson Code Sec. 29-15(b)(1): Since a portion of the 50-ft study area has been disturbed and is proposed to be developed, a W.A.S.H. Mitigation Plan shall be included in the W.A.S.H. Report. In section 4.0 of the report, the proposed mitigation is stated as pruning and removing debris. Explain how and where (whether on south bank or other location) vegetation will be placed as mitigation and show on a mitigation exhibit.
c) Provide a seal for:
i) The portion of the ERR that is the W.A.S.H. Report.
ii) The SWPPP Report.
d) Tucson Code Sec.29-15(b)(1): Address the following element comments:
i) Element c -clarify existing Fairland Stravenue right-of-way along the wash in section 5.3 of report and where the south 50-foot Study Area overlaps the railroad area and Fairland Stravenue. Clarify right of way on W.A.S.H. exhibit. Response letter states that the COT owns the south bank however there is documentation including a Final Plat and right-of-way plans that indicates a portion of the south bank lies in the railroad property. Clearly depict railroad property limits and right-of-way on exhibit and update verbiage in W.A.S.H. Report.
ii) Element e -
(1) W.A.S.H. report refers to shallow overbank flooding occurring in existing conditions. Given that the vegetation stumps that remain in the channel are growing back, discuss in section 5.5 whether there is a consideration to a change in the Mannings value for this stretch of the wash and whether there would be a significant increase in the water surface. This was unclear in response letter as it was stated that the WSEL would return to pre-developed conditions, however the W.A.S.H. Report section 5.5 stated that the stumps are growing back and would likely cause increased flooding potential. Revise and clarify pre-disturbed, existing, and future flood potential in W.A.S.H. Report.
(2) On figure 2, the leaders for the 100-yr floodplain limits appear to be incorrectly pointing to the flood limits. Correctly label floodplain limits on this exhibit.
iii) Element g - Clarify discussion in section 5.7 of the report for sediment transport characteristics for the post-disturbed wash as compared to pre-disturbed conditions - specifically as identified by inspectors for the downstream sediment build-up directly downstream of the area disturbed.
iv) Element h - There are existing power, sewer, gas utilities along the wash; these need to be clearly identified on both the grading plan and on the W.A.S.H. exhibit. Figure 2 is hard to read as scale is small and delineations run together; provide other exhibit showing all utilities and clarify using differentiated linetypes.
v) Element i- Address the following geotechnical evaluation comments:
(1) Regarding the geotechnical assessment for the gantry supports, provide geotechnical engineer's clarification with regard to setback from the top of bank.
(a) This should be based on some type of support system recommended by a structural engineer. Specifically, it is imperative that the construction for the proposed structure is clearly defined with respect to the distance near or into the W.A.S.H. embankment. Provide description/dimensions of gantry base-support that analysis is based on, in section 8.2 of Geotechnical Evaluation.
(b) Clarify/show this disturbance area for the gantry support system on the grading plan and on the W.A.S.H. exhibit that clarifies worst case scenario minimum distances from gantry support structure to top of wash.
vi) Tucson Code 29-12 (a-d): Regarding the conclusion/summary as to how the proposed project meets the intent of the ordinance. Consider adding that there will be no further disturbance, other than that maintenance as outlined in the WA.S.H. Report. It was stated in section 5.5 that as the stumps regrow flooding potential increases. Provide a substantial maintenance program that addresses specific recommendations for W.A.S.H. maintenance within the railroad property. Add maintenance outline to W.A.S.H. Report for SAC review.
e) Tucson Code 29-16(b): On W.A.S.H. exhibit and grading planview, clarify W.A.S.H. Ordinance limits. Provide a larger scale figure 3 that addresses the following clarifications:
i) a 50-ft offsets for the 50-ft Study Areas for both sides of the wash,
ii) any delineation for the remaining resource area found within that study area,
iii) the extents of East Fairland Stravenue right-of-way.
f) On figure 2, explain what an EPG 300-ft corridor is.
2) Address the following remaining comments:
a) For SWPPP report:
i) Provide a SWPP exhibit that addresses the following:
(1) Provide a general location map on an exhibit that identifies the receiving waters. Add to table of contents.
ii) Provide copy of the General Permit within report.
3) In summary, there are essential items needed for the W.A.S.H. / ERR Report approval; it is important that the W.A.S.H. / ERR Report for the Railroad project clarifies the following items:
a) Clarify change in conveyance of the Railroad W.A.S.H. occurred due to the disturbance from June 2006.
b) Clarify change in sediment transport characteristics due to the regrowth of vegetation in the Railroad W.A.S.H. after the disturbance from June 2006.
c) The Gantry structure is placed within the 50-ft Study Area. Clarify how much of disturbance will be necessary to construct the Gantry support structure beyond the 8-ft setback indicated. It is important that any disturbance of the north bank of the Railroad W.A.S.H. be disclosed in the report.
d) Location of the mitigation needs clarification to assure that the proposed revegetation does not negatively impact conveyance within the Railroad W.A.S.H.
e) Right-of-way of E Fairland Sv needs clarification on plans with respect to the top of south bank of the wash and the railroad property.
f) Provide a maintenance plan for Railroad W.A.S.H.

Once you have addressed the comments, you are welcome to set up a meeting to go over the comments. A floodplain use permit will be issued concurrently with the grading plan once approved. For the resubmittal, provide 4 copies of the revised grading/site plan, 4 copies of the revised SWPPP, and two copies of the revised W.A.S.H. Report with revised exhibits discussed in the above comments, a bound copy of the geotechnical report, response letter, and any other supporting documentation. The next submittal should address all the above W.A.S.H. items and grading items in order to determine SAC scheduling. If you have further questions or would like to set up a meeting, call me at 791-5550, extension 2204.

Elizabeth Eberbach, P.E., CPM, CFM
Civil Engineer
Engineering Division
Development Services
12/20/2006 JOE LINVILLE LANDSCAPE REVIEW Denied 1. The project is subject to the provisions of the Watercourse, Amenities, Safety, and Habitat Ordinance (WASH), TCC 29. Include WASH approval documentation with re-submittals. Indicate on the lower right hand corner of the site plan, the case number, date of approval, and any conditions imposed. The site application will be reviewed for compliance only when the approved documents are included in the submittal.

2) Submit a detailed landscape plan per DS 2-07 to document compliance with the WASH Report proposal and with the following comment from the previous review.

The addition to the site of outdoor storage of concrete ties is subject to the provisions of LUC 3.7. Refer to LUC Table 3.7.2-I for landscape border and screening requirements.
A six-foot high screen and a 10' street landscape border is required where the new land use is within 100' of the public street. Revise the plans to provide the required screening and landscape borders. Up to five feet of the required street landscape border may be located in the public right-of-way, if approve by the TDOT City Engineer.
12/20/2006 PATRICIA GEHLEN ZONING REVIEW Denied Please revise plans to reflect comments from first review. Plans do not have notes as requested.
12/20/2006 JOE LINVILLE NPPO REVIEW Denied Submit Native Plant Preservation Plan per DS 2-15.0 or Application for Exception; include with application acceptable documentation, which clearly indicates that the project will not impact Protected Native Plants.

Final Status

Task End Date Reviewer's Name Type of Review Description
01/18/2007 SUE REEVES OUT TO CUSTOMER Completed